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INT-06 Configuring IntelaTracFor Compliance

The industry's leading Mobile Workforce and DecisionSupport System.

Presented By:David ValdezProfessional Services Consultant

© 2013 Invensys. All Rights Reserved. The names, logos, and taglines identifying the products and services of Invensys are proprietary marks of Invensys or its subsidiaries.All third party trademarks and service marks are the proprietary marks of their respective owners.

Presented By:David ValdezProfessional Services Consultant

1Compliance

Compliance is very important! (Duh)

Compliance is an integral part of ensuring the safety of all thatwork in close contact with the chemical plant as well asminimizing fines and fees that come with violating regulations.

Due to the high visibility of recentevents, OSHA and the EPA are underextreme public scrutiny to increaseenforcement. Between 2010 and2011, OSHA added 160 additionalinspectors.

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Due to the high visibility of recentevents, OSHA and the EPA are underextreme public scrutiny to increaseenforcement. Between 2010 and2011, OSHA added 160 additionalinspectors.

In 1991, OSHA and EPA respectively, Released the Standards,PSM & RMP that Applies to Those Companies that are Affectedby The Standards.

PSM and RMP -- Background

A great many industrialfacilities must comply withOSHA's Process SafetyManagement (PSM)regulations as well as the CAA112(r) EPA Risk ManagementProgram (RMP) regulations(Title 40 CFR Part 68).

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A great many industrialfacilities must comply withOSHA's Process SafetyManagement (PSM)regulations as well as the CAA112(r) EPA Risk ManagementProgram (RMP) regulations(Title 40 CFR Part 68).

PSM vs. RMP - What’s the Difference?

RMP•Protects theCommunity

•Protects the GeneralPublic Around theFacility

•Protects AdjacentFacilities Such asSchools & Hospitals

RMP•Protects theCommunity

•Protects the GeneralPublic Around theFacility

•Protects AdjacentFacilities Such asSchools & Hospitals

PSM•Protects theWorkforce

•Protects Contractors•Protects Visitors tothe Facility

•Basically Protects theWorkplace

PSM•Protects theWorkforce

•Protects Contractors•Protects Visitors tothe Facility

•Basically Protects theWorkplace

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RMP•Protects theCommunity

•Protects the GeneralPublic Around theFacility

•Protects AdjacentFacilities Such asSchools & Hospitals

RMP•Protects theCommunity

•Protects the GeneralPublic Around theFacility

•Protects AdjacentFacilities Such asSchools & Hospitals

PSM•Protects theWorkforce

•Protects Contractors•Protects Visitors tothe Facility

•Basically Protects theWorkplace

PSM•Protects theWorkforce

•Protects Contractors•Protects Visitors tothe Facility

•Basically Protects theWorkplace

Did it Work?

“In the last fifteen years, the petroleum refining industry … has had more fatalor catastrophic incidents related to the release of highly hazardous chemicals(HHCs) than any other industry sector covered by the PSM standard. Because ofthis, in 2007 OSHA initiated its refinery NEP to greatly reduce or eliminate theworkplace hazards associated with the catastrophic release of HHCs atpetroleum refineries.

In the first year of the NEP, OSHA inspection teams completed inspections andissued citations at 14 refineries in 6 of OSHA's 10 regions. A total of 348 PSMcitations, including proposed penalties, have been issued.

…We are particularly concerned that our inspection teams are seeing many ofthe same problems repeatedly, and that these include violations of provisionssuch as 1910.119(e)(5), (j)(2), and (j)(5), which are designed to ensure thatdeficiencies in critical process equipment are identified and corrected promptly.”

Directive issued by OSHA in 2007:

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“In the last fifteen years, the petroleum refining industry … has had more fatalor catastrophic incidents related to the release of highly hazardous chemicals(HHCs) than any other industry sector covered by the PSM standard. Because ofthis, in 2007 OSHA initiated its refinery NEP to greatly reduce or eliminate theworkplace hazards associated with the catastrophic release of HHCs atpetroleum refineries.

In the first year of the NEP, OSHA inspection teams completed inspections andissued citations at 14 refineries in 6 of OSHA's 10 regions. A total of 348 PSMcitations, including proposed penalties, have been issued.

…We are particularly concerned that our inspection teams are seeing many ofthe same problems repeatedly, and that these include violations of provisionssuch as 1910.119(e)(5), (j)(2), and (j)(5), which are designed to ensure thatdeficiencies in critical process equipment are identified and corrected promptly.”

