pillai_sreejith@hotmail .com Safety Audit Tips, Observations & Recommendations India P.G. Sreejith Part 1
Safety Audit Observations & Recommmendations
Nov 12, 2014
This presentation on safety audits was prepared based on author's experience in HSE audits. This presentation will be useful for safety auditors.
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Pre -Safety Audit Guidance
• Send the data request (records, reports that you want the client to keep ready for auditing) and audit plan in advance to client
• Prepare checkpoints based on specific hazards of the industry that you are planning to audit
• Collect all possible accident information for the particular plant and industry
Pre -Safety Audit Guidance
• Send the data request (records, reports that you want the client to keep ready for auditing) and audit plan in advance to client
• Prepare checkpoints based on specific hazards of the industry that you are planning to audit
• Collect all possible accident information for the particular plant and industry
Safety Audit Guidance
• Plan the audit (based on defined scope and coverage) and to the extent possible to stick to the plan
• Do a thorough audit, inspect all areas, equipment
• Meet and discuss with maximum number of operators / technicians
• Ask specific, relevant questions
Be keen and watchful!
• Be a keen observer while auditing.
• Look for exhibits in plant notice boards, accident statistics, etc.
• Spent more time in newly built / modified plant (drawing updation, electrical single line diagram, process change procedure/MoC)
Compare!!
• Compare adjacent / similar equipment, phase currents, phase temperatures, conditions, features, shapes when you move around in plant and you could notice:
• Modifications• Rise in temperature• Different type of equipment• Protection devices
Comparison (with comparables) can give lots of valuable hints!!
Safety Observations &
RecommendationsProcess
ChemicalElectrical
InstrumentationMechanical
Occupational HealthFire
Ergonomics
Residual Current operated Circuit Breakers (RCCBs)
• Try tripping a few of them – you will find generally 80%+ bypassed. Investigate and solve the problem technically than readily agreeing to the common ‘Nuisance Tripping’ tactic followed by many.
• Check if the right sensitivity RCCBs are installed.
• UPS loads, HF circuits, DC circuits, etc. requires special type (Super immunized) RCCBs.
Process Changes (for Hazardous plants)
• Take a few old Plant Change Control Procedure (PCCP) / Management of Change (MoC) procedures from the technical services file and check if the relevant drawings are updated. Mostly you will most of the P&IDs are not updated. Check a few modifications!!
• See if review of Hazardous Area Classification (HAC) is part of PCCP / MoC. 90% of the cases, you will not find HAC review in PCCP /MoC.
Process Control Room
• Select 2/3 ESD (Emergency Shut Down) /trip loops and visit the field instruments associated. You could find some serious flaws (bypassing, maintenance issues, fail safe valve positions, associated gauge readings)
• Check the trip & alarm bypass register in the control room. Possibly many will be bypassed for long duration and there would not be any record/control.
• Check if the P&IDs are updated to reflect the recent 3 to 4 process modifications
Pressure Vessels• Check a few PRVs
physically to ensure that they the isolation valves installed below are in line and are not closed
• Do a sample check with the pressure vessel list available to see if any new pressure vessels are left out
• An isolation valve upstream PRV will help to isolate while doing PRV maintenance jobs
Re-Order Level (ROL) for Personal Protective Equipment (PPE)
• Check the ROL (defined minimum inventory level) in stores for critical / special PPE in stores, such as:
• Gas masks / cartridges• Chemical splash-proof goggles
Note:
ROL is to be defined on consumption levels and potential requirement. ROL needs periodic review to avoid high inventory levels.
Electrical Protection Relays
• Check for red flags in relays that indicates that the relay has operated. Find out the reason!
• See if the triple protection relays (common CDG relays from English Electric make) and check if the over current settings are the same (R & B phases will have over current protection)
Transformers
• Check if the winding and oil temperatures are set uniform for all transformers
• See if the bucholtz relay valves are in open condition
• Check for moisture content test reports for transformers that are located near cooling water plant areas / where moisture is present in atmosphere
Toxic Release and Wind Sock
• Fluorescent and illuminated wind socks (at strategic locations) helps in night time evacuations
• Check if wind socks are installed in areas where there is possibility of toxic release
Electrical Testing & Measuring Instruments
• Some big plants calibrate the protection relays with a secondary current injection kit, available internally. See if this master relay is calibrated by a reputed external test agency
• Check if the insulation resistance and earth resistance testers are duly calibrated
First Aid
• Analyze FA box consumption patterns to reveal issues in certain process units, such as:
• Unit A –more head aches• Unit B –slip & fall cases
The FA consumption analysis could help you to identify occupational health issues in some plant areas!
• Do not keep medicines in FA boxes. The plant doctor may be consulted.
Electrical Test Lamps
• Ask electricians if they use test lamps and if yes, check test lamps used by them. Recommend use of double test lamps in series instead of single lamp.
