Standard
			must provide responses to each question that is applicable to
			their operations. Responses must cover all PSM-related operations.
			Please indicate that a question is "Not Applicable" if
			it addresses functionality outside the scope of the operations,
			and briefly explain why. 
			 
			 
			OMB#
			1218 – 0239                                                 
			                                                                
					   Expires xx-xx-xxxx 
			 
			Public
			reporting burden for this collection of information is voluntary
			and is estimated to average 40 hours per response, including time
			for reviewing instructions, searching existing data sources,
			gathering and maintaining the data needed, and completing and
			reviewing the collection of information. Send comments regarding
			this burden estimate, or any other aspect of this collection of
			information, including suggestions for reducing this burden to the
			Office of Partnerships and Recognition, Department of Labor, Room
			N-3700, 200 Constitution Avenue, N.W., Washington, DC 20210 
			 
I.
			Management of Change.
			
			 
			
				
				Has
				the throughput changed from its original design rate? Has the
				site conducted a management of change (MOC) procedure for each
				throughput change since May 26, 1992? 
				For
				the MOC procedures conducted for the unit(s), has the procedure
				listed the technical basis for the change and ALL potential
				safety and health impacts of the change prior to its
				implementation? 
				From
				the site's list of MOCs, identify the oldest MOC procedure which
				might affect the integrity of one or more pressure vessels in the
				unit(s). Do these MOC procedures meet all 1910.119(l)
				requirements? 
				Does
				the MOC process address temporary changes as well as permanent
				changes? 
				Have
				MOCs been conducted on all changes to process chemicals,
				technology, equipment and procedures, and changes to facilities
				that affect a covered process? 
				 
			 
			II.
			Relief Design.
			
			 
			
				
				For
				each throughput MOC procedure conducted, has the procedure
				addressed a review/analysis of the relief system (includes relief
				devices, relief discharge lines, relief disposal equipment and
				flare system) to determine if there may be any safety and health
				impacts due to increased flow as a result of throughput changes
				which might impact the existing relief system? 
 
Guidance:
				An MOC procedure is required anytime a change per the
				requirements of 1910.119(l) is considered. An MOC procedure is a
				proactive management system tool used in part to determine if a
				change might result in safety and health impacts. OSHA's MOC
				requirement is prospective. The standard requires that an MOC
				procedure be completed, regardless of whether any safety and
				health impacts will actually be realized by the change. 
				After
				a change in the throughput in the unit(s), did the process hazard
				analysis (PHA) team consider the adequacy of the existing relief
				system design with respect to the increased throughput during the
				next PHA? 
 
Guidance:
				Typically, the PHA team does not do a relief system engineering
				analysis. However, the PHA team should determine, through proper
				evaluation and consultation with the engineering/technical staff,
				if the existing/current engineering analysis of the relief system
				is adequate for the current/actual unit throughput. 
 
If
				the throughput change was implemented between the time the PSM
				standard became effective (May 26, 1992) and the time the
				original PHA was required based on the PHA phase-in schedule, the
				original PHA would need to address the throughput change.
				However, if there was a throughput change after the original PHA,
				the next PHA update/"redo" or PHA revalidation would
				need to address the throughput change. In either event, an MOC
				procedure on the throughput change would need to have been
				conducted and incorporated into the next scheduled PHA. 
				Does
				the site's process safety information (PSI) include the codes and
				standards used in the design of relief systems? 
				 
				Does the site's PSI
				include the relief system design and design basis?  
 
Guidance:
				This includes the original design and design changes. Examples of
				PSI related to relief devices, their design and design basis
				include, but are not limited to such items as: 
				
					Identification/descriptor
					of each relief device; 
					 
					A
					listing of all equipment which will be relieved through the
					device; 
					 
					Design
					pressure; 
					 
					Set
					pressure; 
					 
					Listing
					of all sources of overpressure considered; 
					 
					Identification
					of the worst case overpressure scenario or relief design; 
					 
					State
					of material being relieved (i.e.,, liquid, vapor, liquid-vapor,
					liquid-vapor-solid, along with an identification of the material
					which was the basis for the relief device selection); 
					 
					Physical
					properties of the relieved materials, vapor rate, molecular
					weight, maximum relieving pressure, heat of vaporization,
					specific gravity and viscosity; and 
					 
					Design
					calculations. 
					 
