By David Ayers
Establishing procedures is as important to reducing hazards as it is to maintaining business operations on all levels. Procedures spell out the standards and conditions to be followed, and comprehensive procedures assist in creating calm from chaos.
By establishing a comprehensive project design review and process hazard review procedure, everyone will know what is expected of them from an environmental, health and safety (EHS) point of view. When business decisions do not take into account environmental, health and safety matters, issues and problems are created that will have to be solved in a crisis situation rather than in a well-thought-out and comprehensive manner. A comprehensive project design review and process hazard review procedure also will help to ensure that adding a piece of equipment or a bringing a new process online will not make the working conditions worse or create hazardous waste by trying to make the working conditions better.
Don't Create Hazards
It is not uncommon for a process to be brought online that creates hazardous waste after the project has started. The questions then asked is: "What should we do with the hazardous waste and how can we reduce it?"
Questions such as these are vital to ask during the initial project or process conception to make sure you are not building the airplane as you fly it, or creating a hazard as you establish the process.
Projects also are judged by cost/benefit, and if no one factors in EHS concerns, then there is the hidden cost of the accidents, injuries, hazardous waste and non-hazardous waste disposal.
In addition, a comprehensive project design review and process hazard review procedure helps with implementing the hierarchy of controls - by engineering out the hazard, implementing administrative procedures and using personal protective equipment (PPE). A comprehensive project design review and process hazard review procedure will help prioritize your efforts to get the most bang for your buck. If you can engineer out the hazard, then it will be a non-issue for the future.
For example, take the "hazard" out of hazardous materials by monitoring for liquid and gas leaks, providing good ventilation exhaust and double-containing chemical lines where it is possible. Administrative procedures can work as long as employees follow the procedures and they are not too time-consuming or difficult to understand. Here is an example of a difficult procedure to follow: Every 2 hours, employees are expected to rotate out of an area if the scrubber is not working properly when the process is using 38 percent hydrochloric acid and not 32 percent hydrochloric acid. These administrative procedures often fall by the wayside and are not followed after a while.
Finally, personal protective equipment can be used by employees to create a barrier and protect them from hazards. But remember, there is a reason PPE is the final step in the hierarchy of controls; it can be misused or used incorrectly. Only by engineering out a hazard can a "win-win" situation be created by protecting employees and allowing them to be as productive as possible.
Several elements combine to form a comprehensive project design review and process hazard review procedure at your facility. The major elements of a successful design and process hazard review process include:
- A project kickoff meeting.
- A documentation review.
- A new or modified construction review.
- An EHS impact review of the project.
- A final process hazard review (PHR) walk-through.
Flowcharts and project diagrams will help provide a visual of the process and create a step-by-step approach to the review, along with a quick representation of the departments from which input is needed to complete the step. Depending on the complexity of the project, some steps can be completed simultaneously.
The first step is sitting down and having a "project kickoff" meeting to let the project or process team personnel introduce themselves. The project or process manager spells out the goals and objectives and starts the group thinking as a team and not just individual departments trying to get the project completed. Teamwork will help smooth the process along and introduce the members of the team to the other members that are tasked with making the project launch successful.
The team members should be accountable to each other to complete action items on time. From an EHS point of view, the team should get an understanding of what the EHS department is looking for. Nothing is more frustrating than not knowing the standards of performance or having a "flexible" standard of performance that depends on schedules and how much money the item costs.
Management commitment will play a large role in this area. Employees only are as committed as the management team. An overall PHR checklist should be made and distributed to the team.
Once the team is established, the next step in implementing a comprehensive project design review and process hazard review procedure is to review the project or process documentation, including product and equipment manuals and specifications, environmental regulations (state, federal, local), material safety data sheets, etc. This is not always a pleasant task. Many of these documents are poorly written or leave some details to the imagination. Consult the Consumer Product Safety Commission Web site (http://www.cpsc.gov) and look for any recalled items that may be used in the project. There are a lot of sprinkler heads currently being recalled.
Many companies do not integrate safety into new equipment purchases and EHS concerns are viewed as an afterthought. For new equipment, a "build and acceptance (B&A)" document can be generated. As part of this document, safety considerations can be listed along with the abatement required to reduce the injury potential by engineering out the hazard to an acceptable level.
This is where you can get a lot of bang for the buck. Hopefully, your company or site management already goes to the EHS department to ask for recommendations on reducing injury potential before equipment is installed or an accident or incident occurs. These recommendations then are integrated into the B&A document and this is a requirement to be fulfilled by the manufacturer before the equipment is accepted and construction begins.
For example, one recommendation might be to double-contain liquid chemical lines and provide a spill cable within the outer jacket. This will contain the spill and the spill cable will provide fast response to a liquid chemical leak. The equipment vendor then must accompany the equipment to the site and show compliance with the B&A document. Hot topics that should be answered include procedures for easy lockout/tagout, any toxic gas monitoring and ventilation requirements, interlocks on the equipment, laser safety and any other equipment-specific safety and training requirements.
If chemicals are to be used in the process, then a chemical substitution should be researched. It is desirable to use the most environmentally friendly chemical, not only for the environment, but also for the employees who will use and service the equipment day in and day out. The chemical substitution could help reduce the need for respiratory protection and other PPE.
Hazardous chemicals also contribute to the generation of hazardous waste. A reduction in hazardous waste generation will help the bottom line and reduce a company's environmental liability at the same time. One such reduction in hazardous waste generation could be to replace the solvent dip tanks for cleaning engine parts with a soap and water system. The parts then are washed and dried in the system, and an oil/water separator is installed to collect the effluent.
