Is Your Process Safety Documentation Adequate?

Don't wait for a safety audit or OSHA inspection to find out.

By Brian J. Kingsley and David E. Kaelin, Sr., Chilworth Global

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Process documentation and other process safety information (PSI) play a key role in process safety management (PSM). Nearly every governing authority, including the US Occupational Safety and Health Administration (OSHA), and the National Fire Protection Association, as well as insurance providers require process safety documentation.

While requirements differ slightly among industries, the key documents common to most include:
• process description;
• process flow diagram;
• piping and instrumentation drawing (P&ID);
• electrical area classification drawing;
• process hazard analysis (PHA);
• material safety data sheets (MSDS);
• design basis for emergency systems and devices;
• startup/shutdown operating procedures;
• normal operating procedures;
• emergency procedures;
• management-of-change procedure; and
• maintenance records.
Supporting documents may include:
• material and energy balance;
• process chemistry;
• materials of construction;
• equipment arrangement;
• plot plant;
• ventilation design;
• emergency planning;
• upper and lower control limits;
• consequence of process deviation; and
• accident/incident investigation reports.

Additionally, a site should carefully maintain — and periodically update or revalidate — documents pertaining to life safety and building structural design.

Of course, the challenge is ensuring the information you have is adequate and remains that way. So, in this article we'll discuss how to assess and address process documentation.

You should start with the fundamentals. Firstly, senior management should prepare a safety mission statement and safety policy that commits them to the safety of employees and their work environment. Secondly, form a safety committee to manage the diverse aspects of overseeing collection of data and the creation of required documentation. Members should include representatives from management; health, safety and environmental; engineering; maintenance; manufacturing; quality control; and any other departments important to your processes. Thirdly, the safety committee should create a "basis of safety" document as a roadmap for your approach to the design and management of the safety system, ensuring your operations meet the intent of your company's safety policy.

The best approach for any large undertaking is to segment it into manageable pieces. The safety committee should delegate individual document ownership to appropriate departments. When resources are limited, outsourcing the technical drawings to a local engineering firm is a common approach. However, you must start the process internally because no one knows your operation better than your own people. Prepare a list of documents currently available, even if they're old or outdated. Perform a gap analysis to define which documents are missing.

If the resources for document preparation (in terms of time or cost) are a factor, select a smaller "boutique" engineering firm that can perform the work part time at a reduced cost. Alternatively, consider contacting a local university about participating in a cooperative program for third- and fourth-year engineering students. Ensure the students are well supervised to make the most of their four to six months with you.

Once you've got current versions of all the documents needed, store them in a centralized secure location where they are accessible to those who need them. Many companies maintain their documents electronically with date stamps and expiration notices to ensure only the latest information is utilized. The requirement for "as built" documentation is time critical not only for process troubleshooting but also for process hazard assessment, management of change, and capital project implementation. Managers and engineers can spend hours looking for missing documents and, unfortunately, sometimes inadvertently use outdated documents, leading to lost time and potential rework. The role of a document control coordinator is much underappreciated and often is critical to minimizing mistakes and lost efficiencies.

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