OSHA PSM Document Request

OSHA PSM Document Request

Here we have an example, from our brother in laws facility, of what regulatory agencies are requesting as a ChemNEP document request. Organizations, and the adept PSM pros they hire, have become more effective and efficient in responses to requests that once left industry pros spinning for traction. But just as it always has, iron sharpens iron, and those making the requests have grown in their own proficiency within the PSM realm.

We hope you all have Merry Christmas and Happy New Year.  Thank you for choosing GCAP as your training provider.

 

www.AmmoniaTraining.com 

 

OSHA – DOCUMENT REQUEST #1

COMPANY: XXX

REQUESTED DELIVERY DATE: XXX

ATTACHMENT A
Item Description
01  

Provide all injury and illness logs (OSHA-300 & 300A) for the last 3 full years plus the current year to date.

 

02  

Provide the legal name of the facility/company, tax identification number, SIC code, and NAICS codes.

 

03  

Provide the number of employees controlled by the company at the facility, number of employees working at PSM covered process, and the number if employees corporate wide (USA).

 

04  

Document(s) exhibiting a summary description of the facility PSM program and PSM “Manual” if appropriate.

 

05  

Document(s) exhibiting or a listing of personnel by name and position responsible for implementing the PSM standards with various elements.

 

06 Document(s) exhibiting the organizational structure (Organizational Chart) showing Position/Title and name of person in the position.

 

07  

 

Document(s) exhibiting Hazard Communications (HAZCOM) policy/procedures for this facility. IF you use corporate procedures as a part of your establishment procedures, please provide any and all corporate procedures developed and implemented as part of your establishments program procedures.

 

08  

 

Document(s) exhibiting Respiratory Protection policies/procedures for this facility. If you use corporate procedure as a part of your establishment procedures, please provide any and all corporate procedures developed and implemented as part of your establishments program procedures. This request includes fit testing results and medical evaluations.

 

09  

 

Document(s) exhibiting the maximum intended chemical (Anhydrous Ammonia) inventories in pounds (lbs.), the method used for determining the maximum intended inventory amount, and procedure/methods used to ensure that the maximum intended inventory is not exceeded.

 

10  

Document(s) exhibiting a procedure/guideline for receiving fresh or make-up Anhydrous Ammonia, certificate of analysis and bills of lading in last 5 years.

 

11  

Document(s) exhibiting PPE Hazard Assessments for the facility including the ammonia refrigeration system.

 

12  

 

Document(s) exhibiting or a listing of all Ammonia Related Incidents in the past 5 years including the current year classified by type (first aid, near-miss, environmental, etc.) including the title and the location in which the incident occurred in the facility.

 

13  

 

Document(s) exhibiting all near-miss investigation summaries completed for the facility in the last year including the current year for Ammonia Related Incidents. Document(s) to include complete report such as but not limited to the root cause analysis if completed, written schedules for actions or findings to be completed or addressed, and documentation of how actions and/or findings were resolved.

 

14  

Document(s) exhibiting the electrical classification of the ammonia refrigeration engine room.

 

15  

 

Document(s) exhibiting the facility’s energy control/lockout-tagout (LOTO) program for this facility. If you use corporate procedures as a part of your facility program, please provide any and all corporate programs developed and implemented as part of your facility’s program.

 

16  

 

Document(s) exhibiting management of change (MOC) policy/procedures for this facility. If you use corporate procedures as a part of your facility program, please provide any and all corporate programs developed and implemented as part of your facility’s program.

 

17  

Document(s) exhibiting or a listing of employee completed training. Documents that show the name of employee, type of training received, and date the training was completed (please do not provide training content).

18  

Document(s) exhibiting the ammonia refrigeration operators training including content specific to the operation of the ammonia refrigeration system including certificates if appropriate.

19  

 

Document(s) exhibiting or a listing of all workers (i.e., hourly and supervisory) involved in the operation of the ammonia refrigeration systems including names, job titles, work shifts, start date in the unit, and the name of the person(s) to whom they report (their supervisor).

 

20  

Document(s) exhibiting the process flow diagrams (PFD) for the ammonia refrigeration system.

 

21  

Document(s) exhibiting Piping and Instrumentation Diagrams (P&IDs) including legends for the ammonia refrigeration system.

 

22  

Document(s) exhibiting a narrative description/process overview for the processes of the facility.

 

23  

Document(s) exhibiting the date of the original start-up and the last upgraded for the ammonia refrigeration system.

24  

Document(s) exhibiting each date and the quantity that anhydrous ammonia was increased to the ammonia refrigeration system in last 5 years.

 

25

 

 

 

Document(s) exhibiting the facilities Mechanical Integrity (MI) procedures (program and task specific instructions) related to the inspection, testing, servicing, repair, alteration of pressure vessels, addressing insulated and non-insulated equipment, frequency of inspections, steps to be taken when insulation is found damaged or inadequate, and when frequency of inspections are to be altered or modified, and piping and relief system equipment. If you use corporate procedures developed and implemented as part of your establishments program. Procedures to be included.

