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Process Safety Management (PSM) for Managing Contractors in Process Plant

Article  in  Journal of Loss Prevention in the Process Industries · July 2015

DOI: 10.1016/j.jlp.2015.06.014

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 Journal of Loss Prevention in the Process Industries 37 (2015) 82e90

Contents lists available at ScienceDirect

Journal of Loss Prevention in the Process Industries

journal homepage: www.elsevier.com/locate/jlp

Process Safety Management (PSM) for managing contractors in

process plant
Noor Diana Abdul Majid, Azmi Mohd Shariff*, Risza Rusli
Centre of Advanced Process Safety (CAPS), Universiti Teknologi PETRONAS (UTP), 32610 Tronoh, Perak Darul Ridzuan, Malaysia

a r t i c l e i n f o a b s t r a c t

Article history: Accidents involving contractors continue to occur with regular frequency. By using the standard set
Received 19 March 2015 within the PSM 29 CFR 1910.119(h) regulations, it has been identified that certain aspects of the way
Received in revised form contractors do work are not up to the stipulated regulatory requirements especially regarding matters
30 June 2015
like not providing mandatory personal protective equipment (PPE) to the workers, not discussing haz-
Accepted 30 June 2015
ards related to handling procedures with the workforce and improper control of non-routine activities
Available online 6 July 2015
during changes in shifts. The PSM 29 CFR 1910.119(h) regulations promulgated in 1992 provides stan-
dards that covered processes to obtain and evaluate data regarding contractors' health and safety pro-
Keywords:
Contractor
grams as well as the contractors' performance evaluation. Many of the accidents involving contractors
Emergency planning and response are direct result of poor training of contractors and/or poor control of the contracted work. Even though
Process safety management most organizations have their own contractor management systems, there are issues in meeting the
Safe work practices requirements of PSM. The PSM standard only state “what to do” not “how to do it”. This is known as self-
Training regulatory policy which depends on the industries understanding to interpret the standard that also
contribute to this problem. This paper presents a structured and easy technique to plan and implement a
practical and comprehensive contractors' management system in process industries that will comply
with OSHA CFR 1910.119. A model has been developed based on this technique and its application has
been tested in a pilot plant for compliance to PSM regulation. The model is beneficial to the process
industries as any deficiencies in the PSM contractors' management program will be highlighted by the
model which will then easily correct the identified deficiency so as to minimize and prevent catastrophic
accidents.
© 2015 Elsevier Ltd. All rights reserved.

1. Introduction in Flixborough (1974), Saveso (1976) and Bhopal (1984) caused

Major accidents such as fires, explosions and the release of toxic
chemicals that cause fatalities, damages to the environment as well
as to the facilities are real threats to the process industries. Unfor-
tunately, such major accidents are becoming incrementally harder
to control with the increasing scale and complexity of the modern
chemical process industries (CPI) (Cui et al., 2012; Vaughen and
Kletz, 2012). As the industrial processes become even more com-
plex and the number of conditions to be controlled becomes
something that may threaten to overwhelm the existing safety
management procedures of the facilities or plants, an ever evolving
chemical accident prevention system needs to be implemented to
prevent major industrial accidents. Large scale accidents like those
* Corresponding author.
E-mail address: azmish@petronas.com.my (A. Mohd Shariff).
much grief and are major tragedies that have forever altered the
process industry landscape and have led to widespread changes in
regulations and development of standards and management
systems.
Process Safety Management (PSM) provides clear stipulation of
aspects that the authorities can regulate and monitor closely. It was
developed through discussion with many parties including US
Regulators, Environmental Protection Agency (EPA) and Occupa-
tional Safety and Health Agency (OSHA). The Occupational Safety
and Health Administration (OSHA) enacted PSM requirements in
the Code of Federal Regulations (CFR) Chapter 29, Section 1910.119.
The purpose of the 14 elements regulation is to prevent or mini-
mize the consequences of catastrophic releases of toxic, reactive,
flammable, or explosive chemicals from a covered process that deal
with any of the 137 highly hazardous chemicals as per the listed
quantities of Appendix A of the regulation (Center for Chemical
Process Safety (CCPS) AIChE, 2007; Kwon, 2006; Mark McGuire,

