What safety document management system is best
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Rosie's answer
Published by SALUSI cannot recommend a specific safety document management system. However, I can provide information on what to consider when selecting and implementing one. An effective process safety management program requires a systematic approach to evaluating the whole process [1]. This includes process design, technology, operational and maintenance activities, emergency preparedness, training programs, and other elements [1].
When auditing your safety programs, documentation is essential 4, 17. The audit should include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer's systems are effectively implemented [2]. The audit team will review all aspects of the training program, including content, frequency, and effectiveness [3]. They will also review safety and health policies, procedures, and work authorization practices [3].
Considerations for your safety document management system:
- Accessibility: Ensure that the site safety plan and all written programs are easily accessible to employees, including mechanisms for review and references [4].
- Accuracy: Complete and accurate written information concerning process chemicals, technology, and equipment is essential [5].
- Organization: The emergency control center should be equipped with plant layouts, community maps, utility drawings, emergency lighting, and appropriate reference materials such as government agency notification lists, company personnel phone lists, SARA Title III reports, safety data sheets, and emergency plans and procedures manuals 2, 17.
- Up-to-date: If changes are made to a process, impacted employees must be trained in the changes and understand the effects of the changes on their job tasks [6].
Sources used for this answer
[1] Rules for the Administration of the Oregon Safe Employment Act (General Occupational Safety and Health, Division 2, OSHA Oregon)
Page 642
Open source documentSource excerpt
Division 2 AO 3-2019 Oregon Administrative Rules The selection of effective audit team members is critical to the success of the program. Team members should be chosen for their experience, knowledge, and training and should be familiar with the processes and with auditing techniques, practices and procedures. The size of the team will vary depending on the size and complexity of the process under consideration. For a large, complex, highly instrumented plant, it may be desirable to have team members with expertise in process engineering and design, process chemistry, instrumentation and computer controls, electrical hazards and classifications, safety and health disciplines, maintenance, emergency preparedness, warehousing or shipping, and process safety auditing. The team may use part-time members to provide for the depth of expertise required as well as for what is actually done or followed, compared to what is written. An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Utilizing the audit procedure and checklist developed in the preplanning stage, the audit team can systematically analyze compliance with the provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of the training program as part of the overall audit. The team will review the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the standard's requirements, documentation, etc. Through interviews, the team can determine the employee's knowledge and awareness of the safety procedures, duties, rules, emergency response assignments, etc. During the inspection, the team can observe actual practices such as safety and health policies, procedures, and work authorization pr…
[2] Occupational Safety and Health Standards (OSHA 29 CFR 1910)
Page 21
Open source documentSource excerpt
## 29 CFR 1910 (OSHA) The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community. To control these types of hazards, employers need to develop the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective process safety management program as envisioned in the OSHA standard. This OSHA standard is required by the Clean Air Act Amendments as is the Environmental Protection Agency's Risk Management Plan. Employers, who merge the two sets of requirements into their process safety management program, will better assure full compliance with each as well as enhancing their relationship with the local community. While OSHA believes process safety management will have a positive effect on the safety of employees in workplaces and also offers other potential benefits to employers (increased productivity), smaller businesses which may have limited resources available to them at this time, might consider alternative avenues of decreasing the risks associated with highly hazardous chemicals at their workplaces. One method which might be considered is the reduction in the inventory of the highly hazardous chemical. This reduction in inventory will result in a reduction of the risk or potential for a catastrophic incident. Also, employers including small employers may be able to establish more efficient inventory control by reducing the quantities of highly hazardous chemicals on site below the established threshold quantities. This reduction can be accomplished by ordering smaller shipments and maintaining the minimum inventory necessary for efficient and safe operation. When reduced inventory is not feasible, then the employe…
[3] Rules for the Administration of the Oregon Safe Employment Act (General Occupational Safety and Health, Division 2, OSHA Oregon)
Page 734
Open source documentSource excerpt
