¶ Welcome and Introduction
Welcome back everybody . Safe , efficient , profitable . Today we are going to be talking about trying to break down some of the silos within your PSM programs , your engineering and maintenance teams , and safety here we go .
All right , welcome back . Welcome back everybody . Am I running this or are you running this one ?
I'm running this one . Ah , I'm running this . I'm a PSM
¶ SOP Challenges and Review Issues
person . There we go , here we go , so the first thing that we're going to talk about is our SOPs .
Standard operating procedures .
So standard operating procedures . A lot of times we have these documents and they're called SOPs and they may be any version of third-party Rotem . Internal Rotem .
We got them from a we contracted that out , so we're good .
Yeah , somebody else Rotem third-party , Some kind of combination of my old plant and I brought it over and I kind of updated it . But now I left and went somewhere else .
So you're saying there could be a whole bunch of variables there could be hodgepodge . Yeah , there we go .
I mean , they may even be different formats than the same location . Like they , some parts of the system may have one template , others have a different format and I'll often just review these so that's the deal . We're supposed to theoretically review these annually .
However , one of the biggest gaps that I have seen in the last several years is that the folks who are reviewing them same folks every year and , generally speaking , I don't know that there's a lot of good documented training on what we're reviewing them for .
That's a good point , and most of the time , the individuals that are reviewing them are on the engineering b&e . You know refrigeration side .
I'm safety . Am I doing this part of it ?
And they're not the experts . So when we talk about reviewing SOPs . It may be correct for the engineering side . They've got nothing to do with any of our safety programs at all .
But what if you have lockout , tagout ?
Well , what if you've got weather ? What if you've got lockout ? What if you've got elevated ?
What if you've ?
got a whole lot of things going on .
Okay , now I understand .
A lot of times our SAPs are written for perfect weather , nothing's going wrong . We have an emergency section , but it only
¶ Safety Expertise in Procedures
gives us one set of scenarios , right , and it always works . Yeah , anytime I talk to my operators , I'm like , well , here's the leak , what are we going to do ? And they're like , you know , well , got this SOP . And I'm like , so , does this SOP address this specific leak ? And got this SOP . And I'm like , so , does this SOP address this specific leak ?
And there's all kinds of discussion and a teetered debate and what really boils down to is that common is I can't write emergency shutdown or emergency stop for every single leak that there ever could be , and the ones that are listed may not work for everything that could . That's associated with that unit that you'd pull that SOP to .
So what should you do ? What should you do if you figure that out ?
so that's when we start evaluating . Maybe we need to broaden the scope of what we're right . Maybe we have more than one emergency shutdown . Maybe we start writing additional plans , free plan . Maybe we start having alternates written in there .
And then the other piece of it is is that you know , and engineering , maintenance , refrigeration operators , they're not safety experts . We're employing a safety expert at the facility because that's their lane and I mean I don't have to have psm knowledge be safety and right .
We've got to pull them in , so they have to be a stakeholder in the sop review and discussion in terms of things even like definitive maintenance right and some of those last procedures that we
¶ Building Cross-Department Communication
do Well .
do you want my lockout in your SOP ?
So that's the next piece , right . So other gap is that we're going to start seeing things in some of these templates that reference some stuff like for lockout procedures refer to . Now , sometimes I've seen the full on lockout in there . I would never advise against that . That's me , my opinion . I would just not write your lockout procedure within your sop .
But we'll start seeing things like refer to lockout procedure , refer to the ppe assessment , refer to and who wrote the lockout procedure , and half the time , I'd say actually more than half the time , don't have that , or I wrote it as a safety person , but I don't have the psm background or utilities wrote it as a safety person but I don't have the PSM
background or utilities wrote it and they don't have the safety background .
So either way , the document could have significant gaps . Is what I want you to know . Ppe assessment for my refrigeration folks If it doesn't cover the entire scope of what they could be doing , it likely could have gaps if I didn't have engineering and safety in the room having a discussion . Same goes for my task procedures .
If we didn't do a task evaluation or pre-job hazard analysis or whatever you want to call it , when we're talking about the hazards associated with that task and writing out that task procedure , safety wasn't involved , or if safety wrote it without refrigeration involved , we're going to see gaps , and so that's what we're really kind of seeing is that we've got to
start getting those two groups in a row , almost like building a community .
We got to be friends , we got to get in together and we've got to review these documents as one , because we're both stakeholders in the same document because , we've got to make sure the PPE assessment dovetails with the confined space assessment , dovetails with the lock procedure , dovetails with our SOP and our task procedures , and that they all say the nice same
happy thing right .
Absolutely , because most of the time they're all saying something different , because if you're , if you're process or procedure says one thing , mine says the other . How do we train ?
Well , that's really what it boils down to is that I'm going to be training folks on task procedures and SOPs If there's no safety considerations in them , how can I mean ?
I'm giving them some kind of general awareness , monthly safety training , but in terms of for them to really know how to safely do their job because there is a lot of gray area we're just kind of expecting them to figure it out and freelance , and that's why we're seeing injuries . In my opinion , we have to tell them because they're new .
How are ?
they going to know ? They don't know what they don't know .