http://dx.doi.org/10.1016/j.jlp.2015.06.014
0950-4230/© 2015 Elsevier Ltd. All rights reserved.
 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90
1996).
Section h of CFR 1910.119 contains the relevant elements for
contractors which require employers to educate contractor about
the processes and related hazards that leads to catastrophic acci-
dents. Industries usually rely on contractors who possess special-
ized skills to perform hazardous tasks during period of intense
activity especially for maintenance, turnarounds and major reno-
vations (Mark McGuire, 1996). The use of contract labor involving
an outside organization should be within the company's risk con-
trol activities (Center for Chemical Process Safety (CCPS) AIChE,
2007). Many deficiencies have been uncovered in the contractor's
management programs when PSM was initially promulgated. The
stipulation of PSM covered specific processes and include the re-
quirements that the plants or facilities' operators must obtain and
evaluate data regarding contractors' safety and health programs as
well as provide paperwork with regards to ascertaining the per-
formance level of the contractors (Early, 1996).
Amongst the non-compliance issues with regards to the regu-
lation stipulated within PSM that commonly arise include not
providing mandatory personal protective equipment (PPE) to
workers, not discussing hazards related to the workforce activities
and improper control of non-routine activities during changes in
shifts (Rashid et al., 2013). Even the most sophisticated operators
find compliance to PSM challenging due to the broad scope and
highly technical nature of the 14 elements (Cunio and Melhem,
2014). Furthermore, these non-compliance issues indirectly re-
lates to the other elements of OSHA PSM regulations particularly on
hot work permit (HWP) and emergency planning and response
(EPR).
After more than 20 years of PSM implementation, accidents
related to contractors still occur. 46 full investigation reports from
1998 to 2008 of plant facility accidents published by U.S. Chemical
Safety and Hazard Investigation Board (CSB) indicate that accidents
have not decreased as expected (Rashid et al., 2013). Even as lately
in 2010, there were at least 6 accidents reported involving con-
tractors out of 40 accident reports submitted to the EU's Major
Accidents Reporting System (eMARS). About 5% of the total acci-
dents reported from 1989 to 2010 in the eMARS major accidents
database have been identified as related to contractors. More than
60 people died and approximately the same number of people
injured. These accidents also involve significant production loss as
well as property or environmental damages.
The application of PSM standards in industries depends on how
the operators translate the standards because it only states “what to
do” not “how to do it”. Thus, the operators need to do it by adopting
internal policies, external standards or a combination of ap-
proaches base on their knowledge, industry practice, facility needs
and conditions and economic considerations (Brackey, 2013; Cunio
and Melhem, 2014). This is known as self-regulatory policy which
depends on the industries’ understanding to interpret the PSM
regulation.
The major challenge to the industries in complying and main-
taining effective process safety programs as per OSHA PSM regu-
lation is the unavailability of easy and effective techniques (Early,
2006; Wee and Jabar, 2008). Regulatory stipulations are all well
and good but to achieve the stipulated standards, procedures must
be reviewed and tighten in such a way as to bring about regulatory
compliance. Unfortunately there is no readily available methodol-
ogy that can be easily adopted to achieve compliance.
Many authors have provided recommendations for continuous
improvements in PSM systems. Louvar (Louvar, 2008) suggested
that companies need to have a system that includes the PSM reg-
ulatory requirements of documentation, communication, delega-
tion and follow-up to ensure that the stipulated standards are
achieved as intended. In addition, designing, implementing and
83
using a complete work process for PSM-related activities are vital to
avoid failures in a PSM management system (Hanchey and
Thompson, 2011). A simple effective and functional system works
better than complicated ones in order to get the job done (Brackey,
2013). None reported on a contractor management system that
follows through the requirements in order to comply and to
maintain an effective contractors' management system.
A comprehensive and systematic management of the contrac-
tors increases the safety and well-being of contractors and their
employees. This will lead to improvements in plant output quality
and productivity as well as less incident rates and minimizes po-
tential damage to the owners’ facilities and equipment (Early,
1996). In addition, it also strengthens the relationships between
contractors and their client companies through joint development
of programs for improvements, better communication and training
(Early, 1996). Thus, new challenges associated with using contrac-
