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AMPCO Safety Management System
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Resident Manager’s Introduction As we have communicated through our company vision and values, mission statement, company performance objectives and periodic discussions with you – our valued employees and company stakeholders - continually improving our performance is necessary for us to become the most successful methanol company in the industry. Health, environment and safety (HES) is one of our core business areas where achieving a high level of performance is essential. HES management practices are in close alignment with operational and other business practices. The HES management practices enhance our firm commitment to protecting the health and safety of our employees and protecting the environment. It also establishes methods to improve the performance of our work. It helps us by establishing a more systematic approach to planning, executing, measuring and improving our work activities. The HES management system provides a framework for conducting our work better by integrating a simple four-step work model into our current business practices. The steps are: Plan, Implement, Measure and Improve. This framework helps us to consistently manage the high priority HES areas of our business. These are depicted in the model as the eleven HES Elements. Each Element is further defined by a series of Requirements by which we will be managing our HES efforts. The Requirements are carried out through our day to day procedures and practices we follow to perform our work. Overall, the HES management system will help us to better align the good work we are already doing and allow us to improve approaches to planning our work, implementing our work, measuring the performance of our work and improving our work methods and outcomes on a continuous basis. As we strive for continual improvement in all areas of our business, we are counting on everyone to collectively focus efforts on strengthening our HES management system practices and thus, our overall performance.
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AMPCO Safety Management System (ASMS) The development of new standards for HES management is a worldwide phenomenon, as national and international attention to HES performance continues to grow. Governments are increasingly demanding that companies adopt a systematic approach to HES issues. An integrated system will help us to comply with all the necessary/applicable standards. Page 5 provides a copy of our HES Policy. Page 6 is an illustration and explanation of the underlying basis of integrating HES requirements into AMPCO operational practices. Aligning the HES Management System Components Our goal is to create a practical HES management system centered on how the work is done – a system that will systematically connect HES requirements to everyday operating programs, procedures and practices AMPCO Vision & Values: The sketches on pages 6 & 7 show the overarching principles that establish the basis for our day-to-day business operations at AMPCO. The vision and values are engrained in the organizational culture and individual worker behaviors HES Management System Framework: The framework establishes the priority HES topics and requirements for systematically managing HES work practices and activities HES Policies, Programs, and Procedures: These are written descriptions of what and how to carry out work; for example, emergency notification, root cause investigation, contractor selection, etc. These may be unique to a functional area or operating location
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Illustration of the AMPCO Safety Management System (ASMS)
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HES MS ELEMENTS 1. Leadership and commitment 2. Risk Management 3. Operating & Maintaining the Facility 4. Management of Change 5. Regulatory Compliance 6. Training and Competency 7. Incident Management 8. Emergency Management 9. Documents and Records 10. Performance Measurement & Tracking 11. Management Review & Follow-up
AMPCO VISION & VALUES
IMPLEMENT
MEASURE
IMPROVE
PLAN
HES MANAGEMENT SYSTEM FRAMEWORK
HOW
HES POLICIES, PROGRAMS, PROCEDURES, & PRACTICES
Functional Support for HES Policies, Procedures, Programs, & Practices (OPERATIONS, MAINTENANCE, ENGINEERING, HES, HR & ADMIN, TRAINING & DEV., GEN. MGMT.)
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• Establish Goals, Objectives, Action
Plans & Performance Measures • Define Roles, Responsibilities,
Authorities, & Competencies • Identify & Incorporate Compliance
Requirements • Identify Risks
• Review Action Plans & Assessments
• Identify Areas of Improvement • Improve via Observations,
Conclusions & Recommendations
• Track and Report Improvements
• Quantify Results through Routine Measurement
• Review Data • Maintain Performance Trends • Determine Achievement of Outcomes • Compare Results • Evaluate Self-Assessments & Third
Party Reviews
• Assign & Execute Expectations,
Roles, Responsibilities • Develop and Utilize Work
Processes and Procedures • Train Individuals • Establish Document and Records
Control Procedures • Enable Effective Communications
Health, Environmental and Safety Management System Design Specifications
Every successful management system is built on a basic “Plan, Do, Check, Act” (PDCA) model. For the AMPCO Health, Environmental and Safety Management System (HES MS), we have modified the PDCA model to “Plan, Implement, Measure, Improve” as shown below.