Most Frequent NEP PSM Citations

• (f)(1) Operating procedures

• (d)(3) PSI pertaining to equipment

• (e)(3) PHA specific criteria

• (j)(4) MI Inspection & Testing

• (e)(5) PHA recommendation

• (l)(1) MOC implementation

1910.119

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• (f)(1) Operating procedures

• (d)(3) PSI pertaining to equipment

• (e)(3) PHA specific criteria

• (j)(4) MI Inspection & Testing

• (e)(5) PHA recommendation

• (l)(1) MOC implementation

Severe Violator Enforcement Program(SVEP)The Severe Violator Enforcement Program (SVEP), which becameeffective on June 18, 2010, is intended to focus enforcementefforts on recalcitrant employers who demonstrate indifferenceto the health and safety of their employees through willful,repeated, or failure-to-abate violations relating to significanthazards.

Between when the program became effective on June 18, 2010and the end of FY 2011, there were a total of 191 inspectionsdesignated as SVEP cases. In the first, partial fiscal year (June18, 2010 – September 30, 2010), there were 41 cases. In FY2011, the first full year of the SVEP, there were 150 SVEP cases

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Bottom Line: OSHA is Serious AboutCompliance and Enforcement of PSM

The Severe Violator Enforcement Program (SVEP), which becameeffective on June 18, 2010, is intended to focus enforcementefforts on recalcitrant employers who demonstrate indifferenceto the health and safety of their employees through willful,repeated, or failure-to-abate violations relating to significanthazards.

Between when the program became effective on June 18, 2010and the end of FY 2011, there were a total of 191 inspectionsdesignated as SVEP cases. In the first, partial fiscal year (June18, 2010 – September 30, 2010), there were 41 cases. In FY2011, the first full year of the SVEP, there were 150 SVEP cases

As of January 2011:

• Approximately 90% of the nation’s refinery capacity is under lodgedor entered “global” settlements (“global” settlements addressmarquee issues at refineries company-wide)

Settlements to date represent:• 28 refiners• 109 refineries• Over $6.5 billion in capital costs for new control technologies• Over $93 million in civil penalties• $80 million in environmental projects• Located in 32 states and territories

EPA Enforcement:National Petroleum Refinery Initiative

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As of January 2011:

• Approximately 90% of the nation’s refinery capacity is under lodgedor entered “global” settlements (“global” settlements addressmarquee issues at refineries company-wide)

Settlements to date represent:• 28 refiners• 109 refineries• Over $6.5 billion in capital costs for new control technologies• Over $93 million in civil penalties• $80 million in environmental projects• Located in 32 states and territories

Bottom Line: So is the EPA

Multimillion Incident an Exception? Hardly.• Average cost per major incident related to operator error exceeds $80M.

• Findings by the Chemical Safety Topical Committee (funded by DOE) reveal anaverage of one chemical incident/day.

• Average cost to comply with ORPS process is estimated at $2M per incident *

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* Source: Gulf Coast Plant Managers Forum Workshop – Plant Success 2011 (ORPS – Occurrence Reporting and Processing System US DOE)

Note: Incident compliance cost requirement does not take into account other direct or indirect costs (e.g. repairing equipment/facilities, employee injuries, revising procedures,increased training, work slowdowns and stoppages during accident investigations and corrective action implementations, etc.).

2Effective Detection

How have other industries succeeded?On October 30, 1935, the US Air Corps held a competition…Boeing’s Model 299 roared down the tarmac, lifted off smoothly,and climbed sharply to three hundred feet. Then it stalled, turnedon one wing, and crashed in a fiery explosion.

The crash had been due to "piloterror,”…(the Boeing model wasdeemed, as a newspaper put it,"too much airplane for one man tofly.“) The Army Air Corps declaredDouglas's smaller design thewinner….So a group of test pilotsgot together and…they created apilot's checklist, with step-by-stepchecks for takeoff, flight, landing,and taxiing…

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The crash had been due to "piloterror,”…(the Boeing model wasdeemed, as a newspaper put it,"too much airplane for one man tofly.“) The Army Air Corps declaredDouglas's smaller design thewinner….So a group of test pilotsgot together and…they created apilot's checklist, with step-by-stepchecks for takeoff, flight, landing,and taxiing…

How have other industries succeeded?

With the checklist in hand, the pilotswent on to fly the Model 299 a total of1.8 million miles without one accident.The Army ultimately ordered almostthirteen thousand of the aircraft, whichit dubbed the B-17.

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And, because flying the behemothwas now possible, the Armygained a decisive air advantage inthe Second World War whichenabled its devastating bombingcampaign across Nazi Germany.

How have other industries succeeded?

In the U.S., hospital-acquired infections affect 1 in10 patients, killing 90,000 of them and costing asmuch as $11 billion each year. Peter Pronovost,developed a checklist in 2001 to tackle oneproblem: line infection.

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A common complication that may occur when a catheter isinserted into the body. His checklist to avoid line infection isincredibly simple. "Doctors are supposed to (1) wash their handswith soap, (2) clean the patient's skin with chlorhexidine antiseptic,(3) put sterile drapes over the entire patient, (4) wear a sterilemask, hat, gown, and gloves, and (5) put a sterile dressing overthe catheter site once the line is in."