				 
			 
			
			Similar design and design bases PSI are required for the rest of
			the relief system equipment downstream from the relief devices,
			i.e., relief vent lines, manifolds, headers, other relief disposal
			equipment, and flare stack. 
			
				
				Are
				there intervening valves on the upstream or downstream lines
				to/from relief devices? If so, does the PHA consider the
				possibility that these valves could be closed during operation,
				rendering the relief devices non-functional? 
				If
				there are intervening valves on the upstream or downstream lines
				to/from relief devices, does the site have effective controls in
				place to ensure these intervening valves remain open during
				operations? 
				If
				there are intervening valves on the upstream or downstream lines
				to/from relief devices, is there an administrative procedure
				(e.g., car-seal procedure) to assure these valves are in the open
				position during operations? If so, has this procedure been
				subsequently audited? 
				Are there open vents
				which discharge to atmosphere from relief devices? If so, has the
				PHA considered whether these relief devices discharge to a safe
				location? 
 
Guidance: PHA teams must address basic
				questions regarding what happens to the hazardous materials after
				they are relieved to atmosphere, including: 
				
					Are
					there negative effects on employees or other equipment that
					could cause another release ("domino effects") of
					hazardous materials/HHC? 
					What
					presumptions or assessments exist to support that there will be
					no negative effects of an atmospheric release of hazardous
					materials/HHC? 
					Are
					employees near where relief devices discharge, including
					downwind locations (e.g., on the ground, on platforms on
					pressure vessels in the vicinity of elevated relief devices,
					etc.)? 
					 
					Could
					a release from a relief device cause a release from other
					equipment, or could other nearby equipment affect the released
					material (e.g., a furnace stack could be an ignition source if
					it is located proximate to an elevated relief device that is
					designed to relieve flammable materials)? 
					 
				 
			 
			
			Part of the site's PHA team's evaluation, after it identifies the
			locations of open vents, is to determine if employees might be
			exposed when hazardous materials are relieved. If the PHA team
			concludes that a current and appropriate evaluation (such as the
			use of dispersion modeling) has been conducted, the evaluation
			could find that the vessels/vents relieve to a safe location. If
			the PHA team determines that this hazard has not been
			appropriately evaluated, the PHA team must request that such an
			evaluation be conducted, or make some other appropriate
			recommendation to ensure that the identified hazard/deviation is
			adequately addressed. 
			
				
				Does
				the site have a mechanical integrity (MI) procedure for
				inspecting, testing, maintaining, and repairing relief devices
				which maintains the ongoing integrity of process equipment? 
				Does
				the process use flares? If so, verify that the flares have been
				in-service/operational when the process has been running. If the
				flares have not been in-service, has the site used other
				effective measures to relieve equipment in the event of an upset?
				Has an MOC procedure been used to evaluate these changes? 
				 
			 
			III.
			Vessels. 
			 
			
				
				Do
				pressure vessels which have integrally bonded liners, such as
				strip lining or plate lining, have an MI procedure which requires
				that the next scheduled inspection after an on-stream inspection
				be an internal inspection? 
				 
				Does
				the site have an MI procedure for establishing thickness
				measurement locations (TML) in pressure vessels, and does the
				site implement that procedure when establishing the TML? 
				Does
				the site have an MI procedure for inspecting pressure vessels for
				corrosion-under-insulation (CUI), and does the site inspect
				pressure vessels for CUI? 
				Does
				the site's MI procedure address testing (e.g. leak testing) and
				repair of pressure vessels? For example, does the MI procedure
				indicate how the testing and repair will be conducted and which
				personnel are authorized to do the testing and repair, including
				what credentials those conducting the testing and repair must
				have? 
 
