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website:  MLMeng.com
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Services & Capabilities
Process Operations Management

Companies that handle certain highly hazardous chemicals in excess of threshold quantities must comply with OSHA's Process Safety Management (PSM) standard, 29 CFR 1910.119 and EPA's Risk Management (RM) Program rule, 40 CFR Part 68.

These regulations are performance-based and compliance with them is quite different from specification-based regulations that spell out requirements. For PSM and RMP many decisions must be made by companies on how to meet the regulatory requirements and what levels of performance are appropriate. As technical improvements are made, OSHA's and EPA's expectations for performance increase. Companies must stay abreast of these developments and adjust their programs accordingly. Many companies find it is more cost effective to seek outside expertise when doing so.

MLM & Associates Engineering, Inc. (MLM) develops complete PSM and Prevention Programs for clients covering all elements of the regulations. Typically, this is done for new facilities or expanded facilities that come under coverage by PSM and/or RMP.

MLM also assists companies in improving their existing programs. This work usually involves an initial assessment of the existing program to identify areas for improvement. Sometimes companies may have a sound PSM program design, but may be struggling with implementing it. MLM's extensive PSM experience enables us to provide implementation guidance to clients in such situations.

MLM also helps clients improve specific elements of their PSM programs. For example, we help clients fine tune mechanical integrity, management of change, and other programs that are part of PSM.

MLM has developed guidelines for all PSM elements:

  • Employee Participation
  • Process Safety Information
  • Process Hazard Analysis
  • Operating Procedures
  • Training
  • Compliance Audits
  • Trade Secrets
  • Mechanical Integrity
  • Hot Work Permits
  • Management of Change
  • Incident Investigation
  • Contractors
  • Pre-Startup Safety Review
  • Emergency Planning and Response

Procedures Development

Written procedures are required by OSHA's Process Safety Management Standard, CFR 1910.119. Contemporary engineering standards also place a heavy emphasis on having comprehensive, up-to-date procedures and training the employees who use them. Indeed, the development and use of effective and user-friendly operating and maintenance procedures in process facilities is essential for safe and efficient operations.

Procedures can have as much impact on process safety as the process equipment. The Operating Procedures element of the Process Safety Management Standard is one of the most frequently cited elements by OSHA year-after-year and therefore deserves special attention to ensure compliance.

Many companies assume their employees can write procedures simply by documenting what they do. However, this approach often produces ineffective procedures. There are much better approaches that can be used to write procedures that do not require any more work than the traditional "write what you do" approach. These new methods produce procedures that are much more effective and usable.

Procedures that are properly written, documented and followed help to ensure that the knowledge required to safely operate processes and equipment is made available to the appropriate operating and maintenance personnel, management, emergency response and preparedness teams, safety personnel and others.

MLM helps clients decide when and where procedures are needed. We help design and develop procedures according to established principles and best practices to ensure they are written for their users. We also help ensure regulatory requirements for procedures are met. While much of our work focuses on operating and maintenance procedures, we also help clients develop other facility procedures such as Safe Work Practices, Emergency Procedures, and Safety Procedures.

MLM helps clients develop new procedures as well as revise existing procedures to meet current standards. We also advise clients on procedure maintenance, control and training.

MLM works with clients interactively to develop procedures. We encourage the active participation of those who will use the procedures. Procedure users provide information on the actions required in the procedures and MLM casts this information into a format that helps ensure usability.

Guidelines for drafting, evaluating and validating procedures are used. We also follow guidelines to ensure the appropriate use of language, numerical information, graphics, and lists and tables. Special types of procedural steps such as non-sequential, continuous or time-dependent are properly formulated.

MLM is experienced in both developing procedures and assessing existing procedures. We understand the regulatory requirements for procedures and current industry standards for procedures development.

Process Hazard Analysis

Process Hazard Analysis (PHA) studies are the foundation for process safety and risk management of highly hazardous process systems. They help companies identify hazard scenarios that could adversely affect people, property, or the environment. Companies that handle or process hazardous chemicals have a responsibility to protect employees, the public and the environment from exposure to accidental releases.

Considering the complexity of today's chemical processes, the challenges involved in facilitating a PHA study, and the potential liabilities from an incident, your best option for completing PHA’s may be to seek the assistance of expert specialists.

MLM uses predictive PHA techniques and methodologies such as Hazard and Operability Studies (HAZOP), What-If Studies, and Failure Modes and Effects Analysis (FMEA) and Major Hazard Analysis (MHA). MLM provides a team leader or facilitator to work with a group of people from the facility to conduct the PHA. We document the PHA study findings and prepare a report on the study. We can also provide a scribe to assist with study documentation, if desired by the client.

We facilitate both initial PHAs and revalidations of existing PHAs.

MLM's PHA expert:

  • Prepares for the study
  • Advises on the selection of team members and methodology and the definition of study scope
  • Oversees the team's brainstorming of causes and consequences of possible accidents and the formulation of recommendations for appropriate corrective actions.