How have other industries succeeded?In 2004, Michigan hospitals began implementing Pronovost’schecklists in ICUs. Sinai-Grace in particular experienced morecentral line infections than 75% of American hospitals

However, by December 2006:• Most ICU’s, including Sinai-Grace, cut quarterly infection rates

to zero• Michigan’s ICU outperformed 90% of ICU’s nationwide.

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However, by December 2006:• Most ICU’s, including Sinai-Grace, cut quarterly infection rates

to zero• Michigan’s ICU outperformed 90% of ICU’s nationwide.

In the 1st 18 months thechecklist saved $175M (est.)and more that 1500 lives!

Point is…Never Assume!

• Regardless of its size, aproper checklist can addvalue and prevent badthings from happening.

• Regardless of the years ofexperience, a simplechecklist can have positiveeffects

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• Regardless of its size, aproper checklist can addvalue and prevent badthings from happening.

• Regardless of the years ofexperience, a simplechecklist can have positiveeffects

Make Your Checklist Count1910.119(e)(3)(iii) (PHA)“Engineering and administrative controls applicable to the hazards and theirinterrelationships such as appropriate application of detection methodologies toprovide early warning of releases. (Acceptable detection methods might includeprocess monitoring…”1910.119(f)(1)“The employer shall develop and implement written operating procedures thatprovide clear instructions for safely conducting activities involved in each coveredprocess consistent with the process safety information and shall address at leastthe following elements.”1910.119(f)(1)(ii)Operating limits:1910.119(f)(1)(ii)(A)Consequences of deviation1910.119(f)(1)(ii)(B)Steps required to correct or avoid deviation.

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1910.119(e)(3)(iii) (PHA)“Engineering and administrative controls applicable to the hazards and theirinterrelationships such as appropriate application of detection methodologies toprovide early warning of releases. (Acceptable detection methods might includeprocess monitoring…”1910.119(f)(1)“The employer shall develop and implement written operating procedures thatprovide clear instructions for safely conducting activities involved in each coveredprocess consistent with the process safety information and shall address at leastthe following elements.”1910.119(f)(1)(ii)Operating limits:1910.119(f)(1)(ii)(A)Consequences of deviation1910.119(f)(1)(ii)(B)Steps required to correct or avoid deviation.

Make Your Checklist Count

6.4 OPERATING PROCEDURES (§ 68.52)

Written operating procedures describe in detail what tasks a process operatormust perform, set safe process operating parameters that must be maintained,and set safety precautions for operations and maintenance activities. Theseprocedures are the guide for telling your employees how to work safelyeveryday, giving everyone a quick source of information that can prevent ormitigate the effects of an accident, and providing workers and managementwith a standard against which to assess performance.

Equipment Inspections. You should include steps for routine inspection andsurveillance of equipment by operators as part of your other procedures.

Consequences of Deviations. Your operating procedures should tell theworkers what will happen if something starts to go wrong.

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6.4 OPERATING PROCEDURES (§ 68.52)

Written operating procedures describe in detail what tasks a process operatormust perform, set safe process operating parameters that must be maintained,and set safety precautions for operations and maintenance activities. Theseprocedures are the guide for telling your employees how to work safelyeveryday, giving everyone a quick source of information that can prevent ormitigate the effects of an accident, and providing workers and managementwith a standard against which to assess performance.

Equipment Inspections. You should include steps for routine inspection andsurveillance of equipment by operators as part of your other procedures.

Consequences of Deviations. Your operating procedures should tell theworkers what will happen if something starts to go wrong.

The Traditional Approach

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“Wasting money puts you in a real party mood” – Andy Warhol

User Administration, Device ManagementSystem & Data Center Management

SystemAdministration

Integrated Workflow - IntelaTrac

Procedures Versioning Scheduling

Super Users Mobile Workers

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User Administration, Device ManagementSystem & Data Center Management

Round/Route Approval PerformanceMonitoring Exception ManagementShift Handover/Logs

Supervisors

Exception ReportsProcess/Performance KPIsEmail Notifications

Management

Process HistorianWW, OSI PI,AspenTech

CMMS / Reliability

Avantis, Maximo, Hansen

EnterpriseIntegration

3Configure a Roundto ComplyConfigure a Roundto Comply

Communication Culture Change:Giving the Operator a Clue

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In many chemical processes around the world, operators are making their roundschecking on those items that have been deemed “critical to process safety”... But inmany instances involving these checklists, there is one item that is painfully obviousafter an incident– the operator was never provided with safe upper and lower limitsof those items they were checking so that they could IMMEDIATELY recognize aprocess deviation.