Guidance:
				API 510 requires in-service pressure vessel tests when the API
				authorized pressure vessel inspector believes they are
				necessary. 
 
Guidance: Recognized and Generally Accepted
				Good Engineering Practices (RAGAGEP) that require credentials
				include, but are not limited to: 
				
					Credentials
					for pressure vessel inspectors, see API 510, Section 4.2. 
					RAGAGEP
					for pressure vessel examiners credentials/experience and
					training requirements, see API 510, Section 3.18. 
					 
					RAGAGEP
					for contractors performing NDE are the training and
					certification requirements ASNT-TC-1A, see CCPS, Section
					10.3.2.1, (In-service Inspection and Testing) Nondestructive
					Examination. 
					 
					RAGAGEP
					for qualifications for personnel who conduct pressure vessel
					repairs, alteration and rerating including qualifications for
					welders, see API 510, Section 7.2.1 and the BPVC, Section IX. 
					RAGAGEP
					for certifications at CCPS, Section 5.4 Certifications, Table
					5-3, Widely Accepted MI Certifications, and Table 9-13,
					Mechanical Integrity Activities for Pressure Vessels. 
					 
				 
				Were
				any deficiencies found during pressure vessel inspections? If so,
				how were they resolved? 
 
Guidance:
				A deficiency (as per 1910.119 (j)(5)) means a condition in
				equipment or systems that is outside of acceptable PSI limits. In
				the case of a pressure vessel, this could mean degradation in the
				equipment/system exceeding the equipment's acceptable limits
				(e.g., operating a vessel, tank or piping with a wall thickness
				less than its retirement thickness). 
				Do
				the operating procedures for pressure vessels list the safety
				systems that are applicable to the vessels? 
 
Guidance:
				Examples of safety systems include but are not limited to:
				emergency relief systems including relief devices, disposal
				systems and flares; automatic depressurization valves; remote
				isolation capabilities, aka emergency isolation valves;
				safety-instrumented-systems (SIS) including emergency shutdown
				systems and safety interlock systems; fire detection and
				protection systems; deluge systems; fixed combustible gas and
				fire detection system; safety critical alarms and
				instrumentation; uninterruptible power supply; dikes; etc. 
				Have
				there been any changes to pressure vessels or other equipment
				changes that could affect pressure vessel integrity, such as a
				change to more corrosive feed, a change in the type of flange
				seal material used for the vessel heads or nozzles, etc.,? If so,
				was an MOC procedure completed prior to implementing the change? 
				 
			 
			IV.
			Piping. 
			 
			
				
				Is
				there information in the MI piping inspection procedures or other
				PSI that indicates the original thickness measurements for all
				piping sections? 
				Is
				there information in the MI piping inspection procedures or other
				PSI that indicates the locations, dates and results of all
				subsequent thickness measurements? 
				Is
				there anomalous data that has not been resolved for any piping?
				(For example, the current thickness reading for a TML indicates
				the pipe wall thickness is greater/thicker than the previous
				reading(s) with no other explanation as to how this might occur.) 
				Has
				each product piping been classified according to the consequences
				of its failure? 
 
Guidance:
				If the site inspects and tests all piping the same, regardless of
				the consequence of failure of the piping (i.e., piping
				inspections are implemented using the same MI program
				(1910.119(j)(2) and action/task (1910.119(j)(4) procedure for all
				piping without consideration of their consequence of failure or
				other operational criteria), then this question is not
				applicable. 
				Based
				on a review of piping inspection records, have all identified
				piping deficiencies been addressed?  
 
Guidance:
				An example of a piping deficiency would be a situation where
				piping inspection data indicates that its actual wall thickness
				is less than its retirement thickness, and the site has conducted
				no other evaluation to determine if the piping is safe for
				continued operation. For a discussion on equipment deficiencies
				the definition of deficient/deficiency. 
				How
				does the site ensure that replacement piping is suitable for its
				process application? 
 
