TITLE: PROCEDURE FOR PROCESS SAFETY MANAGEMENT SYSTEM

INTRODUCTION
In the implementation of Process Safety Management (PSM), management needs good
feedback to ensure that development and continuous improvement of the managing
systems do occur and that the desired results are achieved.

Auditing is a robust detailed feedback system, auditing of company’s process safety process
management systems followed by implementation will provide management with invaluable
feedback in its pursuit to safeguard the environment, employees, physical assets, business,
communities and all of its stakeholders.
Considering the above fact this formalised process safety management audit procedure is
made and will be implementing in full.

SCOPE

This procedure will be applicable to all process plant in IEPL site.

RESPONSIBILITY

Safety Manager

 Training process safety audit team in process safety management auditing

methodology.
 Co-ordinating the audit process every year, Giving feed back to Technical Director ,
making audit finding presentation to all HODs and HOFs, and insuring compliance of
audit findings.

Audit team

To conduct the audit as per schedule and to submit report to plant HOFs and to Safety
Manager.

Plant HOFs

Ensuring implementation and compliance of the team audit findings

PROCEDURE

Process safety audit team shall be constituted consisting of

1. Process engineer from Technical services

2. Safety Engineer/ safety Manager.

The Team shall be trained by Safety Manager on Process safety management auditing
process.
 Every year team shall conduct a detailed audit of all the plants. The Safety Manager shall co-
ordinate the audit the process.

The Team shall use the PSM audit checklist given in Annexure I

The audit team shall give the report to Plant HOF within a week with a copy to Safety Manager.

The Safety Manager shall make a consolidated report from all reports and submit it to Technical
Director within a week after receiving the reports from the team.

The finding of the team and action plan shall be presented by the safety manager in the Central
HSE&F committee meeting. Safety Manager shall also do the follow up for the compliance

REFERENCE

1. Code of Federal regulation- CFR 1910.119

2. CCPS guidelines on auditing process Safety Management systems
3. DOE hand book of Safety Management of Hazardous chemicals.

RECORDS

The Audit report shall be kept by Respective HOD & Safety Manager for Five Years.
 Annexure 1

Indorama Eleme Petrochemical Company Limited

Process Safety Audit Checklist

1-PSM Element: Accountability and Responsibility

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

Policies, Programs and Procedures None Partial Complete

 Does site have their safety policy and
guidelines?
 Does site have its own standards?
 Does site have its own PSM program?

Definition of Responsibilities
 Are responsibilities and accountabilities
defined, established, and communicated?
 Are personnel who need to know or
understand responsibility assignments
made aware of them?
 Are assignments of responsibilities
reinforced?
 Are any key responsibilities overlapping,
shared, or conflicting?
 Is there potential for conflict of interest in
accomplishing key process safety
management tasks and functions?

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

Approvals and Authorization None Partial Complete
 Does someone have the authority to waive
adherence to, or conformance with, an
established standard or requirement?
 Are authorizations to depart from internal
procedures made and recorded?

Personnel Training and Experience

 Have key personnel had formal training to
assist them in performing key process
safety management functions?
 Are there training and awareness activities
to provide an understanding of process
safety management obligations and
responsibilities?
Protective Measures
 Are administrative controls in place to help
achieve desired results?
 Have measures been taken to reduce the
likelihood of non-conformance with
established criteria?
Documentation
 Are records routinely developed and
retained in carrying out various tasks and
functions?
 Are exception reports developed?
 Does the relative importance of a task
correspond with the type and amount of
documentation that is developed? Are
records kept centrally? For at least 5 years?
Internal Verification
 Does facility management or supervision
review, measure, and evaluate results
achieved against established criteria?
2-PSM Element: PROCESS SAFETY INFORMATION

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete

CHEMICAL INFORMATION
Documentation
The following chemical information is available.
 Toxicity Data
 Permissible exposure
 Physical Data
 Reactivity Data
 Corrosive Data
 Thermal and Chemical stability Data
 Chemical Incompatibility

CHEMICAL INFORMATION
Communication
Employees are aware of where chemical information
is located

Employees are informed when changes are made to

the chemical information

CHEMICAL INFORMATION
Implementation
Written program exists for maintaining, revising and
updating chemical information.