tors must be recognized and addressed by the employer as required
by the OSHA PSM regulations.
Thus, this paper presents a structured and easy technique to
plan and implement contractors' management in process industries
in compliance with OSHA CFR 1910.119. A model has been devel-
oped based on this technique and its application has been tested in
a pilot plant to verify the effectiveness and also to ensure compli-
ance with OSHA PSM standards. The model is beneficial to the in-
dustries as any deficiencies in the PSM contractor's management
program is highlighted and corrected to minimize and prevent
catastrophic accidents.
2. Methodology
Contractor provision is a key element in OSHA PSM to ensure
that levels of safety are not compromised by contractor operations.
PSM regulations state that the host facility is responsible for hiring
contractors with a track record of safe work practices on the job.
The recordkeeping is extensive and burdensome but is essential to
ensure compliance. As stated by Early, (2006), the elements in
PSM standards require data development and management. The
OSHA PSM regulations are performance based and state what
needs to be done but for the most part leave it to the users to
decide how to do it in order to comply (Brackey, 2013; Cunio and
Melhem, 2014).
A study disclosed that many PSM citations focused on cause of
accidents rather than on how the industries could efficiently
comply with PSM standards (Luo, 2010). Many emphasize the
importance of having a good safety program but do not describe
how to achieve it (Haesle et al., 2009; Klein, 2005; Louvar, 2010).
Early (2006) is the only one whom reported on a PSM regulation
compliance study and came out with a system named “Database
Management System for Process Safety”. The system can compile
and upload the information for data tracking and documentation.
However, there is no description on how the system can comply
with each of the elements in PSM based on CFR 1910.119(h)
requirements.
Later on, a system named Process Hazards Management for Lab
Scale Pilot Plant (PHM-LabPP) was developed. PHM-LabPP is about
structured techniques for managing the elements within the reg-
ulations. The process hazards analysis (PHA) in the pilot plant fol-
lows the OSHA PSM standards. The system is based on a framework
that can ensure adequate hazards review and fulfill the PHA re-
quirements. In a case study, this application has been successfully
shown to be workable and practicable to manage process hazards
in the pilot plant. Since it is easy to implement, the PHM-LabPP can
be used to effectively manage the process hazards and correct
unsafe process conditions. This technique can also be extended to
commercial process plants in order to comply with PSM regulations
84 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90
(Abdul Aziz et al., 2011a, 2011b; Aziz et al., 2012). The same
approach was then further developed for other elements of PSM
such as process safety information (PSI) (Aziz et al., 2014b,c) and
mechanical integrity (MI) (Aziz et al., 2014a). However, there is no
description on how the system can comply with contractors
element in PSM based on CFR 1910.119(h) requirements.
Thus, the proposed technique focus on assisting plant personnel
to develop, implement and comply with the PSM contractor ele-
ments besides realizing and closing any missing gaps on the
existing contractor program that the process plant has imple-
mented. The framework shown in Fig. 1 summarizes vital infor-
mation and a strategy to manage and implement the contractor
program as required by CFR 1910.119(h).
2.1. Compliance with OSHA PSM contractor management
Following the PSM standards as illustrated in Fig. 1, employers
need to establish a pre-qualification criteria to obtain and evaluate
the contractor's qualifications prior to selecting the contractor as
required under CFR 1910.119(h)(2)(i). The requirements for quali-
fication as stated in the regulations are the contractor's safety
performance and track records. These regulatory stipulations are
there in order to ensure that the contractors have the knowledge,
skills, and certifications to safely complete the work. This include
the contractor's policy statement on process safety, hazards
communication programs, safe work practices such as hot work,
logout/tagout and requisite training. In addition, the contractors'
accident reports and work activities monitoring will have to be up
to standards.
Apart from that, the most essential contractors' pre-
qualification criteria are financial stability, management and tech-
nical ability, contractors' experience, contractors' performance,
resources, quality management and health and safety concerns (El-
Sawalhi et al., 2007). Hence, contractors are required to comply
with the project owner's established pre-qualification re-
quirements during the bidding period or else the contractors' bid
will be deemed invalid or nonresponsive.
The purpose of contractor selection is to reduce project risk,
minimize overall value to the project owner and build a close and
