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| Item | Equipment Tag / Activity | Question | Scenario | Consequence / Hazards | Engineering / Admin Controls | C | F | R | Recommendations |
|---|---|---|---|---|---|---|---|---|---|
| 4.025 | All equipment found on all drawings. Facility Siting: Emergency Situation | There is insufficient staffing to maintain (PSM) critical equipment and document activities as required by 29 CFR 1910.119 (j) to meet minimum standards and provide for safe process operation | Insufficient maintenance coverage due to company downsizing | Loss of VPP Recognition/Status Potential Violations/Fines Exposure to litigation Fire/Explosion Potential Release | None | 4 | 4 | A | Conduct study to determine the minimium staffing required to maintain critical equipment and staff accordingly. |
| 4.018 | All equipment found on all drawings. Facility Siting: Emergency Situation | Control software is changed and modification is not communicated to affected employees | Maintenance employee changes software and creates process upset | Business Interruption Potential for Spill Potential for Fire | Training System Backup | 4 | 3 | A | Document all software changes via a written log. Require initials for review or changes. Investigate software for version control. Consider remote access for Control Engineer (i.e., Cytrix, PC Anywhere) |
| 4.017 | All equipment found on all drawings. Facility Siting: Emergency Situation | Unauthorized tampering with an interlock | Safety setpoints on load cells are changed and the tank overflows. CAMT high level setpoint is adjusted outside of range and overflow occurs. | Spill Environmental Impact Fire Potential Process Interruption | Employee Training Procedures | 3 | 4 | A | Emphasize through training the requirements for interlock changes. Identify who is authorized. Strict and consistent enforcement or disciplinary polich. |
| 4.016 | All equipment found on all drawings. Facility Siting: Emergency Situation | What if the emergency plan, the evacuation routes, and assembly point is not sited with consideration of possible incident locations? | Evacuation points in relation to blowout panels | Employee at Risk | None | 3 | 4 | A | Review evacuation assembly points to minimize risk to employees from blast in mixing. |
| 4.015 | All equipment found on all drawings. Facility Siting: Emergency Situation | What if there is a potential for an incident with one piece of equipment to affect other equipment? | Fire ignites in one mixing tank and spreads to other tanks(s). | Process Interruption Fire / Explosion Quality Issue Personnel Injury | Interlocks Alarms Human Intervention | 4 | 1 | C | No recommendations |
| 4.011 | All equipment found on all drawings. Facility Siting: Control Room | What if the control room is not designed and/or sited with consideration of possible process incidents? | Blast occurs in mixing and shatters observation windows in control room | Employee Injury | Window covers with fusable links | 2 | 4 | B | Confirm glass in window is blast resistant. |
| 4.009 | All equipment found on all drawings. Facility Siting: Security System | What if there is no site security system? | Unauthorized entry onto site by unauthorized personnel / contractors. | Sabbotage Fire / Explosion Process Interruption Risk to Onsite Employees | Controlled Acces Perimiter Fencing Camera Surveillance Onsite Security Service | 4 | 2 | B | Ensure security remains in place for life of facility. |
| 4.003 | All equipment found on all drawings. Facility Siting: HVAC Equipment | What if a release is drawn back into the facility by HVAC equipment? | A release is drawn back into the facility by HVAC equipment. This increases the exposure of employees to hazardous consequences. | Employee Exposure Fire / Explosion Potential | Low odor threshold allows for early detection | 3 | 2 | B | No recommendations |
| 4.002 | All equipment found on all drawings. Facility Siting: External Events | What if external events have not been accounted for in the system design? | External events (e.g., natural disasters-tornado/hurricane, trucking or airplane crashes, etc.) have not been accounted for in the system design. The external event causes a leak / rupture, resulting in a release (i.e., SLA system is impacted by tornado / vehicle). | Major Business Interruption Property Damage Potential Injuries | Emergency Disaster Plan | 4 | 2 | B | Review integrity of supporting structure and accessibility to truck traffic. Install barriers where required or modify traffic patterns. |
| 3.016 | All equipment found on all drawings. Human Factors: Written Procedures | What if a procedure is not periodically reviewed and updated? | Changes are made in the process and existing procedures are not revised to reflect changes. | Equipment Damage Quality Issues Employee Injury | Document Control Required Annuual Procedure Review | 2 | 4 | B | No recommendations |
| 3.014 | All equipment found on all drawings. Human Factors: Written Procedures | What if there are no procedures for some or all of the operations or maintenance activities? | Critical equipment maintenance is performed on equipment without documented PSM required maintenance procedures. | Injury / Fatality Equipment Damage Process Interruption | Training Job Knowledge | 3 | 4 | A | Ensure all identified critical equipment has documented maintenance procedures and those procedures are followed. |
| 3.013 | All equipment found on all drawings. Human Factors: Training / Education | What if employee training is not documented? | Employee is not trained in safe work practices (Lockout Tagout / Operating Procedures). | Injury / Fatality Process Interruption | Documented Training | 2 | 2 | C | Consider improving / enhancing software to notify area employees when refresher training is required. |
