Process Safety Management Program for Contractors

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Clinton Oliver
5 years ago
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1 Page 1 f 7 Sect: 1.0 Purpse This sectin cntains requirements fr Ardent (Cntract Emplyer) and ur subcntractrs fr assisting ur clients in preventing r minimizing the cnsequences f catastrphic releases f txic, reactive, flammable, r explsive chemicals during ur wrk. 2.0 Scpe and subcntractrs under the Management prgram are thse wh are invlved in the prviding services n r the installatin f equipment at client s facilities. All cntractrs and subcntractrs, cvered in this PSM Prgram will be prvided necessary infrmatin cncerning the scpe f wrk and the ptential hazards invlved. 3.0 Regulatry References This Management Prgram is primarily intended t satisfy requirements cntained in the fllwing regulatry dcuments: 29 CFR , 4.0 Respnsibilities 4.1 Management Respnsibilities as a Cntract Emplyer - relative t perfrming wrk n r adjacent t client s prcesses, prcess equipment r hazardus materials cvered by the 29 CFR , standard. Ensure that Ardent Emplyees are trained in wrk practices necessary t safely perfrm assigned wrk including Permit t Wrk prcedures. Ensure that Ardent Emplyees are instructed in the hazards related t prcesses, prcess equipment r hazardus materials assciated with their assigned wrk and wrk lcatins. Ensure that Ardent Emplyees are instructed in their respnsibilities under the Emergency Preparedness and Respnse plans. Ensure that training and instructin dcumentatin is maintained. Ensure that Ardent Emplyees are trained and fllw the safety rules and safe wrk practices f the facilities which they are assigned t wrk. Infrm the client f any unique hazards created by the executin f Ardent wrk r hazards discvered by Ardent emplyees nt previusly identified.

2 Page 2 f 7 Sect: 4.2 Supervisrs Be familiar with and understand the requirements f this Management Prgram. Arrange/facilitate training and instructin sessins required t ensure Ardent Emplyees are trained in wrk practices necessary t safely perfrm assigned wrk including Permit t Wrk prcedures Arrange/facilitate training and instructin sessins required t ensure Ardent Emplyees are instructed in the hazards related t prcesses, prcess equipment r hazardus materials assciated with their assigned wrk and wrk lcatins. Arrange/facilitate training and instructin sessins required t ensure Ardent Emplyees are trained and fllw the safety rules and safe wrk practices f the facilities which they are assigned t wrk. Identify and understand Ardent s and Ardent s Emplyees duties and respnsibilities under the Emergency Preparedness and Respnse plans. Arrange/facilitate training and instructin sessins required t ensure that Ardent Emplyees are instructed in their respnsibilities under the Emergency Preparedness and Respnse plans. Secure and maintain all required dcumentatin under this Management Prgram. Lead r participate in incident investigatins. Infrm the Ardent business unit if assistance frm the Ardent Safety Manager is required during any incident investigatins. Cmplete and prvide the client with all required incident investigatin dcumentatin including all reslutins r crrective actins. 4.3 Emplyees Respnsibilities - relative t perfrming wrk n r adjacent t client s prcesses, prcess equipment r hazardus materials cvered by the 29 CFR , standard. Participate in and understand training in wrk practices necessary t safely perfrm yur assigned wrk including Permit t Wrk prcedures. Participate in and understand hazard instructins related t prcesses, prcess equipment r hazardus materials assciated with yur assigned wrk and wrk lcatins. Knw and understand yur respnsibilities under the Emergency Preparedness and Respnse plans. Knw, understand, and fllw the safety rules and safe wrk practices f the facilities in which yu are assigned t wrk. Infrm yur immediate supervisr f any unique hazards created by Ardent wrk r hazards discvered, nt previusly identified.