long term relationship between members of the project (Darvish
et al., 2009). Thus, the contractor selection is based on the proven
safety performance criteria and track records as established in the
pre-qualification program for the assigned jobs. The selected
contractor has to ensure that the contract employees are qualified
to perform the type of work to be carried out, understand the scope
of work and meet the site and regulatory safety and health
requirements.
Once the contractors have been selected, the employer should
verify that the contractors are familiar with the hazards, emer-
gency action plan and applicable safe work practices associated
with the contractors' work before work begins as required under
CFR 1910.119(h)(2)(iieiv). This is to ensure that contractors are
familiar with procedures, risk identification and mitigation in
place. The employer should monitor and evaluate the contractors'
performance periodically according to CFR 1910.119(h)(2)(v) while
maintaining a precise record of any injury and illness within the
log in process area as stated under CFR 1910.119(h)(2)(vi). The
findings from periodic evaluation determines whether any
corrective actions need to be taken in the contractors' safety
programs. Upon completion of the project, the contractors' per-
formance evaluation is conducted to assess the adherence to
safety, schedule, budget and work quality. This assessment will
determine whether the contractors remains in the pre-qualified
contractor's list.
2.2. Using P&ID as foundation for data management
In this study, P&ID is used as a foundation in managing con-
tractors. It is capable of incorporating details like equipment and
auxiliary and provide all the necessary information thoroughly
without any possible missing information. Using P&ID as the
interface enhance the end users' acceptance since it is commonly
utilized in process plants. This approach is also use in studies for
development of structured implementation techniques for process
hazards analysis (PHA), process safety information (PSI) and me-
chanical integrity (MI) elements of OSHA PSM (Abdul Aziz et al.,
2011a, 2011b; Aziz et al., 2013, 2012, 2014a,b,c).
Fig. 2 shows the P&ID framework for managing contractors in
process plants. The P&ID is divided into several nodes whereby the
nodes are selected based on the number of equipment within the
process plant determined by the end users. Hence, when any
maintenance is needed on the nodes, the employer has to clearly
define the job, identify possible hazard and assess the risk; and
lastly to eliminate and reduce the risks. For example, a contractor is
needed for a job to replace a corroded section of the separation
columns that contains absorbents and the section to be replaced is
3 m in height. Thus, the employer should consider the risk of: i)
handling flammable gas at high pressure condition and ii) working
at height. The employer should also come up with a few possible
risk reduction plans.
2.3. Contractor Management System (CoMS)
Inconsistent contractor management practices in the industry
increase the risk of costly delays, mistakes and hazards to health in
addition to threatening the safety of personnel and equipment
besides polluting the environment. A structured systematic
approach will provide a clear process to identify underlying prob-
lems and resolve them in an objective manner. Thus, it is a great
advantage to compile necessary information for contractor man-
agement into one specific database to ease the tracking and coor-
dination of documents and required actions as compared to doing it
manually. Extraction and tracking will be much easier and less
time-consuming. Investing time and effort to develop a consistent
contractor management system for the industry makes good
business sense. This technique has been adapted to a computer
database model known as Contractor Management System (CoMS)
for ease of demonstrating the concept.
The CoMS is developed in the Microsoft Access environment.
There are six (6) interfaces available in the CoMS which follow the
framework developed earlier (Fig. 1). The interfaces are for Man-
aging Contractors, Application, Pre-Contract Screening, Site Safety
Plan Checklist, Work Monitoring and Evaluation and Accident/
Incident Report. Each interface has different objectives and provide
information for any company to conduct gap analysis to determine
how close the system complies with OSHA PSM requirements.
Establishment of the system will assist regulatory compliance and
ease the auditing process.
3. Proof of concept
Real process plant data is use to validate the concept. However,
issues like data confidentiality, technical support, implementation
of recommendations, management bureaucracy, cost and time has
restricted the implementation in a real industry. As an alternative,
proof of the concept has been carried out using pilot plant data.
Pilot and real process plant has many similarities in nature such as
chemical reaction hazards, safe operating procedures and effect of
expected variations in process conditions (West, 1999).
N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90 85

