SAFETY

QC-PSM-MNL-00-0001
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PSM Compliance Manual

01 Jul 09
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TABLE OF CONTENTS

1.

INTRODUCTION .......................................................................................... 2

2.

PURPOSE .................................................................................................... 2

3.

SCOPE ......................................................................................................... 2

4.

REQUIREMENTS ......................................................................................... 2

5.

REFERENCES ............................................................................................. 6

6.

ATTACHMENTS .......................................................................................... 6

7.

APPENDICES .............................................................................................. 6

Rev.

Issue Date

01 Jul 09

Amendment Description
New Document

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Prepared By:
R. Bartolome

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1. INTRODUCTION
29 CFR 1910.119 requires facilities that handle highly hazardous chemicals to develop a Process
Safety Management (PSM) program.
This OSHA standard is to aid facilities in efforts to prevent or mitigate episodic chemical releases
that could lead to a catastrophe in the workplace and possibly to the surrounding community.
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2. PURPOSE
This manual is intended to provide an outline of the general compliance and implementation
strategies for the 14 elements of PSM. Where necessary, detailed description of associated work
processes are addressed in separate documents.

3. SCOPE
This manual is applicable to the Q-Chem manufacturing facilities in Mesaieed and Ras Laffan.

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4. REQUIREMENTS
4.1

Employee Participation
4.1.1

Intent: Consult and involve employees and their representatives in the conduct and
development of the process safety management (PSM) program.

4.1.2

Implementation Strategy

Employee involvement and participation is encouraged in all work processes

which govern process safety management such as:
Development, review, and revision of process safety information.
Performance of PHA studies
Development, review, and revision of operating procedures and safe work
practices
Development, review, and revision of training modules
Coordination and oversight of contractor activities
Conduct of pre-startup safety reviews
Development, review, and revision of procedures for maintaining
equipment integrity
Development, review, and revision of the work permitting process
Initiation, coordination, and implementation of changes
Conduct of incident investigations
Drills and emergency response exercises
Conduct of internal and external compliance audits
Access to all PSM-related information regardless of trade secret status
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4.2

Process Safety Information

4.2.1

Intent: Compile written information pertaining to process chemicals, process

technology, and process equipment.

4.2.2

Implementation Strategy

4.3

Process Hazards Analysis

4.3.1

Intent: Perform an initial process hazard analysis (PHA) on processes covered by

the PSM standard. These studies must be revalidated at least every five years after
initial completion. Develop a system to track recommendations generated from these
studies.

4.3.2

Implementation Strategy

4.4

PHA studies are coordinated through the Safety Department. HAZOP/LOPA is

the primary method used to conduct PHA studies in the facility. Specific details
of HAZOP/LOPA and associated processes are contained in the following
documents:
PHA Procedure (QC-PSM-PRO-00-0001)
Risk Ranking Matrix (QC-HSE-TBL-00-0008)

Operating Procedures
4.4.1

Intent: Develop, implement, and maintain clearly written, accessible procedures for
safely operating a process during all operating modes. These procedures must be
reviewed periodically and certified annually to ensure their accuracy. Safe work
practices to provide for the control of hazards during operations must also be
developed and implemented.

4.4.2

Implementation Strategy

4.5

Process safety information (PSI) is managed through the Technical

Department as per the provisions of the PSI Policy (QC-PSM-PCY-00-0002).

Operating procedures are developed and implemented by the respective

production units to reflect current operating practices.
The format and content of operating procedures must follow the requirements
stated in the Plant SOP Standard (PD-GEN-STD-00-0001) and outlined in the
SOP Template (QC-PSM-SFM-00-0004).
Operating procedures are kept current and certified through a periodic
evaluation process as described in the Operating Procedures Review,
Revision, and Certification Procedure (PD-ADM-PRO-00-0001).
The EDMS is the primary means for access to operating procedures. EDMS
printouts have a validity of 7 days from the print date as per the date stamped
on the hard copies.
Safe work practices are managed through the Safety Department. These
procedures are developed, reviewed, and implemented as per the
requirements of the Safety Manual Development and Review Process (HSESAF-PRO-00-0020).

Training
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4.5.1

Intent: Train employees involved in operating a process on the overview of the

process and the operating procedures. The training shall include emphasis on
specific safety and health hazards, emergency operations, and safe work practices.
Refresher training shall be provided at least every three years. The completion and
comprehension of training must also be documented.

4.5.2

Implementation Strategy

4.6

Contractors
4.6.1

Intent: Define the responsibilities of the facility and contractors to ensure contractor
employee safety and eliminate/minimize incidents caused by contractor activities.