Continual Improvement is embedded into each component of the diagram – it is the overriding driver for the system. The effectiveness of the HES MS should continue to improve through the use of appropriate objectives, policies, programs, procedures, data analysis and audit results, corrective and preventive actions, and management review.
IMPLEMENT
MEASURE
IMPROVE
PLAN
BASIC HES MANAGEMENT SYSTEM MODEL
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AMPCO Safety Management System (ASMS) Model Leadership and Commitment The role of management is critical to the success of ongoing HES Performance. Management shall: establish policy, objectives, and goals consistent with AMPCO’s culture and values
and in compliance with laws and regulations; demonstrate support and commitment; communicate HES goals, objectives and intentions on a regular basis; provide the resources needed so the HES efforts can achieve the desired performance; hold everyone accountable for achieving the desired level of performance; and review the HES performance results on a regular basis. “Plan” The work activities that comprise planning include: establishing HES goals, objectives, action plans and performance measures for relevant functions within the organization and
translating these into programs, procedures, and practices with defined review periods; defining roles, responsibilities, authorities, and competencies for our work; identifying appropriate compliance requirements and incorporating them in relevant programs, procedures, and practices; establishing timelines and resource requirements for the programs, procedures, and practices implementation; and identifying potential risks through assessment and contingency planning. “Implement”
The work activities that comprise implementation include: assigning specific roles, responsibilities and authorities and monitoring for performance; developing and utilizing work procedures to meet company requirements; training employees on the programs, procedures and practices applicable to their roles and responsibilities; establishing and maintaining document and record control and retention procedures; and stimulating effective communications across all levels of the organization.
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“Measure” The work activities that comprise measurement include: measuring programs, procedures, and practices on a routine basis to quantify performance results; reviewing performance data for consistency and accuracy; maintaining performance trends to assess progress and identify gaps; assessing programs, procedures, practices, and various measurements to determine if expected outcomes are being achieved; comparing performance results against goals, objectives, and action plans; and auditing results through Tier I, II, and III audits. “Improve” The work activities that comprise improvement include: conducting management reviews of HES programs, procedures and practices to evaluate effectiveness and to identify areas for
improvement; using the results of management reviews to make improvements to policies, standards, goals, objectives, programs, procedures,
and practices; and tracking improvements to completion and resolution.
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ASMS Management System --- Elements and Requirements 1. Leadership and Commitment
1.1 The AMPCO HES Policy documents Leadership commitment to continual improvement, injury and pollution prevention, and compliance with applicable legal requirements.
1.2 Leaders demonstrate positive HES behaviors by personal example and reinforce and reward positive behaviors. 1.3 Leaders maintain a structured two way communication channel with employees, contractors and other appropriate
external stakeholders on HES issues. 1.4 Leaders integrate the HES management system and its requirements into business planning and decision making
processes. 1.5 Leaders set clear HES goals, objectives, roles and responsibilities, and performance measures and allocate adequate
resources to achieve them. 1.6 Leaders ensure HES goals, objectives and performance measures are cascaded down to all appropriate levels of the
organization. 1.7 Worker performance is assessed against the set HES goals, objectives and measures.
Special Notes: 1) Social Responsibility is managed separately from HES. 2) Security is managed separately from HES.
2. Risk Management 2.1 All employees participate in identifying potential hazards and risks to personnel, facilities, the public, customers and the
environment.
2.2 Potential hazards and risks are assessed for existing operations, products, new projects, and modifications.
2.3 Assessed risks are addressed by levels of management appropriate to the nature and magnitude of the risk. Decisions are clearly documented and mitigation actions are taken.
2.4 Risk assessments and mitigation methods are referenced in project approval documentation and records.
2.5 Initial process hazard analysis (PHA) is conducted on processes containing highly hazardous materials. PHA’s shall address the hazards of the process, and evaluate any previous incident which had a likely potential for serious impact to the plant operations.
2.6 PHA’s shall be updated and revalidated every five (5) years.
2.7 Risk assessments are updated at specified intervals and as changes occur.
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3. Operating and Maintaining the Facility 3.1 Facility Design & Construction
3.1.1 Facilities are designed and constructed to meet compliance requirements for HES, such as emissions, discharges, impacts to biodiversity, personal health or safety, and/or public health or safety.
3.1.2 Operations, maintenance and HES expertise is integrated early in the facility design stage.
3.1.3 A stage gate approach shall be used to plan, implement, measure and improve new or modified facility and equipment installations.