Operating Limits – The “What”

1910.119(f)(1)(ii)Operating limits:

“ the checklist MUST contain the SAFE UPPER and LOWER LIMITS for theseitems. This way, when the operator is writing down their readings, they canIMMEDIATELY identify a deviation from the SOE and not rely on some checklistreview hours later by someone else with the hopes the deviation will be noticedin time.” - “Operator Rounds” in a PSM/RMP Covered Process - Safety Engineering Network (SAFTENG)

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1910.119(f)(1)(ii)Operating limits:

Consequence of Deviation – The “Why”

1910.119(f)(1)(ii)(A)Consequences ofdeviation;

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You’ve spent years developing PHA’sto determine the consequences ofdeviation. Pass it on!

Action Steps to Correct or AvoidDeviation – The “How”

1910.119(f)(1)(ii)(B)Steps required tocorrect or avoid

deviation

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1910.119(f)(1)(ii)(B)Steps required tocorrect or avoid

deviation

Safety and Health Communications

1910.119(f)(1)(iii)Safety and healthconsiderations

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Task Group Description will handle up to 255 characters

Required Tasks

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“Required” Procedures

When scheduling aProcedure, under the“Advanced” tab, selectthe radio button to makeit a required procedurethat must be completedfor compliancechecklists/rounds.

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When scheduling aProcedure, under the“Advanced” tab, selectthe radio button to makeit a required procedurethat must be completedfor compliancechecklists/rounds.

Recording “As Found/As Left”

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Use Conditional Tasks

Example of As Found/As Left

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Use of Launched and SequencedProceduresAt any given time, a procedure specifically designed with instructional tasksand/or to document corrective action taken could be launched to ensure localcompliance and generate documents accepted by government agencies.

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Procedures can also be “Sequenced” to ensure steps are done in order.

4IntelaTracReportingCapabilities

IntelaTracReportingCapabilities

Data Filter AND Severity Use

Use Severity as areporting tool as well asthe conventional DataFilter

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Supervisors can quickly find anysafety concerns in Auditor Plusby viewing “Severity/Data Filter”

Search Report

Use a specific word/acronym in the Grouptitle, Task title, Tag Name or Notes toidentify compliance related tasks

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Search Report

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Successive Exception Report“We are particularly concerned that our inspection teams are seeing many ofthe same problems repeatedly…”

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5Review

• SOL’s not displayed

• Consequences of Deviation not communicated

• Steps to prevent/correct deviation not communicated

• Specific Health and Safety Issues not easily communicated

• No way to initiate additional tasks when deviationencountered

• Operator must come inside to print additional procedureswhich takes additional time

• Labor intensive documentation for compliance

• Labor intensive documentation retrieval during audit

• Operating Procedures kept in a book somewhere

Problem Description (Paper Based)• Standardized work processes and best

practices• Improved decision support:

• Consequences of deviation and steps toprevent/correct immediately displayed

• Additional tasks/procedures generated to aidoperator and document as found/as left

• Data is available to all using scheduled reports

• Engineers and HSE experts can be notified ofconcerns immediately

• Documentation stored and retrieved mucheasier.

• Operating Procedures imbedded withinOperator Rounds

Results (IntelaTrac Based)

Mobile Solutions Success Story

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• SOL’s not displayed

• Consequences of Deviation not communicated

• Steps to prevent/correct deviation not communicated

• Specific Health and Safety Issues not easily communicated

• No way to initiate additional tasks when deviationencountered

• Operator must come inside to print additional procedureswhich takes additional time

• Labor intensive documentation for compliance

• Labor intensive documentation retrieval during audit

• Operating Procedures kept in a book somewhere

• Standardized work processes and bestpractices

• Improved decision support:• Consequences of deviation and steps to

prevent/correct immediately displayed

• Additional tasks/procedures generated to aidoperator and document as found/as left

• Data is available to all using scheduled reports

• Engineers and HSE experts can be notified ofconcerns immediately

• Documentation stored and retrieved mucheasier.

• Operating Procedures imbedded withinOperator Rounds

Benefits Summary:• Improved safety and environmental performance• Improved awareness of Safe Operating Limits and Actions needed to mitigate• Engaged and empowered the 24 X 7 workforce to support enhanced decision-making and optimized workflows

Operating Rounds and Checklists (IntelaTrac)• Should be included in Operating Procedures• Must include Safe Operating Limits• Must include Health and Safety Considerations• Must address Consequences of Deviation• Must include steps to prevent/mitigate Consequences

of Deviation• Should be certified annually that they are correct and

accurate• Must be part of your MOC process

Review

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Operating Rounds and Checklists (IntelaTrac)• Should be included in Operating Procedures• Must include Safe Operating Limits• Must include Health and Safety Considerations• Must address Consequences of Deviation• Must include steps to prevent/mitigate Consequences

of Deviation• Should be certified annually that they are correct and

accurate• Must be part of your MOC process

IntelaTrac is a process, not a program!

Q & A

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