Preparing For Process Safety Management: What Ag Retailers Need To Do

Michael Hazzan, Technical Manager at AcuTech, PSM Training

To get acquainted with PSM requirements, one of the first things AcuTech’s Michael Hazzan recommends ag retailers do is become comfortable with documenting almost everything they do in writing.

By and large, ag retailers like to use three letter acronyms in their day-to-day operations. Most talk about getting a ROI (return-on-investment) from their equipment. Others mention how much N-P-K (nitrogen-phosphorous-potassium) they have in their warehouses. A few even channel mobile phone “text-speak” when discussing the day’s LOL (laugh out loud) moment.

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But for the past few months, another three letter acronym has begun dominating the daily conversations at most of the nation’s ag retail outlets: PSM. Short for Process Safety Management, PSM requirements are federally-mandated rules many businesses have to follow in order to maintain their operations in the eyes of regulators. Traditionally, PSM standards have applied to such business ventures as oil refineries and food processors. However, broadening definitions and regulations now mean that ag retailers will also fall under these requirements as well.

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Allen Summers Asmark Institute PSM Training

Allen Summers, Director of the Asmark Institute, addresses ag retailers who attended the Process Safety Management course in mid-February at the Ford B. West Center for Responsible Agriculture in Owensboro, KY.

“PSM might very well be one of the biggest things to hit our industry ever,” says Allen Summers, head of The Asmark Institute. “Facilities can’t hire this to be done. It will require the facility personnel to understand the requirements and implement them on a daily basis in order to comply.”

To help prepare ag retailers to be in PSM compliance, Asmark has held a series of training sessions at the Ford B. West Center in Owensboro, KY, over the past six months. These 16-hour, two-day seminars covered virtually every aspect of the coming PSM requirements, with instruction provided by Michael Hazzan, Technical Manager at AcuTech, a process risk management training firm. CropLife® magazine was invited to attend one of these sessions, held in mid-February, to learn firsthand what the new PSM requirements are, how ag retailers will need to prepare for their implementation, and what pitfalls/challenges they might face along the way.

A History Of PSM

According to Hazzan, ag retailers came under scrutiny for PSM on July 22, 2015. That’s when the Occupational Health and Safety Administration (OSHA) announced that retail facilities would no longer be exempt from the PSM Interim Enforcement Policy and would have 12 months to get their operations in compliance. “This was the game-changer for ag retailers,” said Hazzan. “With the stroke of a pen, the PSM community was expanded by 10%, and this included most ag retail locations around the country.”

And in truth, PSM had already been a requirement for many businesses across the country. This came about because of string of process industry accidents that occurred between 1974 and 1989. This included Flixborough, England (a cyclohexane manufacturing plant), Seveso, Italy (a dioxin facility), and the Union Carbide plant in Bhopal, India, where a methyl isocyanate release into the air injured more than 100,000 residents. “OSHA’s PSM standards were adopted shortly after these incidents, in May 1992,” said Hazzan.

As for why ag retailers now find themselves coping with PSM, Hazzan says two more recent incidents are to blame: A March 2005 explosion at a British Petroleum facility in Texas City, TX, which killed 15 people and injured 170 others, and the April 2013 disaster that virtually destroyed the West Fertilizer outlet. “Legislators react to the outrage of the people, especially in the instant video-post age we now live in,” he said. “And while the risk of a serious incident at an ag retail facility is low, the potential is still always there.”

To begin getting acquainted with PSM requirements, one of the first things Hazzan recommends ag retailers do is become comfortable with the idea of documenting almost everything they do in writing. “There’s a popular mantra when it comes to OSHA’s views on PSM standards,” he said. “If it’s not written down, it never happened.”

For example, employers adhering to PSM requirements need to consult with employees (and their representatives when applicable) regarding efforts in developing and implementing PSM elements. “This means you should develop a written plan of action for employee participation, consulting with employees during the PSM program development and making all this information under the PSM standard accessible to employees,” said Hazzan.

Then there’s the Management of Change requirement, which Hazzan said both OSHA and industry view as “one of the most important and necessary aspects of PSM.” This requires operators to establish and implement written procedures to manage changes to process chemicals, technology, equipment, and procedures; and to facilities that affect a covered process. Examples of these would include new equipment, computer program revisions, and the routine replacement of pumps, valves, and other equipment that may be different from what is already in place.

