“We did not choose to be the guardians of the gate, but there is no one else.” – Lyndon B. Johnson
In LOPA, the role of people can be broken down into three categories: Victims, villains, and heroes. Access control serves not only to reduce the number of victims but also restrict access for villains. Individuals, employees or otherwise, should not wander around a covered process without first informing operators.
The requirement in the OSHA Process Safety Management Standard states,
1910.119(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
1910.119(h)(2)(iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas.
The phrase “such as” may suggest that access control procedures are optional, and instead just offered as an example. However, a history of citations targeting missing access control procedures would suggest otherwise. The requirement for contractors is “shall,” making it clear that it is an expectation.
It is important that those operating a PSM-covered process are aware of the current activities in the facility. This does not only include activities that may directly affect the process. Operators should know about any maintenance or sampling going on in the covered process, as well as any other activities by maintenance, contractors, laboratory, or other support personnel (other support personnel may include management and engineers). This is required by the PSM Standard.
In the event of a major incident at the facility, all personnel need to be accounted for. The safe work practice required by the PSM Standard to control the entrance of employees to facilities could be used to supplement OSHAs requirement for Emergency Planning and Response.
There should always be communication between operating personnel and workers performing work within the process area. Hazards and tasks for the work being performed should be conveyed to those performing the tasks and operating personnel in accordance with established procedures. OSHA requires the employer’s entrance procedure cover all the standards listed personnel.
While the entrance procedure is what is required by OSHA, all personnel should be required to either sign into an area using a logbook system and/or be covered under a work permitting system.
Many facilities have a logbook system. Maintenance, contractor, laboratory, or other support personnel are required to sign in to the unit at the control room before entering the covered process. The sign in will include the time in/out and their reason for being in the area.
Work permit/authorization system
Contractors often perform very specialized and potentially hazardous tasks and it is important that their tasks be controlled while working in a covered process. A permit system or work authorization system keeps an employer and all affected employees informed of contract employee activities. The employer will also have more control over the work being performed in the process area. Work permits should be considered specifically for potentially hazardous tasks such as confined space entry activities and nonroutine repair activities.
Work permit and work authorization systems are beneficial for everyone that is working in the facility not just contract employees.
OSHA expects facilities with a PSM covered process to develop and implement safe work practices to control the entrance into the covered area for maintenance, contractor, laboratory, and other support personnel. Without specific direction in the standard, there are multiple means in which to meet the standard. A straightforward method is to require that employees verbally notify the lead operator of their reason to enter the covered process and sign an entrance log located in the control room prior to entering the covered area.
If management and engineers walk into the plant without signing the logbook, filling out a work permit, and/or following other procedures, your safe work practices won’t work. Everyone needs to be trained and on board with the system, otherwise what was the point in creating it?
Safe work practices for entrance into PSM-covered facilities is essential. A well maintained, well run process where an employee’s safety is fully recognized will benefit everyone at the facility. Make sure your safe work practices are adequately developed, have been communicated to employees, your employees have been trained on them, and that they have been implemented. Are you in compliance with the standard?