Responsibility for maintaining, revising and updating

chemical information is clearly established.
 Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete

TECHNOLOGY
Documentation
Written up-to-date process descriptions exist

Block flow diagrams or simplified process flow

diagrams exist

Maximum intended inventories of chemicals are

documented

Information concerning the process chemistry is

documented

Safe operating ranges (upper and lower limits) are

provided for such process parameters as
temperature, pressure, flow rate and composition

Consequences associated with process parameter

deviations are provided including those that would
affect the safety and health of employees

TECHNOLOGY
Communication
Employees are aware of where information is located

Employees are informed when changes are made to

the process technology information

TECHNOLOGY
Implementation
Written program exists for maintaining, revising and
updating process technology information.

Responsibility for maintaining, revising and updating

technology information is clearly established.
 Major Issues /Questions PSM Compliance status Information Source Notes/Comments
None Partial Complete
PROCESS EQUIPMENT
Documentation
Documentation is provided for materials of
construction (including protective coatings) and their
selection bases

Up to date piping and instrumentation diagrams

(P&IDs) are available

Documentation is provided for the design basis of

relief systems

Documentation is provided for the design of

ventilation systems

Documentation is provided that indicates equipment

complies with the design codes, standards or
recognized and generally accepted engineering
practices used in the designing process

Documentation is provided for the design of safety

systems equipment such as interlocks, detection and
suppression systems, etc.
PROCESS EQUIPMENT
Communication
Employees are aware of where process equipment
information is located

Employees are informed when changes are made to

the process equipment information
PROCESS EQUIPMENT
Implementation
Written program exists for maintaining, revising and
updating process equipment information.

Responsibility for maintaining, revising and updating

process equipment information is clearly established.
3-PSM Element:Process Hazard Analysis

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
The PrHA documentation includes the following:

 System analyzed (i.e. a list of P&IDs with

revision numbers and dates)
 Personnel involved in the PrHA
 PrHA method used
 Recommended actions
 Management response to the
recommended actions
The documentation associated with the two most
recent process hazard analyses (PrHAs) is on file
Communication
The findings of the PrHA and actions taken in
response to the findings are communicated to all
affected personnel (i.e. operations, maintenance)
Implementation
Written protocol exist for performing PrHA and
established responsibilities

Written program exists describing: (1) the PrHA

techniques that may be used. (2) When to use them
and (3) how to use them.

The PrHA method selected addresses the followings

 Hazards of the process
 Engineering and administrative controls
applicable to the hazards
 Consequences of failure of these controls
 Consequences to workplace employees of
the engineering administrative control
failures
The PrHA is performed by a team with expertise in
engineering and process operations, with at least one
individual who has experience and knowledge
specific to the process being evaluated
PSM Elements: Process Hazards Analysis, continued

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Implementation (continued)

Written program exist for: (1) documenting the

recommendations and management response to the
recommendations (2) communicating the results to
the affected individuals; and (3) implementing the
recommendations in a timely manner

Written program exist for updating and revalidating

the PrHAs every 5 years.
4-PSM Elements: Operating Procedures

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Written up to date operating procedures address at
least the following operation modes.
 Initial startup
 Normal operation
 Temporary operation (as the need arises)
 Emergency operations (including
emergency shutdowns, conditions under
which to declare a shutdown and
assignment of shutdown responsibility)
 Startup following a turnaround or after and
emergency

Written up to date operating procedures address

operating limits by considering the following:

 Consequences of deviations from operating

limits
 Steps necessary to correct and/or avoid
deviation from operating limits
 Safety systems and their functions