Fig. 1. Contractor management framework based on CFR 1910.119(h).

86 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90
4. Case study
To validate the implementation of managing contractors using
Contractor Management System (CoMS), a case study has been
conducted using High Gravitational Natural Gas Pilot Plant
(HGNGPP) at Universiti Teknologi PETRONAS (UTP). The pilot plant
is use to study the performance of an in-line rotary separator to
remove water vapor from the natural-gas stream at 2e5 MMscfd
for pressure of up to 80 bars. A contractor is needed for the job to
replace a corroded section of the separation columns that contain
absorbents. Since the pilot plant is handling flammable gas at high
pressure condition, the university made it compulsory that proper
contracted workers are employed for the job. The research team
used CoMS that follows the contractor management of PSM stan-
dard to manage the contracted work.
Referring to the concept illustrated in Sections 2.1 and 2.2, the
P&ID is divided into several nodes according to its design intention.
Fig. 3 shows the selected nodes for this case study which consists of
inlet and outlet streams of Compressor V470. Natural gas is sup-
plied from a series of gas bottles to the HGNGPP at a desired
pressure using Compressor V470. The temperature of the exit
stream from the compressor is controlled by air blower V480. The
compilation of the information related to the implementation of
contractor management is guided by the main interface of CoMS. If
the information is not available, the project leader is required to
take necessary actions for the establishment of the contractor
management program of PSM.
A. Managing contractors CFR 1910.119(h)
Fig. 4 shows the ‘Managing Contractors’ interface that consists of
‘Sub-standard’, 'Description', 'Complete', 'Incomplete' and 'Re-
marks' columns. This main interface is use to assess and monitor all
sub-standards of CFR 1910.119(h) to detect non-compliance. The
‘Remarks’ column is to state any comments such as specific
incomplete information or conditions of the Sub-standard. From
the case study, two sub-standards of the contractor management
are incomplete which is work monitoring and accident/incident
reporting.
B. Application CFR 1910.119(h)(1)
Fig. 5 shows the sub-standard of CFR 1910.119(h) which is the
‘Application’. This part applies to contractors performing work on,
around or adjacent to certain parts of a plant that carry out pro-
cesses involving highly hazardous chemicals. The interface is
important in order to maintain the list of contractors who worked
onsite in the vicinity of the covered process, to define the job of
contractor and other related information pertaining to the con-
tractors. Thus, the interface stores all relevant information of the
contractors especially the job location and description, contract
start and end date, list of workers involve and details of the person
in-charge.
C. Pre-contract screening CFR 1910.119(h)(2)(i)
The first requirement in the contractors' provision of PSM is for
the employer to conduct preliminary check on the contractors for
the type of work that they will perform. OSHA PSM emphasize on
evaluating the safety performance and the contents of the safety
programs of the prospective contractors. The two performance
measurements most commonly used are the OSHA Total Incident
Rate (TIR) and the Experience Modification Rate (EMR) (Center for
Chemical Process Safety (CCPS) AIChE, 2011). These two measure-
ments are usually calculated by the employer's insurance company
to determine workers' compensation insurance rates. Other docu-
mentation that the employer should look into when selecting a
contractor is the logbook such as OSHA-300 Log for contractors in
the U.S. The OSHA requires that most employers keep a 300 Log that
keeps all work-related injuries and illnesses at the company's
jobsite.
In addition, the employer must evaluate to ascertain that the
contractor has appropriate job skills, knowledge and experience.
Information such as whether the contractor is familiar with other
related processes can be obtained by requesting for the contractor's
relevant certificates and curriculum vitae. Documented evidence
showing compliance with confined space entry, lockout/tagout,
emergency response and safe work practices should also be
considered by the employer. The contractor should be capable of
demonstrating a track record and commitment to being on time,
working safely and at a fair price (Early, 1996).
Thus, the ‘Pre-Screening’ interface (Fig. 6) records the assess-
ment conducted on the prospective contractors. The ‘Evaluation
Description’ is the part where the user or employer state the doc-
ument(s) of evaluation for example Safety Program Evaluation,
Total Incident Rate, Experience Modification Rate and other eval-
uation factors deemed necessary by the employer. The evaluation
document(s) is customized by the employer stating the criteria that
need to be evaluated for the purpose of selecting the proper con-
tractors. An authorized personnel of the project owner must check
whether the documentations submitted are complete. The ‘Evi-
dence Location’ tab is to monitor and track the documents. The
documents are to be evaluated by the authorized personnel qual-
itatively and the said personnel must ascertain whether the score is
within the acceptable limit. The employer should state the accep-
tance standard of each of the evaluation criteria conducted on the
contractors. Then, the status of the contractor will be justified
either qualified or not qualified for the job. Comments have to be
filled in the ‘Remarks’ column and the action taken after being
evaluated is to be stated in the ‘Action’ column.
D. Site safety plan checklist CFR 1910.119(h)(2)(iieiv)
The safety and health of the plant workplace starts once the
employer knows the job that needs to be carried out. It can be
accomplished by first carrying out a risk assessment to identify the
hazards and then evaluating it. After that, the employer needs to
decide on the necessary precautions. Moreover, a proper emer-
gency response plan must be put in place. The risk assessment
analysis needs to be communicated to the selected contractors.
Thus, this interface (Fig. 7) stresses on the requirements that need
to be communicated to the contractors once the contractors are
selected but prior to the commencement of the contracted job.
The ‘Job Description’ column states the contract work to be
completed while the ‘Risk Assessment’ column checks whether a
complete risk assessment has been conducted for the work. An
‘Evidence Location’ of the risk assessment should be stated and the
risk assessment document must contain all the relevant informa-
tion concerning the possible accidents that could occur. Besides, the
document has to include the risk and hazards mitigation steps. In
addition, the interface contains an outline of the briefing conducted
by the employer in order to ensure that contractors understand the
site safety rules and hazards. The requirement column states the
information that the employer need to convey to the contractors.
For example: company policy, facility safety rules, emergency
response plan, safety and health controls, environmental protection
and other essential information. The other relevant information to
be added to the interface includes methods of delivery i.e. face to
face, computer based training, or other appropriate means, date,
evidence location (attendance and date) and trainer information.
 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90 87