If a hazardous chemical cannot be substituted and must be used, then an abatement system will have to be researched to ensure employee safety and to make sure your company operates within any specific operating permits issued to it (air quality, wastewater, etc.) by the state in which the site is operating.
If the facility has any environmental permits, then these will have to be reviewed to ensure you do not exceed your environmental permit limitations. Even if the permit is not exceeded, the permit may have to be modified to account for the increase in pollutants emitted. Individual site environmental permits are issued on a site-by-site basis and are not covered in the scope of this article.
To help identify environmental permitting issues, an environmental impact assessment can be completed. This will assist in identifying areas where an increase in hazardous waste will occur.
The environmental impact assessment also should list any reductions that will occur because of the new process. This helps accent the positive that will come from the project. A reduction in pollutants may take your facility out of the Title V regulations or reduce your wastewater effluent enough to ease the pH range to discharge. An environmental impact assessment does not always have to be negative.
Equipment operations and maintenance (O&M) manuals are another valuable source of information. The manuals have the materials of construction and, sometimes, the estimated service life of certain consumable parts. This will help in the planning phase to ensure that any chemical used will not prematurely corrode the piping and that the correct materials of construction are used.
Predictive maintenance procedures should be covered in the manuals and will help to formulate a plan to eliminate or reduce any interim actions during events such as liquid chemical spills and gas leaks that will have to be dealt with. The equipment vendor predictive maintenance procedures for a monthly, quarterly, semiannual and annual PM will be listed. This will help in determining the service intervals, number of employees and the resources that will be needed to accomplish these tasks. The manuals also detail any safety issues and an injury reduction plan then can be implemented.
Specific lockout/tagout procedures will have to be written for the equipment. Maintenance personnel can write these procedures, as they are the experts and will have to perform the LO/TO on the new equipment. A draft of the operational and maintenance procedures can be completed at this point. Documentation review is an important aspect that is many times overlooked.
The next step in implementing a project design review and process hazard review is to review any new/modified construction that will be taking place. This is where the project/process concept meets the paper. This part of the process will assist employees in visually understanding the project or process concept.
The equipment and any process piping, electrical conduits, fire alarm horns and strobes and even telephones should be drawn onto blueprints to be reviewed by the team. Many jurisdictions require the blueprints to be reviewed and signed off by a professional engineer.
The design review should take into consideration the applicable building, fire and life safety codes. Sources for information about applicable codes include the National Fire Protection Association (www.nfpa.org) and the International Code Council (www.iccsafe.org). Check with your local jurisdiction to find out which codes they have adopted.
Many cities and counties have building permits that will need to be issued prior to starting any construction. A good design concept may get your site a temporary building permit to get you started. The fire safety codes will help with making sure the facility is protected from fire hazards.
A complete list of planned chemical quantities, building occupancies and the level of fire protection are some of the questions that will need to be answered to determine which building and fire codes apply. Life safety codes will need to be consulted to ensure the exit and egress routes are clear and unobstructed. If hazardous gases are used and monitored, then a sequence of operation will have to be decided upon for maintenance alarms, supervisory alarms, evacuations and any automatic shutdown of operations.
Once the applicable building, fire and life safety codes have been determined, a project design can commence. Many companies perform a 25 percent, 50 percent, 75 percent and an issue-for-construction (IFC) set of drawings. The team should decide the level of detail needed for the different design drawings. This will save time when an item that should appear on the 75 percent design review is argued about at the 25 percent design review stage. This will help make the design review process run smoothly and give everyone an indication what will be discussed at each design review.
The next step is to review the impact of the project on employee safety and health.
After the hazards have been engineered out as much as possible, a simple matrix can be constructed that will list the hazard and the abatement needed to further reduce the hazard to an acceptable level. Perhaps new ventilation or filtration equipment is required, or standard operating procedures will need to be changed, or additional equipment-specific training is necessary. A job hazard analysis (JHA) can be performed if the hazards or process are not well-understood.
Emergency procedures must be created for the new piece of equipment. The final maintenance procedures will need to be written to ensure that equipment can be easily locked out/tagged out and maintained at regular intervals.
If you have an onsite emergency response team, additional equipment may have to be purchased and additional ERT procedures implemented along with a process orientation for the ERT members to make sure they are ready to respond to any new emergencies created by the new process and its equipment.
The final project design review and process hazard review should be the last step in the procedure. The PHR checklist can be used to help monitor progress and assign action items.
At this point, there may be some minor punch list items that need to be covered or items that are a result of the construction effort. Some items of the PHR will be subjective, such as good wire management. Other punch list items include:
- Checking process piping for content labeling along with arrows indicating the direction of flow.
- Labeling electrical panel schedules to ensure a good and adequate lockout/tagout for maintenance personnel.
- Checking that all the operating and maintenance procedures are completed and available at workstations.
- Verifying operator and ERT training.
- Testing the fire alarm if it was modified in any form.
- Testing the evacuation procedure before an incident occurs.
- Testing building public address systems along with running an ERT drill.
At the completion of the project, the person responsible for completing the work should sign for their department. This shows ownership by the individual for ensuring the work has been completed.
Implementing a comprehensive process design review and process hazard review procedure is not an easy feat, as many employees are used to working on their "slice of the pie" and the rest is for someone else to worry about. A comprehensive procedure will help create calm from chaos and ensure that there are no hidden areas for increased employee injury, emergency response incidents and the true cost of hazardous waste generation.
David Ayers, CHMM, CSP, M.S., has been an EHS professional for 10 years. He is the senior safety engineer for National Semiconductor Maryland and holds an M.S. in safety management from West Virginia University and an M.S. in environmental management from the University of Maryland. National Semiconductor Maryland has been an OSHA VPP site since July 2005.