• Single test lamps will explode if tested on 440 volt circuits injuring electricians
Hazardous Area Zone 1 pockets
• Check if Ex e ( Increased Safety) equipment are installed in zone 1 areas
Notes:• Hazardous Areas need to be classified if flammable chemicals
are having a flash point less than 65 degree C
• Zone 1 area: Area where flammable vapour / gases can exist in normal operating conditions
• IS 5572 allows only Ex d or Ex d e type equipment in zone 1 areas
Temperature Classification for hazardous areas
• Check Ex d (flame proof) equipment name plates to see if T-classification aspect is taken care in equipment selection based on the chemical
Note:
Maximum surface temperature of electrical equipment should not be more than the Auto Ignition Temperature (AIT) of the chemicals that are handled / stored where the equipment are located
Surge & Lightning Protection
• Direct lightning protection (Franklin rods, horizontal air terminations) will not protect electronic equipment (UPS, TV, Communication equipment, field instruments, EPBAX, weigh bridges) from surges and transients.
• Surge protection devices are to be additionally installed
Emergency Management Plan (EMP)
• Check if all the telephone numbers are updated
• See if the new / modified hazards (new chemical storage tanks / toxic gas) are considered in the EMP
• Electrical sub station / cable cellar fires are considered as emergency scenarios in EMP?
Rear Electrical panel side identification
• Both front & rear sides (if they can be opened) of electrical panels require to be identified.
• Accidents have occurred where electricians isolated one feeder in the front and opened the wrong live panel on the rear side, resulting in fatal accident!
Orientation of Pressure Relief Valve pipe ends /vents
• Check out if the orientation of PRV vents is away from walk ways / platforms, etc.
• This becomes crucial when PRVs are connected to process vessels that contain toxic gases
• Also look for isolated PRVs!! Look for PRV handle positions.
Chemical compatibility
• Check storage/handling/mixing of chemicals based on their compatibility
Welding
• Gas tests to be done in hazardous areas at:
• Location where welding machine is kept• Location where welding is done
• Welding machine to have both lead and return cables having same length
Work Permits
• Doing audit, look out for a pump / motor /panel under repair and if you find one, check for:
• Valid work permit• If power is positively isolated or not (lock out,
tagged out) at the feeder
AFFF Fire Fighting Foam
• Quality of AFFF to be tested periodically as per manufacturers guidelines/ NFPA 11(once in a year recommended)
• Foam stock to be reviewed based on OISD 116
OH Medical Centre Records
• Analyze the OH centre records to identify trends that will help you to identify:– OH illness in some plant areas– Injury cause categorization– Certain months in an year where accidents
are more– Certain shifts and time where more injuries
are recorded
Accident Reports
• Analyze accident reports for a minimum period of 2 years to categorize and identify trends
• Check a few reports to verify if root cause has been identified and acted upon
• Check the training sessions to check if the accidents are discussed for the benefit of other employees
• Check if accidents of the similar nature repeats! An obvious indication that management is not bothered of accident prevention
Lightning Protection 1
• Installing a vertical air terminal at the top most point in a plant may or may not protect the plant
• This ‘notional volumetric cone of protection’ defined by standards and the actual lightning strike cases do not match
• Install horizontal air terminals atop all buildings that you want to protect
Lightning protection 2
• Earth all metal structures, vessels, tanks to dissipate lightning discharge
• Number of down conductors and its routing are important in the lightning protection design
• Test Links installed on every down conductor helps in effective maintenance
Fire Hydrant System 1• Check if the jockey pump is in manual / auto
mode. Jockey pump has to be in auto mode• If jockey pump is in manual mode, then there is
possibly a un-identified persistent leak (which is possibly underground)
• Ensure adequate diesel stock for the engine driven fire pump
• An emergency light should be available in Fire pump room
Fire Hydrant System 2
• It is a good practice to paint the feeder that feeds fire water pump motor red with the caution, ‘DO NOT SWITCH OFF’
• Install smoke detectors in fire water pump house
• Use infra red hotspot detector (while the fire pump motor is running / when under trial) on the cable terminations to identify hotspots
Smoke Detectors
• Maintain a clearance of 1 meter between smoke detector and A/C air outlet (smoke will be blown away by the air which could result in delayed smoke detection)
• Check the Fire Alarm (FA) panel for healthy condition
• Check for redundant power supply for FA panel• If FA panel has a stand-by battery, check its
healthiness by switching off the main power
HAZOP Recommendations
• Check the HAZOP worksheet to see if the causes are addressed by way of additional safeguards and not only the consequences
• Ensure that nodes are selected so that no part of pipeline / equipment are missed out
• Node selection should be carried out to make the HAZOP process less complex
Critical Process Instrumentation
• Are the critical instruments identified based on ESD loops, etc.?
• Check if sufficient spares are available for all critical instruments
• While carrying out field visit, physically check some critical field instruments to ensure that they are in circuit and not bypassed!
Safety Training• Check if the safety training sessions are
relevant to the plant hazards and past accidents?
• Check the training efficacy by interacting with training participants
• Is participant feedback acted upon?• Are past accidents included in training
programmes?• Competency of faculty satisfactory?
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