Fig. 2. P&ID framework for contractors' management.

E. Work monitoring and evaluation CFR 1910.119(h)(2)(v) closely monitor the contractors' work at reasonable intervals
depending on the hazards and risks associated with the job. For
Contractors are responsible for ensuring the work is done at a example, a high risk job where a permit to work is used, more
reasonable level of safety. However, plant personnel should also contact and monitoring is needed as compared to jobs which are
88 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90

Fig. 3. Part of overall P&ID diagram showing the compression system for HGNGPP.

Fig. 4. Managing contractors CFR 1910.119(h).

Fig. 5. Application CFR 1910.119(h)(1).

Fig. 6. Pre-contract screening CFR 1910.119(h)(2)(i).

considered to have low risks. Monitoring contractors' work allows
the employer to assess the job that has been carried out in addition
to making sure that the job is being done according to plan. The
work monitoring interface (Fig. 8) aims to provide details of the
monitoring that has been performed on the contractors. It is to
ensure that the plant authorized personnel periodically evaluate
the performance of the contractor in fulfilling their responsibilities
under the contractor management requirements of the PSM stan-
dard CFR 1910.119(h)(3)(iev) (Fig. 1). Thus, the interface contains
columns for evaluation date, next reevaluation date, action taken
 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90 89

Fig. 7. Site safety plan checklist CFR 1910.119(h)(2)(iieiv).

Fig. 8. Work monitoring and evaluation CFR 1910.119(h)(2)(v).

Fig. 9. Accident/incident reporting CFR 1910.119(h)(2)(vi).