Guidance:
				Typically, piping replacements are replacements-in-kind (RIK)
				when the process service does not change. However, if the piping
				replacement is not an RIK, then an MOC procedure is required. 
				Does
				the site's MI procedure list required piping inspectors'
				qualifications, welders' qualifications for welding on process
				piping, and when qualified welding procedures are required? 
				Is
				there information in the MI piping inspection procedures or other
				PSI that indicates the original installation date for each
				section of piping? 
				Is
				there information in the MI piping inspection procedures or other
				PSI that indicates the specifications, including the materials of
				construction and strength levels for each section of piping? 
				Does
				the site's MI procedure for piping inspections list
				criteria/steps to be followed when establishing TML for injection
				points in piping circuits? 
				 
			 
			V.
			Operating Procedures – Normal Operating Procedures (NOP),
			Emergency Shutdown Procedures (ESP) and Emergency Operations
			(EOP). 
			 
			
				
				Are
				there established operating procedures, including: normal
				operating procedures (NOP), emergency operating procedures (EOP),
				and emergency shutdown procedures (ESP)? 
				Are
				operating procedures implemented as written? 
				Are
				there ESP for the all Unit(s), and if so, do these ESP specify
				the conditions that require an emergency shutdown? 
 
Guidance:
				ESP are usually warranted during events that may include the
				failure of process equipment (e.g., vessels, piping, pumps, etc.)
				to contain or control HHC releases, loss of electrical power,
				loss of instrumentation or cooling, fire, explosion, etc. When
				EOP do not succeed during upset or emergency conditions in
				returning the process to a safe state, implementation of an ESP
				may be necessary. 
 
When normal operating limits for
				parameters such as pressure, temperature, level, etc., are
				exceeded during an excursion, system upset, abnormal operation,
				etc., a catastrophic release can occur if appropriate actions are
				not taken. These actions must be listed in the EOP and must
				specify the initiating conditions or the operating limits for the
				EOP (e.g., temperature exceeds 225oF or pressure drops below 15
				psig).  
 
Information typically listed in EOP and/or ESP
				includes, but is not limited to the responsibilities for
				performing actions during an emergency, required PPE, additional
				hazards not present during normal operations, consequences of
				operating outside operating limits, steps to shutdown the
				involved process in the safest, most direct manner, conditions
				when operators must invoke the emergency response plan, or
				scenarios when they themselves must stop and evacuate. 
				Have
				control board operators received sufficient training, initial and
				refresher, to be qualified to shutdown the units? 
				 
				Does
				the ESP specify that qualified operators are assigned authority
				to shutdown the unit(s)? 
				Are
				qualified control board operators authorized or permitted to
				initiate an emergency shutdown of the unit without prior
				approval? 
				Do
				EOP procedures identify the "entry point," i.e., the
				initiating/triggering conditions or operating limits when the EOP
				is required, the consequences of a deviation from the EOP, and
				the steps required to correct a deviation/upset once the
				operating limits of the EOP have been exceeded? 
				Do
				NOP list the normal operating limits or "exit points"
				from NOP to EOP; the steps operators should take to avoid
				deviations/upsets; and the precautions necessary to prevent
				exposures, including engineering and administrative controls and
				PPE? 
 
Guidance:
				For NOP, the "operating limits" required are those
				operating parameters that if they exceed the normal range or
				operating limits, a system upset or abnormal operating condition
				would occur which could lead to operation outside the design
				limits of the equipment/process and subsequent potential release.
				These operating parameters must be determined by the site and can
				include, but are not limited to, pressure, temperature, flow,
				level, composition, pH, vibration, rate of reaction,
				contaminants, utility failure, etc.  
 
