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Process Safety Information - Resource Drain or Opportunity?
A recent poll by AcuSafe news indicates that many of our readers believe that Process Safety Information (known as PSI) is an area that many believe is need of a lot of improvement.
Yet the cost of this can be high - especially if the information falls into disrepair between PHA Studies. Have you heard the Process Hazard Analysis Team reporting at the end of their study: "The P&ID's need a lot of work"?
Background - The Origin Of The PSI Requirement
A portion of the Clean Air Act Amendment (CAAA) passed in 1990 specified the minimum Process Safety elements which must be covered. It starts off with: "(1) Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes". The next area discussed in the act leads right into Process Hazard Analyses (PHA). The authors knew you couldn't do much to improve process safety unless you had a basis on which to make evaluations and decisions. So PSI was always viewed as an underlying foundation to conduct PHA's
And so it was off to get all the old records we could about our processes. Perhaps one of the biggest tasks before us was to update (or even create) the Process and Instrument Diagrams (P&ID's), the source of so much information needed to conduct a good PHA. A lot of field verification of piping and equipment was done - all at a high cost. And this was just so we could do the required PHA studies.
Now We're at the Second and Even Third Round of PHA Studies
We're hearing reports of some facilities that are still finding lots of problems with the information in the P&ID's and other Process Safety documents like safety valve specification sheets. Project changes are not shown correctly and there are inconsistencies of information about pressure vessels. Piping errors found during the previous study have not yet been resolved.
The PHA Team is Focused
Remember that the PHA team is focused on every minute detail and aspect of the process. Yes, they will find piping that goes off to 'nowhere' and does not connect to another drawing as indicated. And maybe even a flange size or rating will be shown incorrectly. If the operator, who is a part of the team, is qualified to operate the unit, they should know the routing of the piping from memory or can quickly resolve the issue with a quick trip to the field at a convenient break time. The Team should mark the correction on a set of P&ID's and have their suggestions done right after the PHA is complete. The PHA review will probably be the most thorough check of the PSI that you'll get - and it comes along for no extra cost!
Inconsistent Information Can Be Eliminated
Although it may not be efficient for a PHA team, you can meet all of the requirements of the regulations by eliminating duplicate information on P&ID's. Have the set pressures of Safety Valves indicated on the safety valve spec sheets - and have those always up-to-date and under good change control. Let the PHA team go to the safety valve book to review that node. Similarly with ASME Code Pressure Vessels, make the U-1 forms available to the PHA Team rather than depending on transcribing the information onto the P&ID's. The fewer places the same information is stored, the fewer places need updating as changes are made. That in turn will improve the reliability of the information.
Ensure MOC Is Working - 'Red Lines' Are OK.
Most changes to the process are small and represent a minor improvement. But they do add up in number also that it can be overwhelming to the Drawing Department to make updates to the PSI. This is especially true if they get behind in their work because of budget constraints. So make maximum use of red lined updates to reduce the field walk down time. Field verification by the Drawing Department should be limited to that needed only to confirm "fuzzy mark ups".
'Red Lines' Explained
For those of you who are not using this technique - it's simple. Master sets of drawings are marked up using a red pencil. This then notes this is a change that has not yet been incorporated into the electronic or vellum originals. The Drawing Department personnel come by as needed and update the original drawings from these "Master Drawings". It's important to make a mind shift that the control drawings are not the originals - but those with the red line marks ups.
Reduce the number of control drawings available. You can still easily meet the accessibly requirement of the regulations. Remember that OSHA and EPA only say that the information must be accessible. A Control House is an excellent location which allows "red lined" master control documents which are available to everyone who has a need for the information.
If there is a lot of project work anticipated for a unit, having the red line markups incorporated into the master drawings would make their project work easier. And of course, the PHA revalidation is a good time to incorporate changes.
Projects may be the biggest problem
Major project changes may be the root cause of most incorrect Process Safety Information. The project team swoops in with independent drawings and designs, make a bunch of jump-overs and uprates, and then go on to the next project before the updates to the PSI are finalized. One way to limit this problem is to require your project people make their designs on a 'layer' of your original drawings. Once the project is done, the layer can be incorporated into original document. Even if it's not 100% field verified, your next PHA revalidation should be able to make any minor corrections. Walking the new project from scratch and updating drawings just before the next revalidation is a high cost option you should be able to avoid.
Suggestion Summaries:
Ands so in the true sense of working smarter - not harder (and expensively):
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Use your PHA team as an additional verification tool and make their corrections promptly;
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Eliminate inconsistencies by striving to have information in only one place;
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Use red line updates on one set of master drawings and documents;
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Have project teams use "layers" on your existing drawings.
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