PSM Audit by IEAT
HMC participated in a Plant Integrity Audit as a Pilot Plant between 28-30 March performed by Industrial Estate Authority of Thailand.
The Thai Government established an overall Process Safety Management (PSM) structure in 2014 based on OSHA 29 CFR 1910.119. As a result, a compliance audit will be conducted on all plants in the near future and the operating authority IEAT is expected to launch PSM regulations in 2016.
Per OSHA documentation, unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties.
Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster. Accidents such as those described are high impact, low frequency events and technical knowledge is required in order to ensure the correct management of processes is consistently applied as the corporate operating protocol.
OSHA has published a standard, "Process Safety Management of Highly Hazardous Chemicals" containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe workplaces and this work has served as a guide for the Thai government and its audit authorities.
In Thailand a PSM external audit done by IEAT (Industrial Estate Authority of Thailand), EIT (Engineering Institute of Thailand) and external auditors, shall be conducted on a 3-year basis, or sooner depending on any major plant major changes which may impact process safety management. The PSM external audit results will have a significant role in the extensions of plant operating permits. As the process is now in a startup phase, in 2015 and 2016 3 companies were audited as trial plants. HMC has volunteered to be such a pilot plant since 2014. The objectives of the audits are to ensure that employers are in compliance with PSM standards designed to prevent major accidents and/or limit the consequences to employees, communities and the environment should they occur.
In conducting the initial pilot audits with HMC Polymers, IEAT has the opportunity to practice and refine its audit procedures, while HMC can gain valuable external insight on any possible gaps in our Process Safety Management practices. For the audit conducted between 28-30 March, 25 persons for IEAT, EIT and external auditors/observers came to HMC to work as the audit team.
There were 4 audit sessions in total occurring simultaneously with 2 auditors at each session. Two to three observers were assigned at each session. The 4 audit sessions were assigned to audit 3-4 process safety elements as specified in OSHA 29 CFR 1910.119.
Those elements included such areas as: Process Safety Information, Process Hazard Analysis, Operating Procedures, Contractor Safety Management, Mechanical Integrity and Emergency Planning and Response.
The auditors classify their results using 3 levels: Pass – Pass with some conditions – Not pass. The auditors gave an executive summary to conclude the audit and informed that HMC had received a ‘PASS’ result without any conditions.
At HMC full compliance with all applicable laws and regulations is a fundamental corporate practice, or where appropriate, the application of a relevant company standard if more stringent. We believe that zero TRC (injuries and process incidents) is attainable and that is always our goal and is non-negotiable. We are committed to continuous improvement based on sound science, risk assessment and benefit analysis, and to measure, audit and communicate our performance honestly to all stakeholders.