30

Years
of
Excellence

PROCESS
SAFETY
MANAGEMENT
The booklet
March 2010
 General Manager's
Message

PSM
Safety Beyond Excellence

We in GPIC always strive our obligation to protect our

to establish new systems employees, assets and the local
and strategies to improve our community.
practices in all aspects of our
business. Safety has always This booklet outlines the PSM
been on top of our priorities and requirements and describes
goals. The drive to implement GPIC’s approach to achieving
Process Safety Management those needs. We believe that only
(PSM) relates back to 2001 through the continuous support
when the initial work began to and dedication of our employees
meet the OSHA requirements. at every level we make GPIC one
In 2009, we revitalized the of the safest plants.
PSM Committee with a view to
synergize the company systems to
be more compliant with the PSM
requirement.
GPIC’s Process Safety
Management (PSM) program is
designed to integrate and align
under one umbrella, our plants
related Engineering, Safety,
Operation and Maintenance
activities, with a clear objective
to minimize process related risks.
Through this program, we intend
to achieve the main goal of fulfilling

1 | PROCESS SAFETY MANAGEMENT HANDBOOK2010

GPIC - 30 YEARS OF EXCELLENCE | 2
 Table of
Contents
GM MESSAGE 1
PSM COMMITTEE MESSAGE 4
PSM ELEMENT ADMINISTRATORS 5
PSM MAIN OBJECTIVES 6
DEFINITION 7
PSM ELEMENTS 8
EMPLOYEE PARTICIPATION (EP) 9
PROCESS SAFETY INFORMATION (PSI) 11
PROCESS HAZARD ANALYSIS (PHA) 13
OPERATING PROCEDURES (OP) 15
EMPLOYEE TRAINING (ET) 17
CONTRACTORS (CO) 19
PRE-STARTUP SAFETY REVIEW (PSSR) 21
MECHANICAL INTEGRITY (MI) 23
HOTWORK PERMIT (HWP) 25
MANAGEMENT OF CHANGE (MOC) 27
INCIDENT INVESTIGATION (II) 29
EMERGENCY PLANNING AND RESPONSE (EPR) 31
COMPLIANCE AUDITS (CA) 33

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 PSM
Committee Message
The Process Safety The PSM Committee’s role is
Management (PSM) of Highly to spearhead the establishment,
Hazardous Chemicals, OSHA maintenance, continuous
Standard 29CFR1910.119, is evaluation and enhancement of the
intended to prevent or minimize PSM program. In 2010, we will
the consequences of the release further enhance the program by
of toxic, reactive, flammable or introducing Risk Based Process
explosive chemicals from the Safety (RBPS).
adopted processes. At GPIC,
we have incorporated these This booklet is intended to
requirements into the Integrated give all our employees an overall
Management System and decided understanding of the PSM program
to extend the scope of PSM to and how we comply the OSHA’s
cover all process related hazards. requirements within GPIC.

The PSM system facilitates the All of us play an important role in

elimination of process incidents the success of the PSM program
that could potentially occur as implementation.
a result of failures in systems,
procedures or equipment in
process plants. It is a major step
forward towards a safer working
environment.

GPIC - 30 YEARS OF EXCELLENCE | 4

 Fire & Safety Suptd.

Mechanical Suptd.

5 | PROCESS SAFETY MANAGEMENT HANDBOOK2010

 PSM
Main Objectives
Prevent or minimize  To ensure safe and
the consequences Healthy workplaces and
surrounding environment.
of catastrophic
 To integrate all adopted
release of toxic, practices, system and
reactive, flammable procedures.
or explosive,  To improve productivity

Highly Hazardous and help in minimizing

operation expenses.
Chemicals (HHC’s)
from a process.