That's right . So you're talking about you may have to change a little onboarding . You may have to change a little bit of procedures .
You
¶ Best Solutions and Training Needs
need to change about who's actually reviewing it , what kind of training they have yeah , the reviewer needs to have some training on what they're reviewing it for and we've got to pull safety .
And I know that they feel overwhelmed and they may not want it and they say this is not my problem , but in order they're the expert for that subject but , yeah , they the subject matter expert , and so they may not be able to advise on whether that's the correct shutdown in terms of the refrigeration technical piece .
But when you have a discussion about here's the risk that I'm being exposed to or you talk through the steps you have to do . They should be able to identify Well , here's where you're going to be standing . Oh , we need to fall protection . How are you going ?
to tie off to Well , here's where you're going to be standing .
Oh , we need to fall protection .
How are you going to tie off to ? Well , you need this people because that's safety stuff , but it's not going to be an SOP .
Right .
Nowhere in the SOP is say use the ladder and tie off air .
So I think what it all really boils down to at the end of the day is and y'all have been saying this for a long time but poor refrigeration and maintenance and B and E sometimes they get forgotten about a little bit because of most of our programs are really great about being perfect or production , but because there's so much dynamic changes and different jobs
that we're doing on the refrigeration and the engineering maintenance side , we don't always capture that real good and then , like , those documents don't , don't have anything in them , our programs don't really align with what they're doing , what their procedures say , and now we're just opening ourselves up to a lot of risk of people getting hurt as well as the
citation .
So I have engineering degree and experience , fought leaks , dealt with amputations , all these things . You know what Wouldn't know anything about any of the stuff you said unless I job shadowed them like I did . Yeah , one of the things I did when I became a safety person . I didn't know , so I would just go on project day and I'd watch what they did .
I didn't get paid extra for that , I just went because I was like if I'm gonna be part of this and be responsible for it , gotta understand . I understand I watched him do round .
I still do that today , so so solutions right . So , solutions we talk about . I think training is is the biggest thing , right ? So safety can't really identify the hazards if they don't know what recreation and maintenance and boiler and utilities and all that for that matter , is actually doing .
So one thing is absolutely I'm a proponent of safety people getting refrigeration training . I think that it's very helpful to understand physically what's going on with the system . But the second piece is absolutely job shadow . Job shadow on weekends , job shadow .
Absolutely .
Overhauls on the system , when they're doing pump downs , when they're doing startups , when they're doing line breaks , when they're just doing their rounds , when they're just doing their rounds , when they're changing check-in valves , phas , let's get involved for PHAs .
You know , I realized the other day if we've got people who have only been at the facility for a year or so safety engineering , my operators maybe none of them were there for the last mechanical integrity , or the last snowstorm or the last crazy event ?
Yeah , they may never . They may not know that they oh , that's fine , like no , there was everybody may have turned over , so no , that's right . The history at some of these locations that this actually happened so sometimes would you pull a another location to help you with some of those processes I absolutely would so .
If there is that's , that's another option . So solutions is shadow . Who's there ? Yeah if you find that you've got a greener team and they are a little bit newer , then yeah , absolutely .
Start pulling in people from district locations that maybe do have a little bit more tenure , or maybe we're on some of the calls when they heard about some of this stuff going on at your location .
That's how we get on . Some of the calls is to help almost be we're historian .
Absolutely . You know , look at maybe getting some refrigeration training . Joe and I obviously we do some get up to speed type training stuff with our safety and psm teams . I always want to make a point that , just because you have someone managing documents right , we're a document manager .
We make sure that certain checks and balances which is about it is in place and it is needed .
We've got to make sure but that's two different , different thought patterns we've got the compliance side and , yes , we have the document .
But that person may not be the technical expert and they may not be able to really sign off and say it's correct . They can just say that we have it , but they don't know if it's hold on .
What if we're dealing with RMP ?
Okay , so that's a good one .
Will we get environmental involved ?
Yeah , environmental is absolutely going to potentially be a stakeholder .
Okay , especially like a PHA . Worst case scenario .
Yep , we want to evaluate our PHA , get ready for worst case scenario . That may mean that we are starting to update our RMPs .
I will tell you that's a big one , that we're seeing a lot of people maybe re-evaluate what their RMP says . We're going to do an episode later on that , but yes absolutely so they're really kind of taking a look at .
So maybe training that we had for safety maybe it needs to be a little bit heavier in PSN so that they understand . Because , again , safety has got to sign off on documents . That goes back to the signing Absolutely who can sign what and are we really qualified ?
¶ Closing and Additional Resources
So I think the biggest thing is we've got to sit down in the same room , we've got to really have those joint conversations together and then a lot of job shadowing is really helpful so that we understand the utilities and refrigeration side the same way that we understand .
Can't regulate it if you don't understand it .
Yeah , it's really really hard to identify the hazards and prevent the injury if we don't understand what's going on .
Absolutely . These are our opinions .
If you want some support in person , like I said , we do PSM mini audits , some compliance audits from the PSM side , Do some training with safety for understanding the PSM system and all that Helen-safetycom you can check us out over there for in-person things . Otherwise , you can find us on LinkedIn .
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