It is at the
				point of operation outside these NOP "operating limits"
				that EOP procedures must be initiated. There may be a
				troubleshooting area defined by the site's EOP where operator
				action can be used to bring the system upset back into normal
				operating limits. During this troubleshooting phase, if an
				operating parameter reaches a specified level and the process
				control strategy includes automatic controls, other safety
				devices (e.g., safety valves or rupture disks) or automatic
				protection systems (e.g., safety instrumented systems/emergency
				shutdown systems), would activate per the process design to bring
				the process back to a safe state. Typically, once the predefined
				limits for troubleshooting have been reached for a particular
				operating parameter, the process has reached a "never exceed
				limit". A buffer zone is typically provided above( and below
				if applicable) the trouble shooting zone ("never exceed
				limit") to ensure the operating parameters do not reach the
				design safe upper or lower limit of the equipment/process. This
				design safe upper and lower limits of the equipment or process
				are also known as the boundaries of the design operating envelope
				or the limit above (or below) which it is considered unknown or
				unsafe to operate. Once the operating parameter(s) reach the
				buffer zone entry point, there is no designed or intentional
				operator intervention (i.e., troubleshooting) to bring the
				process system upset back to a safe state. Any intervention in
				the buffer zone is as a result of the continued activation of the
				safety devices and automatic protection systems which initially
				activated at the predefined level during the troubleshooting
				phase. All of these predefined limits are important information
				for operators to know and understand and must be included in the
				PSI and operating procedures. 
				Are
				operating procedures implemented as written? 
				 
			 
			VI.
			PHA, Incident Investigation, and Compliance Audits
			Findings/Recommendations.
			
			 
			
				
				Have
				all corrective actions from PHA, incident investigations, MOCs,
				and compliance audits been corrected in a timely manner and
				documented? Provide a list of all outstanding corrective actions,
				the date of corrective initiation, and the projected completion
				dates. 
 
Guidance:
				There may be instances when a PHA team identifies deficiencies in
				equipment/systems which would violate the requirements of
				119(j)(5) if left uncorrected. If the site continues to operate
				the deficient equipment/system, they must take interim measures
				per 119(j)(5) to assure safe operation, and they must also meet
				the 119(e)(5) requirements to resolve the findings and
				recommendations related to the identified deficiency.  
 
The
				phrase from 119(j)(5), "safe and timely manner when
				necessary means are taken to assure safe operation", when
				taken in conjunction with 119(e)(5) means that when a PHA team
				identifies a deficiency in equipment/systems and the site does
				not correct the deficiency before further use, the site's system
				for promptly addressing the PHA team's findings and
				recommendations must assure: 1) that the recommendations are
				resolved in a timely manner and that the resolutions are
				documented; 2) the site has documented what actions are to be
				taken, not only to resolve the recommendation, but to assure safe
				operation until the deficiency can be corrected; 3) that the site
				complete actions as soon as possible; and 4) that the site has
				developed a written schedule describing when corrective actions
				related to the resolution and any interim measures to assure safe
				operations will be completed. 
 
The system that promptly
				addresses and resolves findings and recommendations referred to
				in both 1910.119(e)(5) and 1910. 119(m)(5) are not
				requirements to develop a management program for globally
				addressing the resolution of findings and recommendations.
				Rather, these "system" requirements address how each
				specific finding and recommendation will be individually resolved
				(Hazard Tracking requirement under VPP). Each finding or
				recommendation will have its own unique resolution based on its
				nature and complexity. 
				Has
				the PHA incorporated all the previous incidents since May 26,
				1992 which had a likely potential for catastrophic consequences? 
				 
			 
			VII.
			Facility Siting/Human Factors.
			
			 
			
				
				Does
				the PHA consider the siting of all occupied
				structures? 
 
Guidance:
				Facility siting considerations for occupied structures include
				both permanent and temporary (e.g., trailers)
				structures. 
 
Global/generic facility siting
				questionnaires/checklists. Some employers (PHA teams) attempt to
				comply with this 1910.119(e)(3)(v) requirement by answering
				global/generic facility siting questions on a short
				questionnaire/checklist. PSM is a performance standard and the
				means the site uses to comply with the standard are generally up
				to them as long as their performance ensures compliance with the
				requirement of the standard. If the site uses a
				questionnaire/checklist as part of its PHA to identify, evaluate
				and control all hazards associated with facility siting, this is
				permissible as long as the method they used complies with the PHA
				methodology requirement, and, more importantly, all facility
				siting hazards have been addressed (i.e., identified, evaluated
				and controlled). This questionnaire/checklist type of methodology
				would not be compliant if the site (PHA team) did not have
				specific justifications for each individual situation/condition
				that the global/generic questions addressed.  
 