GPIC - 30 YEARS OF EXCELLENCE | 6

 Definition
Process Safety – Why do we need Process
Safety?
preventing of accidental
releases of hazardous Prevent major accidents


substances or energy which and reduce the

create safety, environmental consequences of those
or business impact. that do occur
Process Safety
Improve employee’s

Management (PSM) – a health, safety and work
set of formal management environment
practices designed to help
prevent, mitigate, respond to Improve equipment and


or recover from the effects of process reliability

process plants accidents. Reduce production costs


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 PSM Elements
gpic Process Safety  Hot Work Permit
Management has 13  Management of Change
Elements:
 Incident Investigation
Employee Participation

 Emergency Planning and
Process Safety Information

Response
Process Hazard Analysis

 Compliance Audits
Operating Procedures


Employee Training

In the following pages, the
PSM standard requirements
Contractors

and the GPIC compliance are
Pre-Start up Safety Review
 highlighted.
Mechanical Integrity


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GPIC - 30 YEARS OF EXCELLENCE | 8

 1 Employee
Participation (EP)
In order to achieve a high degree of
“Employee” involvement, the element
directs organizations to give its employees
access to Process Hazards Analysis
and all its related practices and systems.
This includes all types of information
concerning safety of plants and personnel.

9 | PROCESS SAFETY MANAGEMENT HANDBOOK2010

GPIC Compliance
Employees are consulted and are fully involved
during the development and implementation of any
Process Hazard Analysis study. Such involvement is
demonstrated through the following methods:
• The establishment of PHA teams, committees
like the SHE committee, Management Union
High Council, Management Union Committees,
regular meetings (Departmental, Sectional and
Daily Operations).
• Incident Reports, Suggestion Improvement
Program, Shift Talks, etc.

Controlling Documents
 SOP-PSM-00-01, Process Safety Management
of Hazardous Chemicals
 PSM Electronic Database

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 2 ProcessSafety
Information (PSI)
The element requires that all the Process
Safety Information shall be made available
in order to carry out a successful Process
Hazard Analysis. This information shall

help in identifying and understanding
the hazards posed by those processes
involving highly hazardous chemicals.

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GPIC Compliance
Information related to Material Safety Data Sheet
(MSDS) of chemicals, codes and standards used,
equipment details, Process & Instrumentation
Diagrams (P&IDs) and Process Flow Diagrams (PFDs)
is captured through the Technical Data Books (TDB),
Maintenance Data Books (MDB), Operation Manuals
and Basic Engineering Documents. The documents
are available at six locations (i.e. controlled libraries)
within GPIC Complex. There is an established system
that ensures controlling, maintaining and updating of
all Process Safety Information documents in those
libraries.

Controlling Documents
 SOP-ENG-02-11, Management of Change (MOC)
 SI-TEC-01, Material Safety Data Sheet Technical
Data Book (TDB Volume 112)
 SOP-ENG-02-04, Updating Technical Documents
 SOP-ENG-01-13 Process Hazard Assessment
(PHA) Procedure

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 3 ProcessHazard
Analysis (PHA)
The element requires that Process Hazard
Analysis (PHA) should be carried out for all
the processes handling Highly Hazardous
Chemicals. This shall help in identifying
the hazards in the process. All such PHAs
should be revalidated at least once every
five years.

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GPIC Compliance
Process Hazard Analysis (PHA) for all the plants
has been completed and documented. The PHA
studies have been revalidated in year 2009. The next
revalidation of all the plants is scheduled to be after
5 years.
Furthermore, in GPIC, process hazard analysis
review is carried out on each and every change
during the Management of Change (MOC) cycle.

Controlling Documents
 SOP-ENG-01-13, Process Hazard Assessment
(PHA) Procedure
 SOP-ENG-02-11, Management of Change (MOC)

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 4 Operating
Procedures (OP)
The element requires that there should be
clear documented operating procedures
to safely carry out activities concerning
normal start-ups and shutdowns,
emergency shutdowns, operations of
temporary nature, handling and exposure
to hazardous chemicals, etc.

