The term OSHA 29CFR, 1910.119 can provoke angst in maintenance planners at chemical plants and other industrial facilities. Maintenance planning is quite detailed in any such facility — but those sites subject to this process safety management (PSM) statute must contend with significantly increased complexity of planning. Following the spirit and letter of the statute are extremely important for two primary reasons: keeping plant personnel safe and avoiding potential government fines. Although on the surface these seem like separate issues, connections exist between personnel safety and potential fines.
While the PSM portion of the regulations of the U.S. Occupational Safety and Health Administration (OSHA) is far reaching, one part affects the maintenance planner more than the rest. That person has the important task of screening the incoming requested work for key words such as “change,” “modify,” “add” or “delete.” In addition, the planner must pay special attention to the repair or replacement of equipment to preclude a mistake that could cause a safety, environmental or equipment issue. This is crucial for ensuring the safety of technicians, protecting the environment, and avoiding collateral damage to equipment; miscues in these areas can cost a company dearly. Doing everything I can as a maintenance planner to give the technician all the tools necessary to complete a job safely is something I always will be most proud of in my career.
Very few facilities I have worked in and around as a work management subject matter expert fall under the OSHA PSM statute. Most of them don’t do a particularly great job of managing changes within their plants. At plants that must comply with this statute, OSHA is very clear in the requirements for management of change (MOC). It’s simple and complex at the same time. The simple part is that any change not made “in kind” requires initiation of a MOC process. The complex part is determining exactly what “in kind” means. For example, some may consider that replacing a 3-in. 300-psi ball valve used for level control with another 3-in. 300-psi ball valve qualifies as a replacement in kind. However, if the valves’ Cv (flow coefficient), control mechanism or other factors don’t match, that may not be so.
I was fortunate to work for a long time in a facility that took this statute very seriously; it produced chlorine, phosgene, acids and caustic. The plant required process engineers to examine even a set point alteration on a vessel level or process flow change to determine the upstream and downstream effects and any unintended consequences of those changes on the process.
Working in a chemical plant that produced lethal material caused a paradigm shift in my thinking, making me very risk averse. So now, no matter where I go, I view processes through my OSHA 1910.119 eyes. Every site, whether or not subject to the OSHA statute, can benefit from the lessons learned from working in that environment. The maintenance planner should ask the same questions. Verifying drawings are correct, ensuring equipment is replaced “in kind,” and confirming the computerized maintenance management system (CMMS) captures the correct history will make your workplace a bit safer every day.
So, you’re a planner in a PSM-covered facility. How does the statute affect what you must do? Let’s walk through a typical process for planning a maintenance job.
1. What jobs should you plan? The simple answer is that all maintenance jobs can benefit from some level of planning. Replacing a reactor vessel obviously requires a much more detailed job plan than, say, swapping a manual discharge valve on a pump. However, you must look at both these jobs through your PSM glasses to ensure that things like material of construction, specifications, size, etc., are considered before any work takes place. Even something as simple as replacing a light bulb deserves some rudimentary planning: you should verify a bulb of the right wattage and base size is specified and available, and arrange for a ladder or stool, if necessary.
2. Is it really necessary to visit every job prior to planning? It is well known as a best practice to go to every site of a planned job before putting together the job plan. Visiting the job site allows you, as a planner, to see for yourself what the job entails. Putting eyes on the job can answer many questions that can’t get answered otherwise. On one occasion, while coaching a planner at a refinery, I was working with him on a particular job of replacing catalyst in a reactor tower. It was a very complicated job. During the process, I told him we needed to climb to the top to verify the flange sizes and fastener sizes and types. He argued the equipment drawings contained all this information. I replied that experience shows drawings don’t always reflect field changes during construction. So, we climbed the 80 feet to the top. The flanges were exactly like the drawing — but the fasteners weren’t. A couple of Class-150 flanges somehow got heavy hex fasteners that didn’t agree with the drawing. If we hadn’t looked at the job, the craftspersons would have made the same climb with the wrong-sized tools, a waste of their time. Fortunately, we did the right thing and took the next steps for a situation like this: checking the specifications, allowing for the correct size fasteners, and ensuring the drawing is updated if needed. An engineering review may be necessary as well.