26  

Document(s) exhibiting the design codes and standards employed and utilized for the installation and maintenance and on-going mechanical integrity of the ammonia refrigeration system equipment and components.

27  

 

Document(s) exhibiting or a listing of critical safety equipment and instruments (interlocks, safety devices, emergency shutdowns, etc…) for the ammonia refrigeration system.

 

28  

Document(s) exhibiting or a listing of current MI deficiencies/exceptions within the ammonia system in the last 2 years.

 

29  

 

Document(s) exhibiting or a listing of pressure vessels included as part of the ammonia refrigeration system indicating the vessel functional item number/descriptor, description of service and location.

 

30  

 

Document(s) exhibiting or a listing of safety relief devices associated with the ammonia refrigeration system indicating the device functional, item number/descriptor, description of service, equipment being protected, relief set point and location.

 

31  

Document(s) exhibiting or listing of oil drain locations in the ammonia refrigeration system.

 

32  

Document(s) exhibiting procedure(s) for draining refrigeration oil from the ammonia refrigeration system.

 

33  

 

Document(s) exhibiting the Standard Operating Procedures (SOP) for the ammonia refrigeration system including but not limited to Initial Start-up, Normal Operations, Temporary Options, Emergency Operations, Emergency Shutdown, Normal Shutdown, Safe upper/lower limits and steps avoid deviation from the safe upper/lower limits, Start-up following a turnaround or after an emergency shutdown, and unloading anhydrous ammonia.

 

34  

Document(s) exhibiting last two annual certifications of the Standard Operating Procedures (SOPs) for the ammonia refrigeration system.

 

35  

Document(s) exhibiting the facilities Emergency Action Plan and/or Emergency Response Plan/Procedures.

 

36  

 

Document(s) exhibiting or listing of all contractors (company name) that perform work on site along with trade/service being provided for the ammonia refrigeration system in the last 2 years.

 

37  

Document(s) exhibiting procedures/policies to evaluate contractor safe performance and programs for the facility.

 

38  

Document(s) exhibiting all contractor injury illness logs for the facility in the last 5 years.

 

39  

 

Document(s) exhibiting the ammonia refrigeration engine room ventilation system design information including the design codes and standards utilized, normal and emergency ventilation sizing and operational requirements (describe how it works), and equipment (exhaust fans) specifications.

 

40  

Document(s) exhibiting the ammonia detectors range and set points for emergency shutdown, ventilation system activation and alarms active.

 

41  

Document(s) exhibiting the intervals and last 2-year testing results of the ammonia detectors, evacuation alarm system and alarms activation system.

 

42  

Document(s) exhibiting the procedures used for bypassing or disabling a device such as but not limited to an ammonia system interlock, alarm(s), detectors, or shutdown system.

 

43  

 

Document(s) exhibiting the facilities last two (2) Process safety management (PSM) compliance audits including findings, recommendations/findings, checklists and/or documents used to conduct the audit, and recommendation(s)/findings status reports.

 

44  

Document(s) exhibiting the procedure(s) for system logs for the ammonia refrigeration system.

 

45  

Document(s) exhibiting system logs information for the last 10 days for the ammonia refrigeration system.

 

46  

Document(s) exhibiting the procedure(s) for the establishing thickness measurement locations (TML’s) for vessels and piping for the ammonia refrigeration system.

 

47  

Document(s) exhibiting Process Hazard Analysis (PHA) policy/procedures for this facility. If you use corporate procedures as a part of your establishment procedures, please provide any and all corporate procedures developed and implemented as part of your establishments program procedures.

 

48  

 

The initial process hazard analysis (PHA) for this facility. This includes document(s) exhibiting PHA reports, PHA worksheets, checklists (such as those that may be used for additional human factors & facility siting issues), actions to address findings and recommendations promptly, written schedules for actions to be completed, documentation of findings and recommendations, and documentation of the resolution of any findings and recommendations.

 

49  

 

The most recent update/redo or revalidation process hazard analysis (PHA) for this facility. This includes document(s) exhibiting PHA reports, PHA worksheets, checklists (such as those that may be used for additional human factors & facility siting issues), actions to address findings and recommendations promptly, written schedules for actions to be completed, documentation of findings and recommendations, and documentation of the resolution of any findings and recommendations.

 

50 Document(s) exhibiting the design codes and standards utilized and written testing procedures (Full and/or Partial) for interlocks and/or safety instrumented controls such as but not limited to the following systems:

1.       Pressure Cut Out on Compressors (High & Low)

2.       Compressor Oil Pressure Differential Cut Out

3.       Compressor High Temperature Cutout

4.       Engine Room Emergency Ventilation

5.       Emergency Stop Button

6.       Level Controls (HIGH & LOW)

 

51  

Provide a list of management of changes (MOC) including title, date and status for the ammonia refrigeration system in the last 5 years.

 

52  

Provide management of changes (including all documents associated with) for the following

1.       Expansion of the engine room and addition of the ammonia refrigeration system.