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GPIC Compliance
GPIC’s existing Standard Operating Procedures
and Standing Instructions include:
• Normal start ups and shutdowns
• Emergency shutdowns considering various
scenarios and plant upsets.
• Simplified trip logic diagrams, catalyst
manual

Controlling Documents
 Standard operating procedures (Plant SOPs)
 Standing Instructions (Plant SIs)
 Plant Trip Logic Diagrams
 SHE-SAF-07, Permit to Work System
 SHE-SAF-05, Complex Emergency
 Material Safety Data Sheets (TDB Vol. 112)
 Relevant P&IDs
 Relevant Vendor Manuals

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 5 Employee
Training (ET)
The element requires that each employee
operating a process is imparted the
relevant training. Thus, each employee
before being involved in operating a
newly assigned process requires to be
adequately trained. Also, refresher training
in operating such processes needs to be
provided to the employees periodically.
The training shall emphasise on the
specific safety and health hazards.

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GPIC Compliance
A structured training program is provided to
employees (including operators, technicians,
supervisors and engineers) prior to the assignment
of any new responsibility. Refresher training program
is also put in place and is designed to update
the knowledge, skills and awareness of safety,
environment and health hazards.
Besides acquiring training on the details of plant
configuration, the program also aims at updating the
employees with “lessons learned” on the process
incidents and accidents that have taken place in
other similar plants. Further, training needs of all
employees are identified and courses are organized
accordingly.

Controlling Documents
 SOP-TRN-00-01, Training and Development
Program for Graduate Supervisors & Engineers
 SOP-TRN-00-03, Cross Training & Development
Procedure for Plant Operators
 SOP-TRN-00-11, New Operators Training
Program
 SI-TRN-00-08, New Employee(s)

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 6 Contractors (CO)
The element requires that contractors
performing maintenance, repair,
turnaround, major renovation work or
specialty work on the process or adjacent
to the process shall be well trained in
carrying out the intended work and shall
be informed about the known potential
hazards related to the work and/or the
process involved.

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GPIC Compliance
GPIC's direct hire and /or lump sum contractors
go through a selection process that starts from
contractor prequalification assessment, trade
testing, equipment verification, safety induction
training, on the job assessment, weekly contractor
safety meetings and post service evaluation.
Contractors performing maintenance within the
process areas are apprised about the hazards
during Safety induction training.

Controlling Documents
 FR-PLN-70-02, Contractor Prequalification
Requirements
 SOP-PLN-70-01, Contracator Services
Management
 FR-MTR-01-09, Contractor / Vendor Performance
Evaluation Form
 GL-S&S-01-08, Safety Checking of Contractors
Equipment
 SOP-S&S-02-02, GPIC Complex Access
& Egress (Induction to contractors by SHE
Department)
 FR-PLN-70-10, Technical Evaluation- Manpower
Supply Services.
 FR-PLN-70-09, Technical Evaluation- Package
Contract Services.
 FR-MTR-01-13, Supplier Pre-qualification Form.

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 7 Pre-Startup
Safety Review
(PSSR)
The element requires that a pre-startup safety
review to be carried out for new facilities and
modifications in the process area.
The review shall confirm that the changes
are as per the design and specifications,
that the safety, operating, maintenance and
emergency procedures are adequate, and
that sufficient training has been given to the
employees for operating the new process or
change.

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GPIC Compliance
A formal Standard Operating Procedure has been
put in place to ensure that any newly installed facility
or modification, before being commissioned, has
been executed as per:
• Relevant design codes, specifications, and
engineering drawings
• Relevant operating, safety and emergency
procedures
• HAZOP recommendations
• Relevant training

Controlling Documents
 SOP-OPR-01, Pre Startup Safety Review (PSSR)
Procedure
 FR-PSM-01 to 10, PSSR Checklists

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 8 Mechanical
Integrity (MI)
The element requires that written
procedures should be available to
maintain:
• Pressure vessels, storage tanks, piping
systems, pumps.
• Relief and venting systems, emergency
shutdown systems, and controls (like
alarms, trip interlocks, etc.)
The standard also, requires quality
assurance during the fabrication and
installation of plant equipment.

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GPIC Compliance
At GPIC, a comprehensive inspection schedule in
line with the process licensor(s) guidelines is being
followed. A Risk Based Inspection technique is also
employed to strengthen the inspection program.
Furthermore, the following activities are carried out
during turnarounds:
• Internal examination of major equipment.
• Safety Relief valves, emergency shutdown
systems and interlocks are checked and tested.
When new equipment is being procured it is
ascertained that the fabrication, construction and
installation is as per the specifications laid down in
the technical enquiry and it adheres to the applicable
codes and standards.
Furthermore, a comprehensive critical equipment
list has been developed at GPIC identifying process
equipment which have impact on production, safety,
health and environment.

