2024 Mar-Apr RETA Breeze

It’s a question we hear often – some times as part of a PHA or Compli ance Audit, but more often with someone just struggling to justify their staffing requests. Unfortunate ly, there really isn’t a simple, definitive answer to the question. No controlling RAGAGEP exists and state / local laws on the topic are relatively rare. This sort of problem isn’t rare in PSM because it is a performance-based standard. Our performance basis is that we are staffed sufficiently to ensure the safety of the people within the building and the surrounding community. We need to answer the “How many Operators do we need?” question in a way that we can support it, or as we like to say, “Build a defensible case for the answer we arrive at. The answer itself will depend on many, many factors. So let’s go a journey and see how we can arrive at an answer we can feel confident in. HOW MANY OPERATORS DO WE NEED?

THE ROAD TO AN ANSWER Let’s be honest, if things are running well; you have a good history with compliance audits, inspections, incident investigations, etc. and a low MI backlog, you’re probably not asking this question. If you are asking this question, it is probably due to an event related to a PSM/RMP element. Let’s look at the kinds of events that typically lead to this question. • Mechanical Integrity • Incident Investigations • Management of Change / Pre-Startup Safety Review Emergency Action and Response Plans Mechanical Integrity: What we’re looking for here is to understand if you have the skill sets and staffing to • • Process Hazard Analysis

adequately maintain your refrigeration system. Whether you do everything in-house, or have a small in-house crew performing basic rounds and contract out all the rest of the maintenance, inspections, and tests, is it adequate? Here’s some MI related questions you might ask to help you determine if your staffing is adequate: • Are we properly implementing our Line & Equipment Opening (sometimes known as line break) procedures? • Are we caught up on ITPMR’s (Inspection, Test and Preventative Maintenance Reports) or work orders? • Is the documentation of ITPMR’s, Work orders, Oil Logs adequate? Are we performing our scheduled walk-through’s and documenting them properly? •

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