Managing Production Changes and Process Safety During COVID-19

Tim Shelton, PE

Companies are looking for ways to re-purpose their operations and need to understand the impact on process safety.

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If your craft distillery is now producing and shipping hand sanitizer or your auto manufacturer is making face masks by the truckload, you’re doing your part to fight the pandemic and keep the economy up and running. As the demand for health and safety products increases to fight COVID-19, more industrial companies are looking for innovative ways to repurpose their operations or increase production to meet the surge. However, it’s important to be aware of two best practices that apply to these new and modified processes — management of change (MOC) and pre-startup safety reviews (PSSR) — and are critical to ensure industrial safety. While we’ll only focus on PSSR, it’s important to have an effective MOC program when managing a change in production (such as from alcohol to hand sanitizer).

Pre-startup safety reviews are part of OSHA’s Process Safety Management (PSM) regulations, and, according to the Center for Chemical Process Safety (CCPS), startup and shutdown present the highest risk for a process safety incident when dealing with highly hazardous chemicals.

For highly hazardous chemicals, a PSSR is required whenever there is a change in the Process Safety Information. If you’ve changed the process chemical, the process equipment or the process technology, a PSSR should be triggered. Such a change should also trigger a Process Hazard Analysis (PHA). This is a structured, team-based activity that identifies hazards and risk scenarios and leads to the development of action items to mitigate and prevent these risks where necessary.

How to Conduct a PSSR

The PSSR may take place during pre-commissioning or cold commissioning phase, but always before any hazardous materials enter the process equipment. It, however, does not replace a well-written and implemented pre-commissioning procedures. The key steps are:

  • Check that Process Hazard Analysis action items have been documented and that MOC procedures have been followed
    This first step is the big one – if you haven’t got this right, it flows down to the other requirements. The PHA does not need to be overly complex but it needs to address at a minimum the hazards of the process. Identify them, understand them and the rest falls into place. For new or modified processes, think about unexpected chemical reactions, potential for runaway reactions and compatibility of materials of construction. Consider hazards your plant is not accustomed to managing. Perhaps your modified process requires a new chemical that is toxic or corrosive. Maybe you need to store and use inert gases which introduce the risk of asphyxiation. Take the PHA and review the action closeout sheets to ensure that review and approval is complete and that approved actions address the identified risk. Trace any actions back to the “approved for construction” drawings.
  • Check that safety systems and emergency procedures are adequate
    Once you have identified the new hazards, your risk analysis and evaluation can inform what safety systems and emergency procedures are needed. Engineering may need to design and verify emergency shutdown systems, pressure relief devices and venting systems, or explosion and fire protection systems. The urgency to modify plants should not undercut the need for competent design and review of these systems.
  • Confirm that the equipment is constructed, installed correctly and meets the design specifications
    This should be an extension of the project inspection and test program. Take your P&IDs and line lists for a walk through of the entire installation. Use a 3-D camera to quickly document separation distances and vessel dimensions. Confirm correct line sizes, set points of relief devices, calibration records of instruments. Look at pump name plates and compare them to the pump curves provided with design specifications. Check vessel name plates for design temperatures and pressures.
  • Ensure that adequate training and hazard communication is provided
    Training should involve everyone who needs to know; all the way from plant manager, operations, maintenance, contractors, suppliers, customers, and should emphasize – you guessed it – the hazards of the new process or product.

Typically, checklists that drill down into each of these elements will be prepared ahead of time. These may also include electrical systems, personnel safety, job hazards analyses, waste streams and environmental impact. The PSSR is not process design and it’s not commissioning, but it should be an independent activity providing a critical link between them. During the current COVID-19 climate, where time is of the essence, it may easily be overlooked or minimized.

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