Controlling Documents
 SOP-PLN-30-05, Preventive Maintenance
Management
 SOP-MCH-01-42, Mechanical Integrity
 SOP-ISP-00-14, Risk Based Inspection (RBI)
 Critical Equipment List

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 9 HotWork
Permit (HWP)
The element requires that a hot work
permit is to be issued for any hot work
operation conducted on or near a process
area.

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GPIC Compliance
GPIC Permit To Work (PTW) comprehensively
covers the hot work permit system. Authorization
to receive or issue permit to work is only granted to
those who pass both a written exam and an interview
to ensure that they fully understand the requirement
and the essence of the (PTW). Appraisal is done
every two years to revalidate this authorization. GPIC
PTW procedure is regularly audited and reviewed.

Controlling Documents
 SHE-SAF-07, Permit to Work System

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 10 Management
of Change (MOC)
The element requires that written
procedures should be established
and implemented to manage changes
to process, chemicals, technology,
equipment and procedures that are not
“Replacement in kind”.
Employees or contract employees whose
job will be affected by the change should
be informed and trained about the change
prior to its commissioning and start-up.

PHA

Screening & Engineering

Raise Implementation
Processing & Approval
RFC

Archive Updating of PSI FAC PSSR

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GPIC Compliance
Changes in any of GPIC facilities, including process
related changes, are covered under the Management
of Change (MOC) Procedure. The Management of
Change system ensures that all requirements; such
as HAZOP, environmental impact, training, and
operating procedure changes are considered before
implementing the change.

Controlling Documents
 SOP-ENG-02-11, Management of Change (MOC)

GPIC - 30 YEARS OF EXCELLENCE | 28

 11 Incident
Investigation (II)
The element requires that each process
incident which resulted in, or could
reasonably have resulted in catastrophic
release of highly hazardous chemicals
should be investigated.
The standard further requires that the
findings and recommendations arising
from the investigation should be resolved
and documented.

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GPIC Compliance
Process Incident and near misses in GPIC
can be reported by any person. The incident,
investigation findings, recommendations and actions
are recorded and saved in the company’s main
database. The investigations of any “lost time”
incidents are investigated by a dedicated team and
the recommendations are reported to the Executive
Management.

Controlling Documents
 SHE-SAF-13, Accident and Near Miss Reporting
 Lotus Notes, Plant Operations Incident Databank
(derived from SHE-SAF-13)
 SOP-OPR-02, GPIC Plant Operation Incident Data
Bank

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 12 EmergencyPlanning
and Response (EPR)

The element requires that an emergency

action plan for the entire complex be
available. The plan should be designed to
handle small releases also.

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GPIC Compliance
A comprehensive emergency response plan is established
to cater to any emergencies within the Complex. The plan
details the emergency warning alarms, control centers,
assembly points, and job roles of the personnel during
emergencies. The plan is reviewed and tested periodically.

Controlling Documents
 SHE-SAF-05, Complex Emergency Procedure
 SHE-SAF-06, Generic Emergency Procedure
 SHE-SAF-08, GPIC Emergency Planning Guide Procedure
 Mock drills procedure (part of SHE-SAF-08)

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 13 Compliance
Audits (CA)
The element requires that the Process
Safety Management (PSM) processes
are evaluated through a compliance audit
by at least one person knowledgeable in
the process once every three years. The
standard also requires that an appropriate
response to each of the findings is
reported and that all the deficiencies are
corrected.

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GPIC Compliance
There is an established procedure to carryout
internal audits of Process Safety Management system
as part of the internal audits of Integrated Management
Systems in GPIC.
External audits shall be carried out once every three
years.

Controlling Documents
 SOP-IMS-00-01, Internal Audit Procedure

GPIC - 30 YEARS OF EXCELLENCE | 34