3 Page 3 f 7 Sect: 5.0 General Prcedures 5.1 Client Prcedures Whenever Ardent perfrms cntract services fr a client with a similar prcedure r special requirements, the client s prcedure may be applied as a substitute prcedure if it meets r exceeds Ardent s prcedure. An example f this may be Cnfine Space Wrk r Cntrl f Hazardus Energy. Cntractr emplyees shall abide by emplyer s safe wrk practices during peratins such as lckut/tagut, cnfined space entry, pening prcess equipment r piping and cntrls ver entrance t facility. 5.2 Management f Change The prcedures shall assure that the fllwing cnsideratins are addressed prir t any change: (I) the technical basis fr the prpsed change, (ii) impact f the change n safety and health (iii)mdificatins t perating prcedures (iv) necessary time fr the change and (v) authrizatin requirements fr the prpsed change. Emplyees invlved in perating a prcess and maintenance whse jb tasks will be affected by a change in the prcess shall be infrmed f, and trained in, the change prir t start-up f the prcess r affected part f the prcess. 5.3 Client s Technlgy Ardent persnnel will nt divulge any knwledge gained thrugh the PSM prcess pertaining t the client s prprietary prcesses r trade secrets and will sign statements t that effect if required. 5.4 Access Cntrl The Client maintains security arund the facility and prcess area t ensure that n unauthrized subcntractrs have entrance r presence in r t the prcess area, and that a safe exit is prvided and maintained. 5.5 Cntract Services Pre-Wrk Prir t Ardent cmmencing wrk in any client s facility, the fllwing requirements must be met: Prvide infrmatin regarding Ardent s safety perfrmance and prgrams (written dcumentatin required) Ardent will request infrmatin frm the client regarding the knwn ptential fire, explsin, r txic release hazards related t the wrk and the prcess Ardent will review the client s emergency actin plan. Ardent will review cpies f lcal safety prgrams, safety, and emergency prcedures, SDS assciated with the wrk and the clients PSM prgram. Ardent will prvide the client with infrmatin relating t any unique hazards presented by the Ardent s wrk r any hazards fund by Ardent emplyees.

4 Page 4 f 7 Sect: Cntract emplyees shall nt perfrm ht wrk until a ht wrk permit is btained frm emplyer. The permit shall dcument that the fire preventin and prtectin requirements in 29 CFR (a) have been implemented prir t beginning the ht wrk peratins, it shall indicate the date(s) authrized fr ht wrk and identify the bject n which ht wrk is t be perfrmed. The permit shall be kept n file until cmpletin f the ht wrk peratins Prir t the start f any wrk Ardent will prvide the fllwing dcumentatin: All safety prgram infrmatin and ther dcumentatin required by the client. Certificatin that Ardent has infrmed their emplyees f ptential fire, explsin, r txic release hazards may exist at r near their wrk area at this facility and that they have explained Emergency Actin Plan t their emplyees. Training dcumentatin cncerning training prvided t Ardent emplyees t insure they understand the safe wrk necessary t safely perfrm tasks. This dcumentatin will cntain at a minimum the fllwing infrmatin: Emplyees name Training date Means t verify cmprehensin Certificatin that they understand the client s Ht Wrks Permit Prgram and ther permits the client uses that will be needed during their time n the client s prperty. Ht wrk shall nt cmmence until a valid permit issued by the Permitting Authrity is btained. As a minimum Ht wrk permits shall cmply with the minimum requirements established by the latest revisin f Ardent s Ht Wrk Safety Prgram and Prcedure, Sectin B.29, dcument O-SS-SSP Ardent will advise the client f any unique hazards presented by their wrk, if any r any fund during their wrk. Certificatin that materials, parts, and equipment t be installed in the scpe f wrk meet industry and engineering standards fr the applicatin used. 5.6 Ardent Subcntractrs Pre-Wrk Prir t allwing a subcntractr f Ardent t cmmence wrk in any Ardent client s facility, the fllwing requirements must be met: Obtain and evaluate infrmatin regarding the subcntract emplyer's safety perfrmance and prgrams (written dcumentatin required) Infrm subcntract emplyers f the knwn ptential fire, explsin, r txic release hazards related t the subcntractr's wrk and the prcess Explain t subcntract emplyers the applicable prvisins f the emergency actin plan. Prvide subcntractrs with cpies f lcal safety prgrams, safety and emergency prcedures, assciated MSDS and a cpy f this PSM prgram. Cmplete all the requirements f Ardent s Subcntractr Liability Agreement. Infrm the subcntractr that a peridic perfrmance evaluatin will be cnducted t ensure the subcntractr and cntract emplyees are fulfilling their bligatins Infrm the Subcntractr that a subcntract injury and illness lg related t the subcntractr's wrk in prcess areas must be maintained n site fr the duratin f the subcntract wrk. The subcntractr must prvide infrmatin relating t any unique hazards presented by the subcntractr s wrk r any hazards fund by the subcntractr emplyees.

