| Department | Environmental, Health and Safety | Document no | EHS-115 | ||
| Title | Process Safety | ||||
| Prepared by: | Date: | Supersedes: | |||
| Checked by: | Date: | Date Issued: | |||
| Approved by: | Date: | Review Date: | |||
1. AFFECTED PARTIES
All Environment, Health and Safety personnel
2. PURPOSE
The purpose of this procedure is to ensure that hazards which have the potential to cause acute catastrophic events, such as accidental chemical releases, fires and explosions are identified, assessed and adequately controlled.
3. SCOPE
The policy covers colleagues, contractors and visitors on-site potentially exposed to the risk of harm due to an acute catastrophic event. It applies to operations such as:
3.1 bulk flammable storage and processing greater than 4,500 kg;
3.2 fluid bed drying of flammable solvent-wet material;
3.3 spray drying (as part of fluid bed dryer);
3.4 the milling of Impact Sensitive materials;
3.5 operations involving Explosible Compounds in quantities greater than 100 kg per year.
4. RESPONSIBILITY \ BUSINESS RULES
4.1 Processes shall be operated in a manner to ensure that they remain within their design limits.
4.2 Site Management shall consult the EHS team for the performance of physical hazard and reaction hazard testing and assessment for processes performed in developmental laboratory and manufacturing operations where required.
4.3 The EHS and Training Manager are responsible for ensuring that Process Hazard Analysis (PHA) studies are carried out for processes where required.
4.4 The EHS and Training Department is responsible for notifying EHS team of identified significant risks as specified in procedure “EHS Risk Assessment”.
4.5 The EHS and Training Department are responsible for notifying EHS team of Serious Accidents as specified in the procedure “EHS Reporting Requirements”.
4.6 Departmental managers shall ensure that the lessons learned from serious accidents and process safety improvements are shared within their respective department.
5. PROCEDURE
5.1 PROCESS SAFETY INFORMATION (PSI) PSI will be developed and maintained to include:
5.1.1 Process and equipment design information.
5.1.2 Safety information concerning the hazards of processes.
5.1.3 Information on material hazards including thermal stability, explosion potential etc.
Group EHS will be consulted where necessary to obtain any other process hazard information required for Process Hazard Analysis (PHA).
5.2 PROCESS HAZARD ANALYSIS (PHA)
A Process Hazard Analysis (PHA) will be performed as recommended by the Process Safety Guideline for all new processes and follow-up action will be implemented where necessary to reduce the risk of a process safety incident.
The type of methodology used to assess risks shall depend on the operation. For operations covered by the Process Safety Guideline only because of their use of Explosible Compounds in excess of the threshold, the PHA need only be a review of the substance hazards and the ignition risks.
A more rigorous methodology such as a HAZOP (Hazard and Operability Study) may be required if the group has limited experience, is unfamiliar with the chemistry or technology, or if the process operation is complex. The HAZOP team should comprise of relevant personnel who are suitably trained, are knowledgeable of the process and equipment and are capable of interpreting Hazard data. HAZOP action items shall be tracked to completion using the site PHA Action Tracking Log and the status of these items shall be reviewed on a quarterly basis.
Quantitative risk assessment of a process shall be carried out where the qualitative analysis does not provided sufficient information to make risk management decisions. Dispersion modelling of accidental chemical releases shall be completed to model worst-case credible releases scenarios to determine whether they could result in harm to colleagues or the community.
External assistance may be sought where on-site expertise is not available in specialised PHA techniques.
At a minimum PHA’s will be reviewed within 5 years of the original date, unless the process has been discontinued or has not been scheduled for production.
5.3 MECHANICAL INTEGRITY (MI)
A program will be developed and implemented to maintain the Mechanical Integrity of Safety Critical Equipment and Instrumentation. The program shall include:
5.3.1 Critical equipment and instrumentation lists;
5.3.2 Applicable codes and standards;
5.3.3 Inspection, maintenance and instrumentation calibration methods and frequencies;
5.3.4 Inspection records/equipment files;
5.3.5 Identifying and addressing equipment deficiencies;
5.3.6 Maintaining an inventory of replacement parts. The Engineering Department is responsible for maintaining the MI program.
5.4 MANAGEMENT OF CHANGE (MOC)
Changes to systems, processes, equipment, procedures and materials, will be assessed to evaluate fully the safety, environmental and health implications prior to making changes. This is completed as per site procedure “Evaluating and Implementing a Change Request”.
5.5 INCIDENT RESPONSE/INVESTIGATION
In the event of a process safety incident the site Emergency Plan will be implemented. This procedure is detailed in procedure “Emergency Response Plan”.
Process safety incidents are also investigated and corrective actions taken in accordance with the procedure “Hazard Identification and Incident/Accident Investigation Reports”.
5.6 OPERATING PROCEDURES
Manufacturing Instructions will incorporate necessary controls to reduce the risk of a process safety incident.
5.7 TRAINING
Effected colleagues and contractors will be made aware of potential hazards associated with processes and equipment and the controls in place to reduce the risk of a process safety incident on site.
5.8 DOCUMENTATION
The following documentation shall be maintained:
5.5.1 Process Safety Information – EHS and Training Department, Engineering Department, Manufacturing Department;
5.5.2 Process Hazard Analysis Studies – EHS and Training Department;
5.5.3 Training Records – EHS and Training Department;
5.5.4 Mechanical Integrity related records – Engineering Department;
5.5.5 Management of Change documentation – Technical Services Department, Quality Department and Finance.
6. DEFINITIONS / ACRONYMS
HAZOP (Hazard and operability study)
PSI (Process Safety Information)
PHA (Process Hazard Analysis)
MOC (Management of Change)
7. SUMMARY OF CHANGES
| Version # | Revision History |
| EHS-115 | New |