FRP Management: Corporate Guidelines and Process Safety Management

Overview
Over the past decade, many industrial companies have eliminated or greatly reduced their internal capability to manage engineered materials. For specialty materials such as FRP, where vendor capability and economic results can vary significantly, this lack of user knowledge can present particular challenges. To assist companies that use FRP equipment and piping, FSE develops corporate guidelines and specifications to ensure adequate design and fabrication criteria.

Services Provided
Since 1976, FSE has developed design, specifications and inspection services to assist the industrial community in obtaining quality FRP equipment for their plants. Important activities in which FSE has participated recently include the development and implementation of corporate guidelines, specifications and training.

These activities bring to bear FSE's experience as well as its capability to tailor a service to meet the specific needs of a client corporation. Some of the activities included in corporate services are:

• Specification and design guidelines, including establishment of design criteria for specific equipment and piping, development of required design submittal information and calculations, determination of allowable physical property values for appropriate laminate construction as well as determination of appropriate materials for construction and laminate sequences for specific applications.
• Quality control guidelines include a specific strategy for inspection and testing of in-process and completed FRP equipment and piping to ensure conformance to the user's requirements. The guideline addresses documentation, test variances, inspection and test methods.
• Preventive maintenance (PM) and Process Safety Management (PSM) guidelines for frequency and scope of initial and on-going inspections, including documentation and reporting requirements to ensure continued safe operation of FRP.
• Seminars for corporate and plant personnel in engineering issues, procurement practices, basic inspection techniques including non-destructive testing (NDT), preventive maintenance (PM) and process safety management (PSM) programs for FRP equipment, ducting and piping.

Process Safety Management Services

Overview
FSE has implemented Preventive Maintenance programs for FRP equipment in many industrial facilities over the last 30 years. FSE structures reporting procedures and inspection and testing methods to align with specific elements of OSHA's Process Safety Management (PSM) standard, 1910.119.

The purpose of OSHA's PSM standard is to prevent or minimize the consequences of catastrophic releases of hazardous chemicals. FSE can contribute to the owner's total compliance program by ensuring the mechanical integrity and ongoing suitability for service of existing and new FRP storage tanks, process vessels, piping and ducting systems.

OSHA 1910.119 requires that the owner document that the equipment complies with recognized and generally accepted good engineering practices. With FRP equipment, this means having experience with the specialized inspection procedures and engineering concepts required to appropriately evaluate FRP equipment. FSE is the recognized industry leader in providing the full integration of these FRP engineering services.

Who is Required to Implement Process Safety Management?
The OSHA PSM regulations apply to any workplace where highly hazardous chemicals (HHCs) are used, stored, manufactured, handled, processed or moved on site. The only exceptions are retail facilities, oil or gas well drilling or servicing operations, or normally unoccupied remote facilities.

HHCs include:

• Toxic or reactive chemicals that are present at or above their designated threshold planning quantity.
• Flammable liquids or gases in quantities of 10,000 pounds or more in one location, except:
  • Hydrocarbon fuels used solely at the workplace, unless they are part of a process containing another HHC and
  • Flammable liquids that are kept below their atmospheric boiling point without benefit of chilling or refrigeration

FSE Process Safety Management Consulting Services Provided
With over 30 years of experience in the field, FSE provides the full spectrum of FRP engineering, inspection and testing services. Each service is important to your PSM program, especially your mechanical integrity compliance program.

These basic services include engineering and design, project management, contractor qualification, training of plant personnel in basic inspection techniques and basic repairs, quality assurance inspection and a fully developed planned maintenance program for your fiber reinforced plastic (FRP) process equipment. All of these services are integrated by an experienced FSE engineering team.

The OSHA PSM program contains 14 main points. FSE has targeted 9 of these areas of compliance support for FRP equipment and can provide them to the owner. These 9 areas are:

• Process Safety Information
• Process Hazard Analysis
• Operating Procedures
• Contractors
• Pre-startup Safety Reviews
• Mechanical Integrity
• Management of Change
• Incident Investigation
• Emergency Planning and Response

Objectives and Benefits of Process Safety Management
The primary objective of PSM is to reduce the number of fatalities and injuries resulting from catastrophic releases of hazardous substances. Other potential benefits to the owner include:

• Enhanced productivity due to fewer process disruptions and accidental shutdowns
• Decreased labor turnover due to a safer work environment
• More efficient utilization of space, labor and equipment as a result of required plant reviews, leading to potential operating and product cost savings
• An improved, integrated approach to process design, construction, operation and maintenance, with process safety as the central focus of concern
• More consistent product quality
• Lower insurance premiums

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