Written up to date operating procedures address the

following safety and health considerations
Procedures and hazards of chemicals used in the
process
Precautions necessary to prevent exposure (i.e.
administrative and engineering controls and
protective equipment)
Measures to take if contact or exposure occurs
Safety procedures for opening process equipment
(e.g. line breaks)
Quality control for raw materials and chemical
inventory levels
Any special or unique hazards
PSM Elements: Operating Procedures, continued

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Communication
Operating procedures are readily accessible to
employees who work in or maintain a process

Employees are informed when changes are made to

the operating procedures

Implementation
Written program exists for updating operating
procedures to include changes in process chemicals,
technology, equipment and facilities.

Responsibility for maintaining, revising and updating

operating procedures is clearly established

Written program exist for annually certifying that

operating procedures are current and accurate.
5-PSM Elements: TRAINING

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
For initial and refresher training, an employee record
exists that contains the name of the employee, the
date of training, and the signature of the person
doing the training

Communication
Employees are made aware of initial and refresher
training that is required.

Training program ensures that employees understand

and adhere to the operating procedures

Implementation

Written program exists for providing refresher and

supplemental training and for establishing acceptable
training methods, responsibilities for training
instructors, and methods for maintaining, revising
and updating certification records.

Written training program ensures that employees are

trained in the following areas
An overview of the process
Operating Procedures
Safety and health hazards and procedures
Safe work procedures applicable to the employee’s
job tasks
6-PSM Elements: CONTRACTORS

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Documentation exists for contractor orientation to
known potential hazards and the applicable
provisions of the emergency action plan.

Communication
Employer assumes the following responsibilities:
 Inform contractors of known potential
hazards related to the contractor’s work
and the process
 Explain to contractor the applicable
provisions of the emergency action plan
Implementation
Written program establishes responsibilities for
orientating contractors to potential hazards and the
applicable provisions of the emergency action plan
and for documenting the orientation.

Written program exists for developing and

implementing safe work practice to control the
entrance, exit and the movement of contractor
personnel at the affected processes.

Written program exist for ensuring that the

contractor assumes the following responsibilities:
Ensuring their workers are trained in safe work
practices
Ensuring their workers follow all applicable safety
rules and work practices.
7-PSM Elements: PRE-STARTUP SAFETY REVIEW

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Prior to introduction of hazardous materials into the
affected process, documentation exists indicating
that a Pre-Startup Safety Review was conducted and
confirming the following:
 Construction is in accordance with design
specifications
 Safety, operating, maintenance and
emergency procedures are in place and are
adequate
 PrHA recommendations have been
addressed and actions necessary for startup
have been completed
 Operating procedures are in place and each
operating employee has been trained

Communication
Operating employees are properly trained in the
hazards and safe operating practices of the new or
modified facility
Implementation
Written program exists for determining when pre-
startup safety review is necessary and establishing
responsibilities for conducting such review.

Written procedure exists for conducting and

documenting pre-startup reviews.
8-PSM Element: MECHANICAL INTEGRITY

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Written procedures exist for maintaining the on-
going integrity of process equipment. Procedures
include maintenance and inspection/testing
frequency for process equipment. The frequency of
inspections/tests shall be consistent with applicable
codes and standards, or more frequently if operating
experience so dictates.

Certification records exist documenting inspections

and tests of equipment. The records contain as a
minimum, the following information:
 Date of inspection
 Name of the individual who performed the
inspection and/or test
 Serial number, or other identifier, of the
equipment tested

Written quality assurance program exists for ensuring

the following:
 Equipment as fabricated meets design
specification
 Appropriate checks and inspections are
performed, as necessary, to ensure that
equipment is installed properly, consistent
with design specifications and
manufacturer’s instruction
 Maintenance materials and spare parts and
equipment meet design specification
PSM Element: MECHANICAL INTEGRITY, continued

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Communication (continued)
Employees involved in maintaining the on-going
integrity of process equipment are trained in the
procedures applicable to the job tasks.

