PSM applicability determination, process hazard analysis, mechanical integrity, management of change and the compliance audit — for ammonia refrigeration, flammables and covered chemical processes.
Companies assume they are under threshold, or assume they are covered and over-comply. Ammonia refrigeration sites in food and beverage are the most common surprise, and the determination should be documented either way.
Process hazard analyses generate recommendations that require resolution and documentation. Open recommendations from a PHA five years ago are among the most damaging findings possible after an incident.
Inspection and test schedules for covered equipment, with acceptance criteria and documented results, plus deficiency correction. This element consumes the most labor and is the most commonly deficient.
Changes get made and the MOC is written afterward, or not at all. Temporary changes that became permanent are a classic finding.
Piping and instrumentation diagrams that do not match the field, missing relief system design basis, and chemical data that was never assembled.
The three-year compliance audit is required, and so is documenting that findings were resolved. Audits sitting with open findings are worse than no audit.
We start with a documented applicability determination, then assess each element against what exists, prioritizing process safety information accuracy, mechanical integrity and management of change — the three that consume the effort and generate the findings.
We facilitate or participate in PHAs and revalidations, build the mechanical integrity schedule and record structure, and run the three-year compliance audit with a closure process rather than a report.
Only above the threshold quantity for anhydrous ammonia in a process. Many food and beverage sites sit just above or just below, and the determination depends on how the process is defined, which is exactly why it should be documented rather than assumed.
RMP covers overlapping chemicals and thresholds with similar elements and separate reporting. Sites covered by PSM are frequently covered by RMP as well, and the programs should be built together rather than twice.
At least every five years. Revalidation is not a re-run from scratch, but it must genuinely account for changes since the last study.
New facilities and modified facilities where the modification requires a change in process safety information. In practice this is closely tied to your management of change process.
Both. We facilitate HAZOP and what-if studies with your operations and maintenance personnel in the room, which is where the value is.
Twenty minutes to work through applicability and, if you are covered, which elements carry your real exposure.
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