| 3.012 | All equipment found on all drawings. Human Factors: Task Design / Job Organization | What if an employee is stressed due to shift work and overtime schedules? | Due to staff shortages, employee is required to work extended hours (16). | Fatigue increased risk for accidents Morale Issues Employee Health Issues | Overtime Policy | 3 | 4 | A | Adhere / enforce overtime policy Provide additional staff to provide coverage |
| 3.009 | All equipment found on all drawings. Human Factors: Organization / Policies | What if human factors / issues are not systematically addressed by management? | Employee reductions / staffing in hazardous areas requires employees to perform additional responsibilities and often work alone due to business conditions (cost reductions). | Employee Injury / Fatality Quality Issues Potential for Fire / Explosion | Conflict Resolution Program HR Hotline Ombudsman | 3 | 3 | B | Educate levels of management with influence on decision making to the importance of staffing in critical areas. |
| 3.007 | All equipment found on all drawings. Human Factors: Workplace / Working Environment | What if the work environment is too cold, hot, humid, noisy, or dark? | Employee work environment is extremely hot and places employee at risk for heat stress / stroke due to insufficient cooling capability on first and second floor. | Employee Injury / Fatality Operator Error | P.M. - Facilities Maintenance | 2 | 4 | B | Professional review of HVAC System by a competent expert with the necessary credentials and knowledge (i.e., ASHRAE P.E.) |
| 3.005 | All equipment found on all drawings. Human Factors: Operator / Process Interface | What if set points are changed without authorization? | Setpoints are changed without MOC resulting the equipment to operate outside the safe operating limits. | Equipment Damage Employee Injury / Fatality Release Process Interruption Quality Issues | MOC Procedure Training | 3 | 4 | A | Ensure operating limits established in operating procedures are communicated and adhered to. |
| 3.004 | All equipment found on all drawings. Human Factors: Operator / Process Interface | What if the control / display layout does not follow the standard format? | Controls are confusing and operator makes an error. | Spill Fire / Explosion Hazard | Interlocks / Alarms Training | 3 | 1 | C | Standardize emergency push buttons through the Mixing Area. |
| 3.003 | All equipment found on all drawings. Human Factors: Operator / Process Interface | What if an employee strikes equipment, piping, or valves with a hammer, wrench, etc? | An employee strikes equipment / piping / valves with a hammer, wrench, etc. This causes a crack or rupture, resulting in a release. | Fire / Explosion Potential Employee Injury / Fatality Spill | Training Ventilation (reduced vapor concentration) | 3 | 3 | B | Re-emphasize the importance through documented training. |
| 3.002 | All equipment found on all drawings. Human Factors: Operator / Process Interface | What if the employee must perform maintenance on equipment while operating? | Maintenance is performed on equipment while the equipment is operating. An upset occurs, exposing the maintenance personnel to a release. | Employee Injury / Fatality | Training Job Knowledge Manufacturer Recommendations | 2 | 3 | B | Identify areas where this could occur and document the procedural requirements. |
| 3.001 | All equipment found on all drawings. Human Factors: Operator / Process Interface | What if there is inadequate isolation prior to maintenance? | Piping and / or equipment is inadequately isolated for maintenance. The piping / equipment is opened, resulting in a release. | Spill Employee Injury / Fatality Equipment Damage Fire / Explosion Potential | Lockout / Tagout Procedures | 4 | 4 | A | Ensure that all equipment containing energy sources in the Mixing Area have a documented Lockout / Tagout Procedure in place. |
| 2.003 | All equipment found on all drawings. Emergency Situation: Location and Use of Emergency Equipment | What if emergency equipment is incompatible between emergency response teams? | Emergency equipment is incompatible between emergency response teams (e.g., fire department, hazardous response contractors, local emergency response teams, etc.). This results in an increased exposure to hazardous consequences. | Delayed Response Potential for Injuries / Fatalities | Coordinated Training w/ Fire Department Radio exchange at Main Gate with Response Personnel Roles and Responsibilities | 3 | 1 | C | No recommendations |
| 2.001 | All equipment found on all drawings. Emergency Situation: Employee Emergency Notification System | What if the employee emergency notification system is non existent, inadequate or inoperable during an emergency situation? | The employee emergency notification system is non existent, inadequate or inoperable during emergency situation. This prevents proper initiation of emergency actions (e.g., evacuation, shelter in place), increasing the exposure to hazardous consequences | Employee Injury / Fatality Delay in Required Emergency Response | Separate Radio Frequencies Dual Repeaters on Backup Power Training | 3 | 2 | B | Ensure / Verify repeaters are not on same circuit. |
| 1.001 | All equipment found on all drawings. Facility Siting: Equipment | What if the instrumentation tubing is improperly protected? | The instrumentation tubing is improperly protected. The tubing experiences an impact. This causes the tubing to leak, resulting in a release or this causes an incorrect reading resulting in a release. | Potential for Unsafe Shutdown Process Interruption Spill / Release Potentail Fire / Explosion | 2 | 3 | B | Conduct surveillance for tubing susceptible to impact. |