For
				example, a PHA team responds "Yes" to a
				questionnaire/checklist asking, "Is process equipment
				located near unit battery limit roads sited properly?" In
				this case, OSHA would first expect that the site (PHA team) would
				have identified
				each location
				where process equipment is sited near a unit battery limit road.
				Next, OSHA would expect the site would have evaluated
				each
				piece of process equipment located in the vicinity of a roadway.
				This evaluation is conducted to determine if each
				of the specific process equipment's siting is adequate/controlled
				(e.g., guarded by crash barriers, elevated on a concrete
				pedestal, etc.) to protect it from releasing its hazardous
				contents should it be struck by vehicular traffic. Without
				specific justification or other specific evidence that
				corroborates the site's "Yes" response to this
				global/generic questionnaire/checklist question, a possible
				regulatory issue could exist for failing to address process
				equipment siting near roadways when it conducted its PHA.
				 
 
Guidance: Occupancy
				Criteria Evaluations for Employee Occupied Structure.
				OSHA does not accept occupancy criteria evaluations (see API 752,
				Section 2.5.2) as the basis for a site's determination that
				adequate protection has been provided for employees in occupied
				structures which sites have identified as being potentially
				subject to explosions, fires, ingress of toxic materials or high
				energy releases. In these occupancy criteria evaluations, the
				site identifies vulnerable employee occupied structures and the
				hazards they may be subjected to, but rather than providing
				protection to either the structures or employees through measures
				like employee relocation, spacing, or protective construction,
				the site simply accepts the employee exposures as adequate based
				on their own acceptable occupancy criteria. This occupancy
				criteria evaluation is solely based on the occupancy threshold
				criteria a site is willing to accept. For instance, API 752 list
				occupancy threshold criteria used by some companies as 400
				personnel hours per week as acceptable exposure for employees in
				an occupied structure, regardless of the magnitude of the hazard
				these employees are potentially exposed to. The 400 personnel
				hours per week equates to 2 employees continually exposed in an
				occupied structure even if that structure has virtually no
				protective construction and it is sited immediately adjacent to a
				high pressure-high temperature reactor which contains flammable
				or extremely toxic materials. 
 
Non-Essential
				Employees.
				A site's PHA facility siting evaluation must consider the
				presence of non-essential personnel in occupied structures in or
				near covered processes. The "housing" of these
				non-essential employees in occupied structures near operating
				units may expose them to explosion, fires, toxic material, or
				high energy release hazards. Therefore, unlike direct support/
				essential personnel (e.g., operators, maintenance employees
				working on equipment inside a unit, field supervisors, etc.) who
				are needed to be located in or near operating units for
				logistical and response purposes, sites (PHA teams) must consider
				and justify why non-essential employees are required to be
				located in occupied structures which are vulnerable to the
				hazards listed above. The term "non-essential"
				identifies those employees who are not needed to provide direct
				support for operating processes. Non-essential employees include,
				but are not limited to, administrative personnel, laboratory
				employees when they are working inside a lab, maintenance staff
				when they are working inside maintenance shops/areas, and
				employees attending training classes.  
 
Guidance: An
				example of how a temporary structure could affect a release of
				HHC would include a situation where a trailer's unclassified
				electrical system could potentially ignite flammable
				materials/unconfined vapor cloud if released from the process. 
				Do
				the PHA teams identify and evaluate all situations where
				operators are expected to carry out a procedure to control an
				upset condition, but where the operators would not have enough
				time to do so based on operating conditions? 
				Do
				the PHA team(s) identify and evaluate all situations where field
				employees must close isolation valves during emergencies, but
				where doing so would expose the employees to extremely hazardous
				situations? For example, to isolate a large inventory of
				flammable liquids, a downstream manual isolation valve would need
				to be closed, but the isolation valve is located in an area that
				could be consumed by fire. 
 