4.6.2

Implementation Strategy

4.7

4.7.1

Intent: Implement a review process to ensure that specified requirements have been
met before the introduction of any highly hazardous chemical into a new or modified
process involving a change in chemicals, technology, or equipment.

4.7.2

Implementation Strategy
Pre-startup safety reviews are led and coordinated by change facilitators and/or
equipment owners. PSSR requirements are described in the MOC/PSSR
Policy (QC-PSM-PCY-00-0010).

Mechanical Integrity
4.8.1

Intent: Implement an ongoing equipment integrity program that ensures process

equipment are designed, constructed, installed, and maintained to minimize the risk
of hazardous releases.

4.8.2

Implementation Strategy

4.9

The program for contractor safety management is a multi-department

responsibility as outlined in the Contractors Procedure. The work processes
contained in this document are based on the requirements of the global
procedure from CPChem, OE 1250 Contractor Safety Management.

Pre-Startup Safety Review

4.8

The Training and Development Section leads and coordinates operator training
through the Operator Certification and Refresher Training Policy (QC-PSMPCY-00-0005) and associated documents such as:
Training Guidelines (AD-TRN-GLN-00-0001)
Global Training Matrix (AD-TRN-MTX-00-0001)

The equipment integrity program is also a multi-department responsibility as

outlined in the Equipment Integrity Policy (QC-PSM-PCY-00-0008). Specific
work processes for the program are contained in the Equipment Integrity
Manual (QC-PSM-MNL-00-0002).

Hot Work
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4.9.1

Intent: Develop and implement safe work practices to manage hazards during nonroutine/non-operational tasks.

4.9.2

Implementation Strategy

Control of any activity using open flame or any other source of ignition,
otherwise known as hot work, is addressed through the Permit To Work
(PTW) Procedure (HSE-SAF-PRO-00-0006).

4.10 Management of Change

4.10.1 Intent: Establish and implement procedures to manage changes to process
chemicals, technology, equipment, procedures, and facilities.
4.10.2 Implementation Strategy

The Safety Department provides oversight for the MOC process. Change
management for changes other than replacement-in-kind (RIK) are addressed
through the MOC/PSSR Policy (QC-PSM-PCY-00-0010).

4.11 Incident Investigation

4.11.1 Intent: Investigate each incident which resulted in, or could reasonably have resulted
in a catastrophic release of highly hazardous chemical in the workplace.
4.11.2 Implementation Strategy

The requirements for the investigation of incidents and near misses are
covered in the Incident/Near Miss Reporting and Investigation Procedure.
(HSE-SAF-PRO-00-0001).

4.12 Emergency Planning and Response

4.12.1 Intent: Establish and implement an emergency action plan for the facility in
accordance with the provisions of 29 CFR 1910.38 to appropriately and safely
handle releases of hazardous chemicals.
4.12.2 Implementation Strategy

Each of the Q-Chem facilities have developed and implemented a site-specific

emergency preparedness and response plan to address emergencies (HSEERT-PRO-00-0001). In addition, the Emergency Response Section also
maintains a set of standards and procedures for the inspection, testing, and
maintenance of ER-related systems and equipment to ensure their
serviceability at all times.

4.13 Compliance Audits

4.13.1 Intent: Certify that the facility has evaluated compliance with the provisions of the
PSM standard, at least every three years, to verify that the procedures and practices
developed under the standard are adequate and are being followed.
4.13.2 Implementation Strategy
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The specific details on the conduct of compliance audits are contained in the
Compliance Audits Procedure (QC-PSM-PRO-00-0002). These system audits
are conducted as part of the organizations Compliance Assurance Program
(QC-OEM-PRO-00-0001).

4.14 Trade Secrets

4.14.1 Intent: Make all information necessary to comply with the PSM standard available to
people responsible for PSM work processes without regard to possible trade secret
status of such information.
4.14.2 Implementation Strategy

Q-Chem will make available all relevant information, regardless of its

confidential nature, to employees or authorized contractors to safely perform
approved work activities.
Q-Chem shall specifically make available all information necessary to those
persons responsible for:
Compiling process safety information
Conducting and participating in process hazard analysis
Developing operating procedures and safe work practices
Conducting and participating in incident investigations
Emergency planning and response
Conducting and participating in compliance audits
Q-Chem shall require all employees and permanent contractors to sign a
confidentiality agreement as part of their employment contract.
Q-Chem shall require all third-party contractors to sign a confidentiality clause
as part of the contract process.

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5. REFERENCES
29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals
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6. ATTACHMENTS
None
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7. APPENDICES
None
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