Effective PSSR in Management f Change fr Existing Plants 66 th Canadian Chemical Engineering Cnference Octber 18 th, 2016 Presented by Sam Sanati, P.Eng, FS Eng. 30 January 2017 1
Pre Startup Safety Review Last chance t cnfirm the bjectives f change have been met and ptential risks are mitigated befre energize the system. 30 January 2017 2
Case Study: Sweetening Unit Start-up Gasket rupture f an Exchanger during start-up. Causes: Material defect Cnstructin/installatin errr (misaligned flanges) Findings: PHA did nt include this scenari fr start-up Gasket and flanges were nt tested befre installatin 30 January 2017 3
When we need PSSR? CFR 1910.119(i) The emplyer shall perfrm a pre-startup safety review fr new facilities and fr mdified facilities when the mdificatin is significant enugh t require a change in the prcess safety infrmatin. Canadian PSM Guideline : Element 3 (Capital Prject Review and Design Prcedure) Element 6 (Prcess and Equipment Integrity) Pre-startup safety reviews shuld be cnducted befre cmmissining a new r mdified prcess, replacing equipment r recmmissining mthballed equipment. The review shuld cver bth equipment and perating prcedures t ensure that all elements are in place and functinal. 30 January 2017 4
When we need PSSR? CFR 1910.119(i) The emplyer shall perfrm a pre-startup safety review fr new facilities and fr mdified facilities when the mdificatin is significant enugh t require a change in the prcess safety infrmatin. Canadian PSM Guideline : Element 3 (Capital Prject Review and Design Prcedure) Element 6 (Prcess and Equipment Integrity) Pre-startup safety reviews shuld be cnducted befre cmmissining a new r mdified prcess, replacing equipment r recmmissining mthballed equipment. The review shuld cver bth equipment and perating prcedures t ensure that all elements are in place and functinal. 30 January 2017 5
PSSR Requirement Check: PSIs (e.g. P&IDs) are updated Design intent is met Update f Prcedures and instructins Cmpletin f training prgram Review cmpletin f incident investigatin recmmendatins, Review cmpliance audits, Review PHA recmmendatins Further Items: Human Factrs SCE List SCE Perfrmance Standards PHA Recmmendatins are implemented 30 January 2017 6
PSSR Team A multidisciplinary team is selected fr PSSR. PSSR Lead shuld be Cmpetent : Gd understanding f relevant PSIs Gd knwledge abut what regulatin requirement Preferably, gd knwledge n the subject f the change Independent frm the change request r prcess 30 January 2017 7
PSSR: Have We Checked Human Factrs Requirement? Sprinkler: - N mechanical handling is required. - Only access t the valve is needed Gaseus System: - Mechanical handling is required. - Access fr Replacement f cylinders 30 January 2017 9
MC Risk Assessment Currently, What-if is a cmmn used risk assessment methd fr management f change prcess in existing facilities. Cncern: What-if is nt always the prper methd t use Cmpetent facilitatr is nt chairing the meeting Smetimes residual risks are nt estimated 30 January 2017 10
PSSR : Risk Assessment Clse-ut 35 recmmendatins made by the Natinal Transprtatin Safety Bard Only six have been successfully cmpleted Furteen f the recmmendatins issued t the Federal Aviatin Administratin and its Eurpean cunterpart, EASA, are marked by the NTSB as clsed-unacceptable. Recmmendatins that gt an unacceptable respnse deal with: Pilt training, Directins fr pilts facing the lss f pwer in bth engines, Equipping planes with life rafts and vests and making it easier fr passengers t use them US Airways Flight 1549 Incident [Reference: glbalnews.cm] 30 January 2017 11
Risk Assessment Clse-ut PSM Guideline Element 3: Cnfirm that a prcess hazard analysis has been dne and that recmmendatins have been reslved r implemented prir t start up If a recmmendatin is unacceptable then ALARP demnstratin and senir management apprval is needed. 30 January 2017 12
Prcedure Update Bayer Pesticide Explsin 30 January 2017 13
Change in Safety Critical Elements PSM Guideline Element 3: Ensure critical equipment has been identified and incrprated int a preventative maintenance prgram. The big accidents are just waiting fr the little nes t get ut f the way. Carlyn Merritt (Frmer CSB Chair) 30 January 2017 14
Update Prcess Safety Infrmatin Sme f the key dcuments (such as P&IDs) shall be authenticated and stamped by a prfessinal engineer. Ensure the updated PSI have been reviewed by all stakehlders Ensure all PSIs are cmmunicated and apprved by the applicable regulatrs. 30 January 2017 15
PSSR Dcumentatin Prper dcumentatin is needed fr future Investigatin 30 January 2017 16
Summary Review f Human Factrs requirements t ensure the mechanical change des nt create an ergnmic hazard. Ensure a prper risk assessment methd is selected and all the residual risks are reduced t an acceptable level. Clsing ut the recmmendatins f risk assessment study is nt cmpleted until their implementatin is verified. If the recmmendatin is nt feasible then ALARP demnstratin and senir management apprval is needed. Prcedures shuld be updated and apprved. Change in a SCE shuld be highlighted in PSSR t ensure that the relevant dcuments (perfrmance standards, verificatin scheme, etc) have been updated. 30 January 2017 17
Thank yu If yu d like t find ut mre visit: Sam.Sanati@atkinsglbal.cm www.atkinsglbal.cm Atkins Limited except where stated therwise. 30 January 2017 18