Division 2 AO 3-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - e. The employees will review and discuss the site safety plan as part of the training program. The location of the site safety plan and all written programs should be discussed with employees including a discussion of the mechanisms for access, review, and references described. - B. RCRA Operations Training for Treatment, Storage and Disposal Facilities. - 1. As a minimum, the training course required in 29 CFR 1910.120(p) should include the following topics: - a. Review of the applicable paragraphs of 29 CFR 1910.120 and the elements of the employer's occupational safety and health plan. - b. Review of relevant hazards such as, but not limited to, chemical, biological, and radiological exposures; fire and explosion hazards; thermal extremes; and physical hazards. - c. General safety hazards including those associated with electrical hazards, powered equipment hazards, lockout/tagout procedures, motor vehicle hazards and walking-working surface hazards. - d. Confined-space hazards and procedures. - e. Work practices to minimize employee risk from workplace hazards. - f. Emergency response plan and procedures including first aid meeting the requirements of paragraph (p)(8). - g. A review of procedures to minimize exposure to hazardous waste and various type of waste streams, including the materials handling program and spill containment program. - h. A review of hazard communication programs meeting the requirements of 29 CFR 1910.1200. - i. A review of medical surveillance programs meeting the requirements of 29 CFR 1910.120(p)(3) including the recognition of signs and symptoms of overexposure to hazardous substance including known synergistic interactions. - j. A review of decontamination programs and procedures meeting the requirements of 29 CFR 1910.120(p)(4). - k. A review of an employer's requirements to implement a training program and its elements. - l. A rev…
[4] Rules for the Administration of the Oregon Safe Employment Act (General Occupational Safety and Health, Division 2, OSHA Oregon)
Page 621
Open source documentSource excerpt
Oregon Occupational Safety and Health Division Division 2 ## Appendix C to 1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) This appendix serves as a nonmandatory guideline to assist employers and employees in complying with the requirements of this section, as well as provides other helpful recommendations and information. Examples presented in this appendix are not the only means of achieving the performance goals in the standard. This appendix neither adds nor detracts from the requirements of the standard. - 1. Introduction to Process Safety Management. The major objective of process safety management of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals especially into locations which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, nonroutine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements which impact the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment. The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to …
[5] Rules for the Administration of the Oregon Safe Employment Act (General Occupational Safety and Health, Division 2, OSHA Oregon)
Page 641
Open source documentSource excerpt
Oregon Occupational Safety and Health Division Oregon Administrative Rules AO 3-[redacted street address] for medium to large facilities to enhance coordination and communication during emergencies for on plant operations and with local community organizations is for employers to establish and equip an emergency control center. The emergency control center would be sited in a safe zone area so that it could be occupied throughout the duration of an emergency. The center would serve as the major communication link between the on-scene incident commander and plant or corporate management as well as with the local community officials. The communication equipment in the emergency control center should include a network to receive and transmit information by telephone, radio or other means. It is important to have a backup communication network in case of power failure or one communication means fails. The center should also be equipped with the plant layout and community maps, utility drawings including fire water, emergency lighting, appropriate reference materials such as a government agency notification list, company personnel phone list, SARA Title III reports and safety data sheets, emergency plans and procedures manual, a listing with the location of emergency response equipment, mutual aid information, and access to meteorological or weather condition data and any dispersion modeling data. - 14. Compliance Audits. Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. A small process or plant may need only one knowledgeable person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer's systems are effectively implemented. The audit should be conducted or lead by a person knowledgeable in audit techni…
[6] Rules for the Administration of the Oregon Safe Employment Act (General Occupational Safety and Health, Division 2, OSHA Oregon)
Page 631
Open source documentSource excerpt
Oregon Occupational Safety and Health Division Oregon Administrative Rules AO 3-2019 Division 2 Careful consideration must be given to assure that employees including maintenance and contract employees receive current and updated training. For example, if changes are made to a process, impacted employees must be trained in the changes and understand the effects of the changes on their job tasks (e.g., any new operating procedures pertinent to their tasks). Additionally, as already discussed the evaluation of the employee's absorption of training will certainly influence the need for training. - 7. Contractors. Employers who use contractors to perform work in and around processes that involve highly hazardous chemicals, will need to establish a screening process so that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. For contractors, whose safety performance on the job is not known to the hiring employer, the employer will need to obtain information on injury and illness rates and experience and should obtain contractor references. Additionally, the employer must assure that the contractor has the appropriate job skills, knowledge and certifications (such as for pressure vessel welders). Contractor work methods and experiences should be evaluated. For example, does the contractor conducting demolition work swing loads over operating processes or does the contractor avoid such hazards? Maintaining a site injury and illness log for contractors is another method employers must use to track and maintain current knowledge of work activities involving contract employees working on or adjacent to covered processes. Injury and illness logs of both the employer's employees and contract employees allow an employer to have full knowledge of process injury and illness experience. This log will also contain information which will be of use to those auditing process safety management co…
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