Implementation
A record keeping system exists for documenting the
mechanical integrity of all affected equipment.

A quality assurance program exists for ensuring that

all affected equipment is properly designed, installed,
and maintained

Written program requires that equipment

deficiencies outside acceptable limits be corrected to
meet acceptable limits as specified in the process
safety information package before further use

Inspection and testing procedures follow generally

accepted good engineering practices that are
consistent with manufacturer’s recommendations
PSM Element: Hot Work Permit

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
A permit exists on file (until completion of the hot
work operations) containing the following
information:
 Certification that the fire prevention and
protection requirements contained in
29CFR 1910.252(a) have been implemented
prior to beginning the hot work operations
 Date(s) authorized for the hot work
 Equipment or facility on which the hot work
is to be done

Communication
Completion of hot work operations is properly
communicated to the individuals responsible for
maintaining hot work permits on file
Implementation
A system exists for issuing permits and responsibility
for issuing permits is clearly established
PSM Elements: MANAGEMENT OF CHANGE

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Written procedures exist to manage changes (except
for “replacements in kind” to process chemical
technology, equipment, and changes to facilities.
Procedures ensure that the following are addressed
prior to any change:
 Technical basis for the change
 Impact of the change on safety and health
 Modifications to operating procedure
 Necessary time period for the change
 Authorization requirements for the change

Communication
Employees involved in the process are informed of
and trained in the change in process as early as
practicable prior to its implementation
Implementation
Written protocol exists for determining what changes
in the process (equipment, operating limits, etc.)
requires implementation of management of change
requirements.

Written protocol exists for implementing

management of change in training employees,
revising operating procedures, and process safety
information.
PSM Element: INCIDENT INVESTIGATION

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Incident investigation reports shall be retained for 5
years and shall contained, as a minimum the
following information:
 Date of the incident
 Date the investigation began
 Description of the incident
 Factors that contributed to the incident
 Any recommendations resulting from the
investigation

Communication
The report has been reviewed with all operating,
maintenance, and other personnel whose work
assignments are within the facility where the incident
took place
Implementation
Written program exists for reporting and
investigating (within 48hours) any incident that
results in, or could reasonably resulted in a major
accident

Written program includes establishment of an

incident investigation team consisting of persons
knowledgeable in the process and other appropriate
specialties, as necessary.

Written program includes system for promptly

addressing the incident investigation report findings
and recommendations and for implementing report
recommendations in a timely manner
PSM Element: EMERGENCY PLANNING AND RESPONSE

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Written up-to-date emergency response plan exists
containing the following elements:
 Emergency escape procedures and escape
route assignments
 Procedure to be followed by employees
who remain to operate critical plant
operations before they evacuate
 Procedure to account for all employees
after emergency evacuation have been
completed
 Rescue and medical duties for those
employees who are to perform them
 The preferred means for reporting fires and
emergencies
 Names or regular job titles or persons or
departments who can be contracted for
further information or explanation of duties
under the plan

Documentation exists of employee training with

respect to the emergency response plan including
refresher training

Communication
An alarm system with distinctive signals for each
purpose

Employees are aware of the location of emergency

response plan documentation, have access to it, and
are notified when changes are made to the plan
PSM Element: COMPLIANCE SAFETY AUDITS

Major Issues /Questions PSM Compliance status Information Source Notes/Comments

None Partial Complete
Documentation
Employers documents compliance at least every 3
years

The employer documents the findings of the audit,

the management response to the findings of the
audit, and certifies that deficiencies have been
corrected. The two most recent reports are retained

Communication
Deficiencies found during the compliance safety audit
are communicated to responsible individuals for
subsequent improvement of the PSM program

Implementation
Written procedure exists for performing and
documenting compliance safety audits and for
establishing a team of individuals ( at least one of
which is knowledgeable in the process).