5 Page 5 f 7 Sect: Prir t the start f any wrk the Subcntractr must prvide the fllwing dcumentatin: Their safety prgram infrmatin and ther dcumentatin required by Ardent s Subcntractrs Liability and Safety Agreement. Certificatin that they have infrmed their emplyees f ptential fire, explsin, r txic release hazards may exist at r near their wrk area at this facility and that they have explained the Ardent s Emergency Actin Plan t their emplyees. Training dcumentatin cncerning training prvided t their emplyees t insure they understand the safe wrk necessary t safely perfrm tasks. This dcumentatin will cntain at a minimum the fllwing infrmatin: Emplyees name Training date Means t verify cmprehensin Certificatin that they have explained the Ardent and Client s Ht Wrks Permit Prgram and ther permits Client uses that will be needed during their time n Client s prperty. Ht wrk shall nt cmmence until a valid permit issued by the Permitting Authrity is btained. As a minimum Ht wrk permits shall cmply with the minimum requirements established by the latest revisin f Ardent s Ht Wrk Safety Prgram and Prcedure, Sectin B.29, dcument O-SS-SSP Agreement t advise Client f any unique hazards presented by their wrk, if any, fund during their wrk. Certificatin that materials, parts and equipment t be installed in the scpe f wrk meet industry and engineering standards fr the applicatin used. The Ardent Superintendent is respnsible fr issuing infrmatin and dcuments t the subcntractr and cllectin and review f subcntractr infrmatin and certificatins. 6.0 Incident Investigatin Ardent will immediately reprt t the client all incidents invlving Ardent persnnel r any Ardent subcntract persnnel. The nsite supervisr will either lead r participate in the incident investigatin and will infrm the Ardent business unit if he/she requires any assistance frm the Ardent Safety Manager. The nsite supervisr will be respnsible fr cmpleting and prviding the client with all the required dcumentatin including all reslutins r crrective actins. As a minimum, Ardent s supervisr shall fllw Incident Investigatin and Reprting prcedures established in the latest revisin f Ardent s Incident Investigatin Prgram, Sectin E.2, dcument O-SS-SPP-0038, and the latest revisin f Ardent s Incident Reprting & Recrdkeeping Prgram Sectin E.3, dcument O-SS-SPP The fllwing shall apply: All incidents resulting in r that culd have reasnably resulted in a catastrphic release f highly hazardus materials shall be investigated. An investigatin shall be initiated n later than 48 hurs fllwing the incident.

6 Page 6 f 7 Sect: The investigatin team shall include at least ne persn knwledgeable in the prcess, hazardus materials r equipment invlved. A reprt shall be prepared fllwing the investigatin that includes the fllwing minimum infrmatin: Date f incident Date investigatin began Descriptin f the incident Factrs cntributing t the incident Recmmendatins resulting frm the investigatin Ardent shall maintain an injury and illness lg related t the nsite wrk. 7.0 Training All Ardent emplyees and subcntractrs invlved in prviding services n, r the installatin f, equipment at client s facilities shall be trained in the hazards and safe wrk prcedures necessary t safely perfrm their assigned wrk Training Cntent: Safe wrk practices necessary t safely perfrm assigned wrk including Permit t Wrk prcedures. Hazards related t prcesses, prcess equipment r hazardus materials assciated with their assigned wrk and wrk lcatins. Respnsibilities under the Emergency Preparedness and Respnse plans. Safety rules and safe wrk practices f the facilities in which they are assigned t wrk. Respnsibilities t infrm the client f any unique hazards created by the executin f Ardent wrk r hazards discvered that have nt previusly been identified. 8.0 Reprting & Recrdkeeping 8.1 Training - All training shall be dcumented Dcumentatin shall cntain at a minimum the fllwing infrmatin: Emplyees name Training date Means t verify cmprehensin 8.2 Reprts All expsure incidents shall be reprted Incident Reprt - All expsure events resulting in injury, illness, r lss f cnsciusness f an emplyee shall be recrded as Incidents n an Ardent Incident Reprt Spills - Spills r releases that meet any f the fllwing criteria shall be recrded as Incidents n an Ardent Incident/Accident Reprt OR as per the

7 Page 7 f 7 Sect: latest revisin f Ardent s Envirnmental Plicy and Prgram, Ardent dcument O-EV-EPP Oil based fluids spilled n land r water mre than five (5) galln Chemical based fluids r prducts spilled n land r water mre than (5) gallns r five (50) punds which ever is less. Spills r a release f any prduct within the client s reprting criteria Near Miss Reprts - Failures in cntainment, cntrl methds, islatin, etc., nt resulting in emplyee injury, illness, r expsure, shall be recrded as near miss events n an Ardent Near Miss Reprt. 8.3 Cntrl & Retentin - Recrds assciated with this prgram shall be handled in the fllwing manner: Custdian Ardent s Directr f HS&E shall be the custdian f the all recrds assciated with this prgram Incidents - shall be handled per the Incident Reprting and Recrd Keeping Prgram and shall be maintained fr a minimum f 5 years Availability A cpy f this plan shall be made available, upn request, t all by the emplyee, and the required OSHA fficials.

CONFINED SPACES SAFETY & HEALTH ISSUES AND REGULATORY COMPLIANCE

CONFINED SPACES SAFETY & HEALTH ISSUES AND REGULATORY COMPLIANCE Are the emplyees r cntractrs wh wrk in yur facility expsed t cnfined space hazards? Have yu cnducted a thrugh assessment f yur facility