3.1.4 Deviations from design standards and process controls are identified and managed. Deviations are recorded and maintained in project files.
3.1.5 Quality assurance and inspections practices are in place to verify facilities meet design and procurement specifications and that construction is completed in accordance with approved standards.
3.2 Pre-Start Up Review
3.2.1 Pre-start up reviews are conducted for all new or modified equipment. The pre-start up reviews are recorded and maintained in the project files. Corrective actions are completed prior to start-up. Actions taken are recorded.
3.3 Operating Procedures
3.3.1 Key operating parameters are established and regularly monitored for conformance. Workers understand their roles and responsibilities to maintain operations within the stated parameters.
3.3.2 Clearly defined start-up, operating, maintenance, emergency shutdown, and routine shutdown procedures are current, in place, and have assigned accountabilities.
3.3.3 Procedures are periodically evaluated to verify they are current and accurate.
3.4 Mechanical Integrity
3.4.1 Mechanical integrity is maintained by use of clearly defined and recorded operational, maintenance, inspection and corrosion control practices. CFR 1910.119 requirements shall be used for mechanical integrity.
3.4.2 Equipment that has been out of service for maintenance or modification shall be subject to documented inspection and/or testing prior to use.
3.4.3 Reliability and availability of protective systems shall be maintained by appropriate testing and maintenance programs.
3.4.4 Decommissioning, remediation and restoration plans shall be established using risk-based studies for end of life equipment and facilities.
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3.4.5 Condition-based and/or reliability-based maintenance practices shall be used to guide the delivery of the maintenance program.
3.5 Contractor and Supplier Management
3.5.1 Pre-qualification, selection and retention criteria shall be maintained for work performed by contractors, suppliers and others as appropriate.
3.5.2 AMPCO HES requirements are clearly communicated and provided to contractors, suppliers and others as appropriate.
3.5.3 Hazards and risks associated with contractor, suppliers and others are identified, communicated and mitigated prior to performing work or providing the service.
3.5.4 Contractors will be monitored and audited to track their performance, correct instances of non-compliance and identify opportunities for improvement.
3.5.5 Contractors shall be held accountable for conducting training for their workers in work practices necessary to safely perform the work.
3.5.6 Products and services are verified for meeting company HES standards prior to their purchase.
3.6 Product Stewardship
3.6.1 Assessments shall be conducted on methanol and intermediate streams when changes occur, including the potential effects that may occur by workers handling these products.
3.6.2 New uses or markets for methanol shall be evaluated to ensure HES hazards and risks are identified and mitigated.
3.6.3 Current and accurate information on HES hazards and risks relating to the use, storage, handling, transport and disposal of methanol shall be available to workers, contractors, customers and others that are appropriate.
3.6.4 Procedures exist to collect and evaluate adverse effects reported or experienced by those handling company products.
3.6.5 A practice shall be maintained to provide 24-hour emergency response HES information on company products.
3.7 Control of Work
3.7.1 A “permit to work” system shall be maintained to ensure the appropriate level of job HES review and evaluation is conducted prior to authorization for work to begin.
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3.8 Worker Health and Wellness
3.8.1 A first aid and medical program shall be maintained to provide emergency response and care, as well as for appropriate chronic job related medical condition management.
3.8.2 An industrial hygiene program shall be maintained to monitor and evaluate workplace exposures, control any harmful exposures, and conduct follow-up exposure monitoring as appropriate.
3.8.3 A worker wellness program shall be maintained to promote worker health, as well as healthy lifestyles both on and off the job.
3.8.4 A Malaria Control Program shall be maintained to safeguard the health of all employees.
3.9 Environmental Aspects
3.9.1 A pollution prevention program shall be maintained to avoid the release of pollutants. Should releases occur, steps shall be in place to minimize and control the impact of any release to air, water or land.
3.9.2 A waste management program shall be maintained to avoid or minimize the generation of hazardous and non-hazardous waste materials. Wastes shall be reused where possible or disposed of in a responsible manner.
4. Managing Change
4.1 All temporary and permanent changes to organization, personnel, procedures, equipment, products, materials or substances shall be evaluated, documented and approved to ensure that HES risks are appropriately controlled.
4.2 The original scope and duration of temporary changes shall not exceed the specified time limit without the review and approval by the appropriate level of management.
5. Regulatory Compliance
5.1 Legal and other regulatory compliance requirements and obligations are identified, recorded on a compliance register and tracked for conformance.