Guidance:
				Some sites (PHA teams) attempt to comply with this requirement by
				simply addressing some global/generic human factors questions on
				a short questionnaire/checklist. This type of methodology would
				not, by itself, be adequate if the PHA team did not have specific
				justifications for each of its global/generic responses.  
 
For
				example, if a PHA team responds "Yes" to a
				questionnaire/checklist asking whether emergency isolation valves
				(EIV) are accessible during emergencies, OSHA would then expect
				that the PHA team had identified,
				evaluated,
				and considered each
				EIV's accessibility ( i.e., would the EIV be located in an area
				that might be consumed in fire, or is the EIV located above
				grade). 
				How
				do the PHA teams identify likely human errors and their
				consequences? Have appropriate measures been taken to reduce the
				frequency and consequences of these errors? 
				 
			 
			VIII.
			Operator Training.
			
			 
			
				
				Have
				operating employees been trained on the procedures each is
				expected to perform?  
 
Guidance:
				An "A" operator might be required to perform a
				different set of operating procedures than a "C"
				operator. Therefore, to determine if the employee has in fact
				been trained on the specific operating procedures they are
				expected to perform, cross-reference the specific procedures that
				an individual operator is expected to perform with the training
				records of the specific procedures for which the individual
				operator has received training. Also determine if operators
				perform tasks more than what is expected for their level of
				training. 
				From
				interviews with control board operators in the units, have these
				operators received sufficient training, initial and refresher, to
				be qualified to shutdown the units per the requirements of
				119(f)(1)(i)(D)? 
				Based
				on the employer's explanation of their management of operator
				refresher training, verify that selected operating employees
				received, completed, and understood the refresher training. For
				each employee who operates a process, has the employer ensured
				that the employee understands and adheres to the current
				operating procedures and that the refresher training is provided
				at least every three years, and more often if necessary? 
				 
			 
			IX.
			Safe Work Practices.
			
			 
			
				
				Does
				the site have a safe work practice which it implements for
				motorized equipment to enter operating units and adjacent
				roadways? 
 
Guidance:
				"Motorized equipment" includes, but is not limited to
				automobiles, pickup trucks, fork lifts, cargo tank motor vehicles
				(CTMV), aerial lifts, welder's trucks, etc. 
				Does
				the site audit its safe work practices/procedures for opening
				process equipment, vessel entry, and the control of entrance to a
				facility or covered process area? 
				Does
				the site have a safe work practice for opening process equipment,
				e.g. piping and vessels, and does the site require their
				employees and contractor employees to follow it? 
				 
			 
			X.
			Incident Investigation Reports.
			
			 
			
				Provide
				a list of actual incidents and near-miss incidents that occurred
				at the site within the last year. Have all factors that
				contributed to each of the incidents been reported and
				investigated?  
 
Guidance:
				An "actual incident" is defined as an incident with
				negative consequences such as a large HHC release, employee
				injuries or fatality, or a large amount of property or equipment
				damage. Typically, based on loss-control history, there is a much
				higher ratio of near-miss incidents in the chemical processing
				and refining industries than there are actual incidents.
				
				 
			 
			XI.
			Blowdown Drums and Vents Stacks (Blowdowns).
			
			 
			
				
				Does
				the site have any blowdowns? If so, does the PSI include the
				original design and design basis for each blowdown at the
				site? 
 
Guidance:
				Blowdown(s) – refers to a piece of disposal equipment in a
				pressure-relieving system whose construction consists of a drum
				to collect liquids that are separated ("knockout") from
				vapors and a vent stack, which is an elevated vertical
				termination discharging vapors into the atmosphere without
				combustion or conversion of the relieved fluid. Blowdown(s) are
				separate vessels intended to receive episodic (e.g., when
				de-inventorying a vessel for a planned shutdown) or emergency
				discharges. Blowdown(s) are designed to collect liquids and to
				dispose of vapors safely. In the refinery industry, hydrocarbons
				typically enter blowdown(s) as liquids, vapors, or vapors
				entrained with liquids. Blowdown(s) typically include quench
				fluid systems which reduce the temperature of hot, condensable
				hydrocarbons entering the blowdown as well as the amount of vapor
				released via the vent stack. These systems can include internal
				baffles to help disengage liquids from hydrocarbon vapors.
				Sometimes, blowdown(s) include inert gas or steam systems to
				control flashback hazards and to snuff vent stack fires if
				ignited by sources such as lightning 
 