3. What “tools” does a planner need? I put tools in quotation marks because some facilities I visit have a collective bargaining agreement that precludes the planner or supervisor from turning wrenches (using tools). Such facilities sometimes require different arrangements to ensure compliance with the collective bargaining agreement. This might include assigning a tradesperson to accompany the planner in case removing a guard or inspection plate is necessary to properly plan the job. Regardless, a planner should have some very basic supplies for correctly creating a job plan.
• Digital camera. A picture is worth 1,000 words. So, take a good digital camera with a flash and zoom. An intrinsically safe (explosion-proof) camera might be necessary in some cases; this could be expensive — but is a necessary tool.
• Digital voice recorder. My single most important tool in planning jobs is a digital voice recorder. Wet weather doesn’t mean we plan jobs from our desks. Taking a paper pad or job-planning template into the rain may be a bad idea but the voice recorder will work there. Using the recorder to capture important details about the job absolutely will make your job easier. It will free up your hands to carry rags to wipe off displays or grease from data plates. Listening to the recording back in the office can remind you to check certain aspects of the job that you might skip on paper. Of course, you’ll need an intrinsically safe recorder in explosive areas.
• Micrometer. Digital or analog, a micrometer is an important tool to measure flange thicknesses, fastener sizes and many other items that a tape measure can’t measure accurately.
• Long tape measure. Pipe typically comes in 20-ft random lengths, so take at least a 25-ft measure.
• Magnet. You can use this to determine if the material of construction is ferrous or not. Of course, it won’t differentiate among aluminum, titanium or stainless steel — but can help you get on the right track. If the metal is painted, you can’t tell what it is but the magnet sees through the paint.
• Flashlight and miner’s light. You have to be able to see what the job is to plan it correctly.
• Telescoping mirror. This is essential for looking under and around places you can’t see otherwise.
Many other tools may help you improve your ability to plan jobs correctly. I used to carry paint remover, a screwdriver and a wire brush because painters invariably cover the data plates on pumps. Remember to write a notification for the painters to replace what you removed, especially if the environment is corrosive.
4. What am I looking for? As a planner in a PSM-covered facility, you’re the first line of defense in recognizing when a MOC process should be initiated. Experience should make you adept at knowing what to examine and why. As I mentioned earlier, notifications with words like change, delete, modify, install, etc., should raise an alarm for you to look at the job particularly closely. Even a job request that says “replace valve” should remind you that “replace” implicitly means “in kind.” Use resources like manufacturers’ websites, your local engineering department, drawings (as long as they’re current) and, of course, your work order history and preplanned work order library.
5. So, is that it? Absolutely not. The practical tips listed here aren’t a substitute for experience and training. Veteran planners at a facility should impart knowledge to less-seasoned staff. Having the entire planning staff located in the same area or office can expedite information exchange. However, I’d be remiss not to note that an experienced planner doesn’t necessarily follow best practices. So, it’s essential that the planners are trained in a proven program and held accountable to best management practices.
Fines And Other Punishment
During my maintenance planning career, I have had the unfortunate task of dealing with the repercussions of injuries and even a fatality. Generally speaking, if investigators come to your site, they will interview the maintenance planner. As the “super user” of the CMMS, the planner will be asked to pull data from the system so the investigators accurately can determine the cause of the incident. Some things such as paperwork errors or clerical mistakes can incur small fines or none at all but can lead to action items to make corrections. Something more serious such as willfully hiding or otherwise withholding information can prompt larger fines. More and more often, those responsible face jail time.
In a perfect world, fear of fines and jail time shouldn’t be the motivation for “doing the right thing.” Instead, being risk averse and correcting these problems by careful examination should preclude “the interview” from a regulator. As a maintenance planner, I always have considered the most important aspect of my job to be the safety of those technicians that I planned for and worked with every day.
ROGER CORLEY is a work management and materials management subject matter expert at Life Cycle Engineering, Charleston, SC. Email him at [email protected].