Conditions of Release (COR) Safety Procedures and Guidelines

Conditions of Release (COR) are safety procedures and guidelines that define and address the necessary steps and precautions to ensure equipment and operations are safely released back into service after maintenance, modification, or any other activity that could affect their integrity. These procedures aim to prevent unintended releases of hazardous materials or energy and ensure equipment functions as intended.

General Safety Procedures

Mechanical Integrity Program

A mechanical integrity program is crucial for equipment used to process, store, or handle hazardous chemicals, ensuring it's designed, constructed, installed, and maintained to minimize release risks. This program includes:

Identification and categorization of equipment and instrumentation
Inspections and tests
Testing and inspection frequencies
Development of maintenance procedures
Training of maintenance personnel
Establishment of criteria for acceptable test results
Documentation of test and inspection results
Documentation of manufacturer recommendations as to meantime to failure for equipment and instrumentation

The first line of defense is to operate and maintain the process as designed and to keep the chemicals contained. This is backed up by the controlled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks designed to receive such chemicals. Secondary defenses include fixed fire protection systems, dikes, and designed drainage systems to control or mitigate hazardous chemicals once released.

A quality assurance system is needed to ensure the proper materials of construction are used, fabrication and inspection procedures are proper, and installation procedures recognize field installation concerns. 'As built' drawings, certifications of coded vessels and other equipment, and materials of construction need to be verified and retained in the quality assurance documentation.

Equipment installation jobs need to be properly inspected in the field for the use of proper materials and procedures and to assure that qualified craftsmen are used to do the job. The use of appropriate gaskets, packing, bolts, valves, lubricants, and welding rods need to be verified in the field. Also, procedures for the installation of safety devices need to be verified, such as the torque on the bolts on ruptured disc installations, uniform torque on flange bolts, proper installation of pump seals, etc.

Any changes in equipment that may become necessary will need to go through the management of change procedures.

Non-routine Work Authorizations

Non-routine work conducted in process areas needs to be controlled consistently. Hazards must be communicated to those doing the work and operating personnel whose work could affect process safety. A work authorization notice or permit must detail the steps a maintenance supervisor, contractor representative, or other person needs to follow to obtain the necessary clearance to start the job.

Work authorization procedures need to reference and coordinate lockout/tagout, line breaking, confined space entry, and hot work authorizations. The procedure also needs to provide clear steps to follow once the job is completed to provide closure for those that need to know the job is completed and equipment can be returned to normal.

Managing Change

Changes to process chemicals, technology, equipment, and facilities, other than 'replacement in kind,' need to be properly managed by identifying and reviewing them prior to implementation. Operating procedures contain operating parameters (pressure limits, temperature ranges, flow rates, etc.) and the importance of operating within these limits. Operation outside of these parameters requires review and approval by a written management of change procedure.

Management of change covers changes in process technology and changes to equipment and instrumentation. Changes in process technology can result from changes in production rates, raw materials, experimentation, equipment unavailability, new equipment, new product development, change in catalyst, and changes in operating conditions to improve yield or quality. Equipment changes include changes in materials of construction, equipment specifications, piping pre-arrangements, experimental equipment, computer program revisions, and changes in alarms and interlocks.

Temporary changes have caused a number of catastrophes over the years, and employers need to establish ways to detect temporary changes as well as those that are permanent. It is important that a time limit for temporary changes be established and monitored since, without control, these changes may tend to become permanent. Temporary changes are subject to the management of change provisions. In addition, the management of change procedures are used to insure that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change.

A typical change form may include a description and the purpose of the change, the technical basis for the change, safety and health considerations, documentation of changes for the operating procedures, maintenance procedures, inspection and testing, P&IDs, electrical classification, training and communications, pre-startup inspection, duration if a temporary change, approvals, and authorization. Where the impact of the change is minor and well understood, a checklist reviewed by an authorized person with proper communication to others who are affected may be sufficient. However, for a more complex or significant design change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments may be appropriate.

Changes in documents such as P&IDs, raw materials, operating procedures, mechanical integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the drawings and procedure manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated.

Pre-Startup Safety

For new processes, a PHA (Process Hazard Analysis) is helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters.

For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than 'replacement in kind' made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and non-routine work in the process area may need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the startup.

