Contractors and Process Safety Management

Introduction

Process Safety Management (PSM) is a crucial aspect of ensuring the safety and well-being of workers in industries where hazardous materials and processes are present.

US OSHA Process Safety Management 1910.119 establishes specific safety standards for workplaces with hazardous materials and processes. Canadian Provinces and Territories have implemented similar protocols to manage hazards where dangerous materials and substances are present.

The core of PSM is to prevent or minimize the occurrence of catastrophic incidents such as explosions, fires, and releases.

This article covers PSM elements and responsibilities that impact contractors as they work within running facilities or engage in maintenance activities where significant process hazards are present.

Impacted Industries

Here are the major industries where contractor workforces are typically exposed to process-related hazards:

• Chemical manufacturing: This includes companies producing chemicals such as pharmaceuticals, pesticides, fertilizers, paints, and other chemical substances.

•  Petroleum refining: Oil refineries process crude oil to produce various petroleum products like gasoline, diesel, jet fuel, and lubricants.

• Petrochemical industry: This sector produces chemical products derived from petroleum or natural gas, such as plastics, synthetic fibers, solvents, and various specialty chemicals.

• Pharmaceuticals: Manufacturing facilities that produce drugs, medications, and pharmaceutical products.

• Pulp and paper industry: Paper mills and pulp manufacturing plants that use chlorine, hydrogen peroxide, or other hazardous substances in their processes fall under the scope of PSM requirements.

• Food processing: Certain segments of the food processing industry may be subject to the PSM standard if they use highly hazardous chemicals, such as ammonia refrigeration systems in cold storage facilities.

• Steel and metal processing: Industries involved in the processing and fabricating steel, aluminum, and other metals may come under the PSM standard if they handle hazardous chemicals or have specific processes that pose risks.

• Waste treatment and disposal operations typically have high-hazard chemical processes.

• Renewable energy: Certain renewable energy sectors include biofuels or biomass processing facilities. 

Process Safety Management

Energy Safety Canada, in their publication, An Introduction to Process Safety, defines Process Safety as a disciplined framework for managing the integrity of operating systems and processes handling hazardous substances.

It is achieved by applying good design principles, engineering, and operating and maintenance practices. It deals with the prevention and control of events that have the potential to release hazardous materials and energy.

Such incidents can result in toxic exposures, fires, or explosions and could ultimately result in serious incidents, including fatalities, injuries, property damage, lost production, or environmental damage.

Where Contractors Fit In

Contractors and subcontractors play a vital role in implementing PSM on work sites. Understanding and fulfilling specific responsibilities is essential to maintain a safe working environment. The key responsibilities include:

• Coordination with the Facility: General Contractors must coordinate with the facility's management to ensure they know the PSM requirements and understand their responsibilities within the site's safety framework. From a field safety management perspective, much of the work coordination requirements are typically managed through a safe work permit system. Contractors must know and comply with the permit system operated by the facility owner or their designate.

• Training and Qualifications: Contractors must ensure that their personnel are appropriately trained and possess the necessary qualifications to perform their assigned tasks safely. This includes understanding the hazards associated with the processes, following established procedures, and being familiar with emergency response plans. Fundamental knowledge requirements on PSM worksites include control of energy (electrical and mechanical isolations), hot work safety, HAZCOM/WHMIS, and respiratory protection. Contract employees must understand potential emergency conditions, site-specific warning systems, evacuation and muster procedures, and call-in procedures.

• Compliance with PSM Elements: Contractors must comply with the PSM elements relevant to their scope of work. These elements include process safety information, process hazard analysis, operating procedures, training, contractor management, pre-startup safety review, mechanical integrity, and incident investigation. By adhering to these elements, contractors contribute to maintaining a safe work environment.

• Communication and Reporting: Contractors must communicate and collaborate effectively with the facility's management and other contractors to exchange critical safety information and promptly report any potential hazards, incidents, or near-miss events. Timely communication enhances overall safety awareness and enables proactive hazard mitigation.

Subcontractor Management

General contractors are responsible for managing subcontractors to ensure that they adhere to PSM requirements. Subcontractor management entails:

• Prequalification and Selection: General contractors should prequalify subcontractors based on their safety records, experience, qualifications, and adherence to safety standards. Selecting reputable and safety-conscious subcontractors experienced on work sites with process hazards is a prequalification consideration.

• Safety Orientation and Training: General contractors must provide subcontractors with a comprehensive safety orientation and ensure they receive appropriate training regarding the site's PSM requirements. While facility owners are obligated to ensure safety orientation specific to PSM issues is provided to all contractors on the work site, it is the job of the general contractor to ensure that their subcontractors attend the orientation.

• Continuous Monitoring: General contractors monitor subcontractors' performance throughout the project, conduct periodic safety assessments, and address any non-compliance issues promptly. Regular inspections help identify potential hazards and ensure subcontractors work according to established safety protocols.

• Communication and Collaboration: Effective communication between general contractors and subcontractors is essential to maintain a seamless flow of safety information. General contractors should establish clear communication channels, provide feedback, and encourage subcontractors to report safety concerns or incidents.

Contractor Requirements Under Process Safety Management Standards

Contractors must adhere, at least, to the following PSM elements and activities:

• Written Procedures: Contractors must develop and implement written procedures for safely conducting their work activities. These procedures should address the specific hazards associated with the covered processes and outline the steps to ensure safety. It is common for facility operators to impose particular standards for high-risk work activities like confined space entry, electrical and mechanical isolations of process equipment, safety work permit systems, and chemical management protocols. In these cases, general contractors and their sub-contractors must understand and comply with the owner/operator protocols.

• Safe Work Practices: Contractors must establish and enforce safe work practices consistent with the PSM requirements. This includes using appropriate personal protective equipment (PPE), following established procedures, and maintaining a safe work environment.

• Hazard Communication: Contractors must ensure that their employees understand the hazards associated with the covered processes and have access to the necessary information about the chemicals involved. This includes providing Safety Data Sheets (SDSs) for the chemicals, communicating the hazards to employees, and training employees on interpreting and using the information.

• Pre-Job Planning: Contractors must engage in pre-job planning to assess the hazards associated with their work and develop appropriate safety measures. This includes identifying potential risks, establishing procedures to mitigate those risks, and communicating the safety requirements to all involved parties. Incorporating a permit review (where a permit system has been implemented) is a critical component of pre-job planning on PSM worksites.  

• Incident Reporting: Contractors must promptly report incidents, accidents, or near misses to the facility owner/operator. This allows for investigation, analysis, and implementation of corrective actions to prevent similar incidents in the future.

Conclusion:

In conclusion, Process Safety Management is a comprehensive framework designed to prevent and mitigate the risks associated with hazardous substances and processes.

Contractors and subcontractors working on sites where PSM regulations are in force must proactively fulfill their responsibilities, including coordination, training, compliance, communication, and subcontractor management. By doing so, they ensure their own safety and contribute to the overall safety and success of the project.

Ultimately, the commitment to Process Safety Management benefits everyone involved, fostering a secure working environment and preventing accidents and incidents that could have severe consequences.