PSM Program Development
West Texas, USA
M&H was contracted to develop a Process Safety Management (PSM) program for a liquid handling facility located in West Texas. M&H worked with the operator to determine if the facility falls under the oversight of PSM and then developed all required documentation and training in order to comply with 29 CFR 1910.119.
The PSM program consists of 14 elements. The elements listed can be found in 29 CFR 1910.119.
M&H developed a complete PSM program that fully complies with all elements of 29 CFR 1910.119. Along with the overall program document, M&H developed individual documents and other required forms and programs to ensure the facility is in compliance.
- Employee participation
- Process safety information
- Process hazards analysis
- Operating procedures
- Pre-startup safety review
- Mechanical integrity
- Hot work permit
- Management of change
- Incident investigation
- Emergency planning and response
- Compliance audits
- Trade secrets
Acquisition Due Diligence Support
West Texas USA
M&H was contracted to provide due diligence to a midstream company during their acquisition of a facility located in West Texas. The facility consisted of a pipeline gathering system, nine compressor stations, and one process plant. A review of all available facility documentation including: design specs, pipeline MAOP calculations, ProMax process model, NACE documentation, and other process safety information. In addition, M&H reviewed the facility corrosion monitoring program, all regulatory compliance items, and the mechanical integrity program.
M&H provided a report summarizing findings and providing recommendations. This report was used by the purchasing company during the final evaluation of the facility.
PSM Program Development
Southeast New Mexico, USA
M&H was contracted to develop a PSM program based on the 14 elements of 29 CFR 1910.119. In addition, the program was developed based on the following industry best practices and standards:.
- Code of Federal Regulations 49 CFR 192 – Transportation of Natural and Other Gas by Pipeline, Subpart L – Operations and Subpart N – Qualification of Pipeline Personnel;
- Code of Federal Regulations 49 CFR 195 – Transportation of Hazardous Liquids by Pipeline, Subpart A – General, Subpart B – Annual, Accident, and safety-related condition reporting, Subpart C – Design Requirements; and
- State regulatory and local municipal requirements where operations will take place.
M&H developed a written process safety information plan, process hazards analysis plan, contractor plan, PSSR plan, hot work permit plan, management of change plan, incident investigation plan and procedure, emergency response plan, and audit plan that complied with the requirements of 29 CFR 1910.119.
As part of the overall PSM program, M&H developed a maintenance integrity program, including the establishment of a CMMS system and maintenance procedures that covered all key equipment, including:
- Pressure vessels and storage tanks
- Piping systems
- Relief and vent systems and devices
- Emergency shutdown systems