Incident Investigation

Incident investigation identifies the underlying causes of incidents and implements steps to prevent similar events. The intent is for employers to learn from past experiences and avoid repeating past mistakes. OSHA expects employers to be aware of and investigate events that result in or could reasonably have resulted in a catastrophic release, including 'near misses'.

Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their knowledge of the events form a significant set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those who can benefit from the information. The cooperation of employees is essential to an effective incident investigation. The focus of the investigation should be to obtain facts, and not to place blame. The team and the investigation process should clearly deal with all involved individuals in a fair, open and consistent manner.

Emergency Preparedness

Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness or the employer's tertiary (third) lines of defense are those that will be relied on along with the secondary lines of defense when the primary lines of defense which are used to prevent an unwanted release fail to stop the release. Employers will need to decide if they want employees to handle and stop small or minor incidental releases. Whether they wish to mobilize the available resources at the plant and have them brought to bear on a more significant release. Or whether employers want their employees to evacuate the danger area and promptly escape to a preplanned safe zone area, and allow the local community emergency response organizations to handle the release. Or whether the employer wants to use some combination of these actions. Employers will need to select how many different emergency preparedness or tertiary lines of defense they plan to have and then develop the necessary plans and procedures, and appropriately train employees in their emergency duties and responsibilities and then implement these lines of defense.

Employers at a minimum must have an emergency action plan which will facilitate the prompt evacuation of employees when an unwanted release of highly hazardous chemical. This means that the employer will have a plan that will be activated by an alarm system to alert employees when to evacuate and, that employees who are physically impaired, will have the necessary support and assistance to get them to the safe zone as well. The intent of these requirements is to alert and move employees to a safe zone quickly. Delaying alarms or confusing alarms are to be avoided. The use of process control centers or similar process buildings in the process area as safe areas is discouraged. Recent catastrophes have shown that a large life loss has occurred in these structures because of where they have been sited and because they are not necessarily designed to withstand over-pressures from shockwaves resulting from explosions in the process area.

Unwanted incidental releases of highly hazardous chemicals in the process area must be addressed by the employer as to what actions employees are to take. If the employer wants employees to evacuate the area, then the emergency action plan will be activated.

For outdoor processes where wind direction is important for selecting the safe route to a refuge area, the employer should place a wind direction indicator such as a wind sock or pennant at the highest point that can be seen throughout the process area. Employees can move in the direction of cross wind to upwind to gain safe access to the refuge area by knowing the wind direction.

If the employer wants specific employees in the release area to control or stop the minor emergency or incidental release, these actions must be planned for in advance and procedures developed and implemented. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work before they respond to handle an actual release. The employer's training program, including the Hazard Communication standard training is to address the training needs for employees who are expected to handle incidental or minor releases.

Equipment Operation and Maintenance

When the manufacturer's procedures are unavailable, develop, and ensure compliance with, all procedures necessary for the safe operation of the equipment and attachments. [1]

Ensure that procedures for the operational controls are developed by a qualified person. [1]

Ensure that procedures related to the capacity of the equipment are developed and signed by a registered professional engineer familiar with the equipment. [1]

The employer must ensure that safety devices and operational aids that are part of the original equipment are maintained in accordance with manufacturer procedures. [1]

The employer must train each operator, prior to operating the equipment, on the safe operation of the type of equipment the operator will be using. [2]

The employer must train each signal person in the proper use of signals applicable to the use of the equipment. [2]

The employer must ensure that equipment is inspected in accordance with manufacturer procedures. [2]

The employer must ensure that the equipment is designed by a qualified engineer. [2]

Assembly/Disassembly Operations

Before commencing assembly/disassembly operations, the A/D director must ensure that the crew members understand all of the following: [3]

Crew member understanding:

Crew Instructions [3]

Their tasks.
The hazards associated with their tasks.
The hazardous positions/locations that they need to avoid.

During assembly/disassembly operations, before a crew member takes on a different task, or when adding new personnel during the operations, the requirements in paragraphs (d)(1)(i) through (d)(1)(iii) of this section must be met. [3]

Before a crew member goes to a location that is out of view of the operator and is either in, on, or under the equipment, or near the equipment (or load) where the crew member could be injured by movement of the equipment (or load), the crew member must inform the operator that he/she is going to that location. [3]

Where the operator knows that a crew member went to a location covered by paragraph (e)(1) of this section, the operator must not move any part of the equipment (or load) until the operator is informed in accordance with a pre-arranged system of communication that the crew member is in a safe position. [3]