and remarks. The plant personnel needs to indicate Yes or No to 5. Conclusion

indicate whether the contractors are performing their jobs as
prescribed by the sub-standard while the description column in-
dicates documents which need to be referred to and the location of
the documents. After checking the requirements, the plant
personnel should indicate the corrective actions to be taken and set
the next date for reevaluation to check whether the gaps have been
closed or otherwise.
F. Accident/incident reporting CFR 1910.119(h)(2)(vi)
Regulations and standards require that incidents be reported,
investigated and analyzed to determine corrective actions and
prevent recurrence. Thus, all incidents and close calls no matter
how small it is, should be reported and brought to the attention of
the worksite supervisor so that he can determine the risk potential
and submit reports as required. The ‘Accident/Incident Reporting'
interface (Fig. 9) records each contractors' injury and illness logs
during the work performed at the plant. It can be in the form of
OSHA 300 log that is used in the U.S. or any separate recording
format developed by the plant/facility. The plant personnel should
address the description of the log and the evidence location. The
remark column is use to indicate any comment such as accidents/
incidents involved death or permanent disability, days away from
work, job transfer or restriction which are useful information for
future selection of contractors.
This project proposes a systematic approach to assist plant
personnel to develop, implement and comply with the OSHA PSM
CFR 1910.119(h) contractor elements besides realizing and closing
any missing gaps on the existing contractor program that the
process plant has implemented. The first and most important
objective of this study is to develop a framework for contractor
management. The second objective is to develop a database pro-
totype tool with the purpose of using it to assist end-users to easily
track information and documents, determine gaps and provide
quick solutions in a structured manner according to PSM contrac-
tor's requirements as captured in the Remarks column of every
CoMS interface. Finally, the proposed system of CoMS is user-
friendly, practical and has the potential to be commercialized for
use in any process industry.
References
Abdul Aziz, H., Mohd Shariff, A., Roslan, M.R., 2011a. Application of Process Hazards
Management in Lab-scale Pilot Plant.
Abdul Aziz, H., Mohd Shariff, A., Roslan, M.R., 2011b. Managing Process Hazards in
Lab-scale Pilot Plant for Safe Operation.
Aziz, H.A., Shariff, A.M., Roslan, M.R., 2012. Managing process hazards in lab-scale
pilot plant for safe operation. Am. J. Eng. Appl. Sci. 5 (1), 84e88.
Aziz, H., Shariff, A., Rusli, R., 2013. Managing Process Chemicals Information for Pilot
Plant Based on Process Safety Management Standard.
Aziz, H.A., Shariff, A., Muhamad, M., 2014a. Development of process safety man-
agement system (PSMS): mechanical integrity (MI). Appl. Mech. Mater. 625,
90 N.D. Abdul Majid et al. / Journal of Loss Prevention in the Process Industries 37 (2015) 82e90
486e489.
Aziz, H.A., Shariff, A.M., Rusli, R., Yew, K.H., 2014b. Managing process chemicals,
technology and equipment information for pilot plant based on process safety