Examples of PSI
				related to blowdowns, their design and design basis include, but
				are not limited to, such items as: 
				
					Physical
					and chemical properties of the materials relieved to blowdowns
					(See API STD 521, Section 6.2.1); 
 
Guidance: Of
					particular concern are heavier-than-air hydrocarbons with
					relatively lower boiling points. Additionally, hot hydrocarbons
					pose a greater risk because they are more volatile. Releasing
					these materials under the right conditions can result in the
					formation of unconfined vapor clouds which can and have resulted
					in major catastrophes at refineries and chemical plants. 
					A
					definition of the loadings to be handled (See API STD 521,
					Section 7.1); 
					The
					exit velocity of gasses/vapors released from the vent stack (See
					API STD 521, Section 7.3.4); 
					Design
					basis/"worst-case" scenario for maximum liquid –
					vapor release to blowdown (See API STD 521, Section 4.5.j and
					7.1.3); 
					When
					more than one relief device or depressuring valve discharges to
					a blowdown, the geographic locations of those devices and valves
					must be defined (See API STD 521, Section 4.4.q. and 7.2.3); 
					The
					design residence time of vapor and liquid in the drum (See API
					STD 521, Section 7.3.2.1.2); 
					The
					design basis for the vapor – liquid separation for the
					drum; 
					The
					design basis for the exit velocities for the vent stack; and 
					 
					The
					nature of other, lesser hazards related to smaller releases not
					related to the design "worst-case" scenario such as
					the release of toxic (e.g.,, H2S) and corrosive chemicals. 
					 
				 
				Since
				the original installation of the blowdowns, have the original
				design and design basis conditions remained the same? If not, was
				an MOC conducted to determine if the blowdown design and capacity
				are still adequate? 
 
Guidance:
				Examples of conditions that may have changed since the original
				design and installation of the blowdowns include: increased
				throughput in the unit(s) that relieve to the blowdowns;
				additional relief streams routed to the blowdown, blowdowns
				originally designed only to handle lighter-than-air vapor
				emissions from their stacks have had liquids or other
				heavier-than-air releases emitted from their vent stacks;
				additional equipment, a new unit, or occupied structures have
				been sited near the blowdowns in a manner that was not addressed
				in the original design or design basis, etc. 
				Did
				the PHA identify all scenarios where hot, heavier-than-air, or
				liquid hydrocarbons might be discharged from blowdown stacks to
				the atmosphere? 
				Can
				the site demonstrate that atmospheric discharges from blowdowns
				are to safe locations?  
 
Guidance:
				Other structures such as control rooms, trailers, offices, motor
				control centers, etc., must be considered in a PHA to determine
				if they have been sited in a safe location that might be affected
				by a hydrocarbon or toxic material release from a blowdown.
				Unsafe locations can include, but are not limited to, the
				location of equipment which could act as an ignition source, such
				as a furnace stack; an employee platform on a column where
				employees would be exposed in the event of a release; a control
				room; a satellite building; a trailer; a maintenance area/shop;
				an emergency response building; an administration building; a
				lunch or break room; etc. 
				If
				there is a high-level alarm in the blowdown drum, is there an MI
				procedure for calibrating, inspecting, testing and maintaining
				the instrument/control? 
 
Guidance:
				The required documentation data must include the date of the
				inspection or test, the name of the person who performed the
				inspection or test, the serial number or other identifier of the
				equipment on which the inspection or test was performed, a
				description of the inspection or test performed, and the results
				of the inspection or test. 
				Have
				blowdown operators received appropriate training, either initial
				or refresher? 
				 
			 
			  
			 
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