“This element is intended to be a ‘speed bump,’ but not a road block to change,” said Hazzan. “Challenges to meeting this requirement include ensuring that all covered changes are identified and changing the previously ingrained practices and company culture on making changes.”

Written documentation also applies in the areas of Process Safety Information (PSI) and Process Hazard Analysis (PHA), he said. “PSI enables those involved in the process to identify and understand hazards associated with it,” said Hazzan. “This includes information on any materials hazards present, the technology of the systems being used, and other equipment that might be involved. And this needs to be in a written form that is accessible to all employees. You can’t rely on someone’s memory to accomplish this.”

As for PHA, this should be a written analysis addressing such topics as process hazards at the facility, outlining the engineering and administrative controls used to address them, and the likely consequences of failing to adhere to these controls. “This analysis should be updated and revalidated at least every five years using a team approach to assure that the PHA is consistent with the current process,” said Hazzan.

The Importance Of MI

Of all the many moving parts that will make up an ag retailer’s functioning PSM plan, said Hazzan, Mechanical Integrity (MI) is probably the most important. “The first line of defense in process safety is to keep hazardous materials contained through well designed, operated, and maintained equipment,” he said. As such, fully one-fourth of the 16-hour PSM training session was devoted to looking at the MI requirements in-depth.

For starters, MI covers virtually all the equipment at a facility involved in any type of process operations. This includes pressure vessels and storage tanks, piping systems (including their various components), relief and vent devices, emergency shutdown systems, pumps, and other controls such as monitoring devices, sensors, alarms, and interlocks. Written procedures covering all these items need to be established and employees need to be trained in maintaining equipment integrity.

“In addition, inspection, testing, and preventive maintenance should be performed on all process equipment, which is the heart and soul of the MI requirement,” said Hazzan. “The frequency of this should be consistent with manufacturer’s recommendations or more frequent if so determined through prior operating experience.” He recommended adhering to Recognized And Generally Accepted Good Engineering Practices (RAGAGEPs) established by such organizations as the Compressed Gas Association, the American Society of Mechanical Engineers, and the American Petroleum Institute for guidance in this area.

For many in the processing sector, performing these kinds of proactive methods in their operations was usually not the norm, said Hazzan. “Until PSM was implemented, most processing companies did not do preventive maintenance on their equipment,” he said. “Most had the philosophy of ‘we don’t fix anything until after it breaks.’”

According to Hazzan, common MI deficiencies include overdue inspections/testing, safety features that are bypassed (such as blocked in-relief valves), the use of pipe clamps to temporarily stop leaks, and pressure relief valves and other components that may have expired. “MI is the most complicated PSM element in part because it involves many activities and groups/departments at the site,” he said. “Most companies are still working to comply with this element.”

Other Considerations

Beyond these components of PSM, Hazzan advised ag retailers attending the training session to look at such areas as Standard Operating Procedures (SOPs).

Process Safety Management (PSM) Training Course

Ag retailers attend the Process Safety Management (PSM) Training Course in February 2016 at the Ford B. West Center for Responsible Agriculture in Owensboro, KY.

“SOPs should be written in a style and level of detail that supports their use as training documents and should include storage and transfer operations not covered by the Department of Transportation,” he said. “Electronically available SOPs are okay, as long as there is at least one hardcopy available in the event of a power outage.”

Then, there’s auditing all PSM elements periodically. “These should be conducted every three years, be done by at least one person that is knowledgeable in the processes of the facility, be certified, and filed with a written report,” said Hazzan. “And any corrective actions should be taken immediately once the audit is complete. Facilities cannot take the three years until the next audit to do this.”

Some ag retailers in attendance mentioned their hope that a lawsuit filed by the Agricultural Retailers Association might buy them some more time to get their PSM elements in order. Asmark’s Summers offered this advice: “Use this extra time wisely to learn more about PSM, upgrade your installations, line up contractors, and move forward in developing these programs before the end of September. Waiting around to get started on this subject would be a bad idea, given the complexity of the rules and the learning curve involved.”

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