management standard. Process Saf. Environ. Prot. 92 (5), 423e429.
Aziz, H.A., Shariff, A.M., Rusli, R., 2014c. Managing process safety information based
on process safety management requirements. Process Saf. Prog. 33 (1), 41e48.
Brackey, A.C., 2013. Process safety management: 21 years plus or minus: what i
wish i'd known then and what we can't afford to forget now! Process Saf. Prog.
32 (3), 260e263.
Center for Chemical Process Safety (CCPS) AIChE, 2007. Guidelines for Risk Based
Process Safety. John Wiley & Sons Inc., Hoboken, New Jersey.
Center for Chemical Process Safety (CCPS) AIChE, 2011. Guidelines for Auditing
Process Safety Management Systems, second ed. John Wiley & Sons, New York.
Cui, L., Shu, Y., Wang, Z., Zhao, J., Qiu, T., Sun, W., et al., 2012. HASILT: an intelligent
software platform for HAZOP, LOPA, SRS and SIL verification. Reliab. Eng. Syst.
Saf. 108, 56e64.
Cunio, C., Melhem, G., 2014. A guide to the legal framework of the PSM standard for
engineers. Process Saf. Prog. 33 (2), 152e155.
Darvish, M., Yasaei, M., Saeedi, A., 2009. Application of the graph theory and matrix
methods to contractor ranking. Int. J. Proj. Manag. 27 (6), 610e619.
Early I, William F., 1996. Contractor and Client Relations to Assure Process Safety.
American Institute of Chemical Engineers, New York.
Early, W.F., 2006. Database management systems for process safety. J. Hazard.
Mater. 130 (1e2), 53e57.
El-Sawalhi, N., Eaton, D., Rustom, R., 2007. Contractor pre-qualification model:
state-of-the-art. Int. J. Proj. Manag. 25 (5), 465e474.
Haesle, J., Devlin, C., Mccavit, J.L., 2009. Improving process safety by addressing the
View publication stats
human element. Process Saf. Prog. 28 (4), 325e330.
Hanchey, K., Thompson, J.R., 2011. The challenge to implement and maintain an
effective PSM program. Process Saf. Prog. 30 (4), 319e322.
Klein, J.A., 2005. Operational discipline in the workplace. Process Saf. Prog. 24 (4),
228e235.
Kwon, H., 2006. The effectiveness of process safety management (PSM) regulation
for chemical industry in Korea. J. Loss Prev. Process Ind. 19 (1), 13e16.
Louvar, J.F., 2008. Improving the effectiveness of process safety management in
small companies. Process Saf. Prog. 27 (4), 280e283.
Louvar, J., 2010. Guidance for safety performance indicators. Process Saf. Prog. 29
(4), 387e388.
Luo, H., 2010. The effectiveness of U.S. OSHA process safety management inspection
e a preliminary quantitative evaluation. J. Loss Prev. Process Ind. 23 (3),
455e461.
Mark McGuire, Moran, 1996. OSHA's Process Safety Management Standard: a
Proven Written Program for Compliance. Government Institutes, United States
of America.
Rashid, M.I., Ramzan, N., Iqbal, T., Yasin, S., Yousaf, S., 2013. Implementation issues
of PSM in a fertilizer plant: an operations engineer's point of view. Process Saf.
Prog. 32 (1), 59e65.
Vaughen, B.K., Kletz, T.A., 2012. Continuing our process safety management journey.
Process Saf. Prog. 31 (4), 337e342.
Wee, Morris Kho Kee, Jabar, Busari, 2008. Strengthening process safety re-
quirements in HSE management system e an NOC's experience. In: 10th Pro-
cess Plant Safety Symposium e Jointly Co-sponsored with ACS, p. 45.
West, A.S., 1999. Plant process safety starts in the laboratory. Chem. Health Saf. 6
(2), 15e17.