5.2 Compliance obligations are built into work procedures and practices (link to 3.3 – Operating Procedures).
5.3 New and emerging compliance requirements and obligations are monitored for applicability to plant operations. 6. Training and Competency
6.1 Recruitment, selection and placement procedures ensure that personnel are qualified, competent and physically and mentally fit for their assigned job.
6.2 New or transferred workers, contractors and temporary visiting personnel undergo appropriate site orientation and induction training which covers HES rules and emergency procedures.
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6.3 Worker HES training and competency needs are periodically evaluated, improvement plans developed and tracked to closure.
6.4 Workers shall be trained in the procedures and practices for completing their jobs. The training shall include emphasis on the HES aspects of the assignments.
6.5 Refresher training for workers in plant process areas shall be at least every three years. Refresher training for non-plant process area workers shall be based on hazard potential of the assignments.
6.6 The workforce competency is verified by means of objective tests or other methods and recorded before they perform their jobs.
6.7 Training programs and instruction methods are evaluated to determine their effectiveness.
7. Incident Management 7.1 All health, environmental, personal safety, process safety, security, mechanical integrity incidents and near misses are
openly reported in a timely fashion.
7.2 Major incidents are investigated by a cross-functional team trained in incident investigation.
7.3 Incident investigations, including identification of root causes and preventive actions, are recorded and corrective actions taken.
7.4 Information gathered from incident investigations is analyzed to identify and monitor trends and develop preventive actions.
7.5 Lessons learned from investigations are shared across the Punta Europa facility workforce and affected personnel take preventive actions.
8. Emergency Management
8.1 Plans and procedures are maintained to provide a secure workplace.
8.2 Plans and procedures are maintained to address emergency scenarios with potentially serious consequences, including reasonably foreseeable worst case scenarios. The plans shall include appropriate considerations of communications and community recovery needs. Efforts shall also include appropriate input for community preparedness plans related to potential company incidents.
8.3 Equipment, facilities and personnel needed for emergency response are identified, available, and regularly tested.
8.4 Personnel are trained and understand emergency plans, their roles and responsibilities, and the use of crisis management tools and resources.
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8.5 Drills and exercises are conducted to assess and improve emergency response capabilities, including liaison with and involvement of external organizations.
8.6 Periodic updates of plans and training are used to capture lessons learned from previous exercises or incidents. 9. Documents and Records
9.1 A documents and records management procedure is maintained to approve, review, revise and re-issue HES policies, programs, procedures, and practices.
9.2 A documents and records management procedure is in place to maintain drawings, design data and other information.
9.3 Pertinent records are maintained, available and retained as necessary.
9.4 Confidential information shall be identified and segregated from other information.
9.5 All documents are legible, labeled, dated and protected from damage. Obsolete documentation is identified and removed from circulation.
9.6 PHA updates and revalidations and any resolved recommendations records shall be retained for the life of the process.
9.7 Worker health, medical and occupational exposure records are maintained with appropriate confidentiality and retained as required
9.8 A records retention policy shall be in place that covers key principles of records management identified in 9.1 through 9.7.
10. Performance Measurement and Tracking 10.1 Metrics
10.1.1 HES performance metrics, both lagging and leading, are established, communicated and understood throughout the organization.
10.1.2 HES performance metrics are regularly used to make the necessary HES policy, program, procedure or practice improvements.
10.1.3 AMPCO reports HES performance data as part of the Owner’s reporting requirements. 10.2 Inspection and Audits
10.2.1 Plant supervision is actively involved in periodic self assessments of effectiveness of HES procedures and practices.
10.2.2 Procedures exist to continually improve personnel HES behaviors through observation, recording and coaching.
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10.2.3 A documented, risk-based inspection and audit program exists to periodically evaluate progress towards HES policy, procedures, performance objectives, and regulatory compliance.
10.3 Corrective Actions
10.3.1 Corrective actions resulting from incident investigations, near misses, audits, inspections, PHAs, etc., are prioritized, assigned accountability, recorded, and tracked to successful closure.
11. Management Review and Follow-up
11.1 The Management Team reviews the HES management system periodically, but at a minimum annually, to ensure it is continually delivering consistent, desired performance. Based on the results from the review, corrective actions shall be established for making necessary improvements.
11.2 The Management Team promotes the sharing of HES lessons learned inside and outside the company.
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AMPCO SAFETY MANAGEMENT SYSTEM
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