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04/13/2005
Conclusions
Appendix:
Management Responsibilities
OSHA APPENDIX C TO 1910.119 - COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT
In addition, various engineering societies issue technical reports that affect process design.
For example, the American Institute of Chemical Engineers has published technical reports on topics such as two-phase flow for venting devices. This type of technically recognized report would constitute good engineering practice. Operating procedures addressing operating parameters will contain operating instructions about pressure limits, temperature ranges, flow rates, what to do when an upset condition occurs, what alarms and instruments are pertinent if an upset condition occurs, and other subjects.
Computerized process control systems add complexity to operating instructions. These operating instructions need to describe the logic of the software as well as the relationship between the equipment and the control system; otherwise, it may not be apparent to the operator.
Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures.
Our Interpretation
Now that organizations like the EEMUA have defined recommended practices for Alarm Management, OSHA will soon compare your plants to these practices.
Do You Know What Is Really Critical?
By Dennis C. Hendershot
In general, a more reliable plant is a safer plant. Unplanned shutdowns, with equipment in modes of operation not anticipated by the designer, can create significant risks. And, data shows that for most continuous chemical plants, the highest risk phases of operation are startup and shutdown.
Our Interpretation
An effective alarm system is important in terms of production, safety and equipment damage. Alarms need to occur early enough, but not too early.
Responsible Care Manufacturing Code of Practice
Each company shall have written operating, engineering and maintenance procedures which specify conditions for the responsible operation of any facility during normal or abnormal circumstances. The company shall:
Our Interpretation
You need to conduct process hazard analyses, and have comprehensive procedures to address how the operator must respond to alarms.
Matrikon ProcessGuard
EEMUA
Alarm Management Workshops
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