PrimoPDF, Job 3

Administering CHRA
Activities Effectively –
A PETRONAS Case Study
CHRA Case Study
Contents
Presentation Objective
Background
PFK’s CHRA
Information on PFK
PFK CHRA Introduction
CHRA Process Flow
Operationalising CHRA
Expectation on CHRA exercise
Findings
Challenges
Advantages / Disadvantages
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CHRA Case Study
Presentation Objective
To share the experience of PETRONAS in
administering / carrying out CHRA in one of the
PETRONAS plant
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CHRA Case Study
Background
All of PETRONAS OPUs have carried out CHRA to a certain extent
either by:
PETRONAS in-house resources
Consultants
The OPUs compliance to the USECHH Regulations 2000, in
particular, CHRA was assessed through:
• CHSE Noise & USECHH Legal Compliance Assessment
carried out in 2002 – 2003
• CHSE Tier-3 HSE Assurance
One of the main findings was quality of CHRA reports varied from
one OPU to another (some was incomplete/insufficient)
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CHRA Case Study
Background
What Are the Common Issues ?
Mistakes in categorizing work unit
Incorrect Hazard Rating for mixture of chemicals
Imprecise description of tasks
Selection of Duration Rating (DR)/ Frequency Rating (FR)
Subjective assessment of Magnitude Rating (MR)
Poor assessment on the adequacy of existing control
Recommendations (e.g. LEV, PPE, Chemical Exposure Monitoring,
Health Surveillance) are too general
Variation in the format of CHRA Report
No mechanism to amend or updating the CHRA report
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CHRA Case Study
Background
What Has Been Done by PETRONAS ?
PETRONAS Industrial Hygienists have reviewed existing CHRA reports
from various Operating Units (OPUs)
Debated and compiled the strengths and weaknesses of the finding
Developed common methodology and approach to carry out CHRA to
ensure high quality of CHRA across PETRONAS
Identified one OPU (PFK SB) as a pilot project to implement PETRONAS
CHRA common methodology and approach
Conducted CHRA Enhancement Training to all PETRONAS CHRA
assessor/ focal person
Implemented CHRA standardization across the group
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CHRA Case Study
PF(K)SB’s CHRA
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CHRA Case Study
Information on PFK
PETRONAS Fertilizer (Kedah) Sdn. Bhd. is a wholly owned
subsidiary of PETRONAS
It is the second PETRONAS fertilizer complex, Commercial
operation started in 1999 in Gurun, Kedah
The daily production capacity of the complex is:
Urea
- 2000 MT
Ammonia
- 1125 MT
Methanol
- 200 MT
Formaldehyde
- 17 MT
Supporting facilities include:
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Steam distribution and generation system
Cooling water
Instrument air
Nitrogen
Waste water treatment plant
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CHRA Case Study
PFK Plant
Urea & Ammonia Plant
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Urea Export Terminal
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CHRA Case Study
PFK CHRA Introduction
CHRA was carried out and reviewed between October –
November 2004
Basic hazards and risk identification data was available prior to
CHRA
It was carried out by PETRONAS in-house resources, utilizing
PFK staff with assistance from Corporate HSE
CHSE apply standardize methodology to carry out CHRA in
ensuring high quality CHRA reports are established in
PETRONAS
The methodology used is as per the “Assessment of the Health
Risks Arising from the Use of Hazardous Chemicals in the
Workplace Manual” (DOSH, 2000)
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CHRA Case Study
CHRA Process Flow
Awareness on the USECHH requirement
Staff attended the
1st
HSE
CHRA training organized by CHSE
HSE
Briefing to PFK MC on CHRA Plan
HSE
Appointment of CHRA Task Force members,
endorsed by HSE Steering Committee
HSE SC
Some of CHRA Task Force members
attended NIOSH CHRA Training
CHRA Task Force
Conducted a series of CHRA Awareness training to staff
HSE
Task Force members carry out CHRA
CHRA Task Force
Review of CHRA findings and CHRA exercise
CHSE/CHRA Task Force
Presentation of CHRA findings to PFK Management
HSE/CHSE
Final preparation of CHRA Report
HSE/CHSE
Submission of CHRA Report to DOSH
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Operationalising CHRA
Members of the task force were selected from areas where
chemicals are used/stored in PFK; and from specific discipline
Co-ordinator
Custodian
Facilitator
OHD
CHRA assessor
Task Force
Utility
Hygiene Tech.
Urea
Engineering
Ammonia
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Lab
Warehouse
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CHRA Case Study
Expectation on CHRA Exercise
CHRA to cover the whole company
Task force members to meet weekly on Friday
To collect data from:
Available CSDS and from suppliers
Hazard register and hazard rating
Chemical spills incident report
Accident reports
Health complaints/surveys
Job safety analysis
Timely report submission to DOSH
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CHRA Case Study
Findings
Clear direction and advice from CHSE made Task Force
members more committed
A comprehensive assessment on the use of chemicals in the
Laboratory
280 chemicals were assessed
The interactions between chemicals were also considered
Detailed description of tasks were developed, enabling the
assessor to identify steps that require special attention
Two options used to fill up Form C (Workplace Assessment):
By “chemical” – traditional method
By “task” – new method
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CHRA Case Study
Findings
Non-routine tasks were assessed through table top
exercises, staff feedback and actual site survey
Shutdown activities were covered during the
exercise, eg.:
Catalyst change-out
Chemical cleaning
Critical plant activities (non-routine jobs) were
identified and evaluated during the exercise:
Breakdown of syngas compressors
Welding activities on a life ammonia reactor
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CHRA Case Study
Findings
Monitoring of chemical exposure were specified based on the
exposure and adequacy of control measures as well as the
availability of monitoring and analysis protocol:
• Welding fume exposure
• IAQ in laboratory
Thorough review of CHRA findings by ROHA enabled specific
tests/ methods to carry out Health Surveillance, Medical
Surveillance and Biological Monitoring were proposed:
• Eg. Visual assessment (fundoscopy) was proposed for Lab
technicians performing Methanol product sampling
• Eg. Spirometry and chest x-ray was specified for MIG/TIG
welders
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CHRA Case Study
Findings
Format of “Summary Report of CHRA” (for DOSH submission)
were modified:
• Expanding “Recommendation” column to specifically to PPE,
Exposure Monitoring, Health Surveillance, and Biological
Monitoring
• This will allow various sections to pick up actions required by
their sides to close the CHRA gaps identified
Format of “Final CHRA Report” were proposed and has been
accepted by PETRONAS to be standard format to be used across
PETRONAS OPUs
The integration of CHRA with the Hazard and Effect Register as
per the HEMP (Hazard and Effect Management Process)
Procedure
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CHRA Case Study
Challenges
Availability of task force members:
Most of the team members were line people, whose core functions
are non-HSE
CHRA was not included as part of their KPI
Transfer of trained assessor(s) from PFK
Lack of training/experience of team members; Some has not
attended CHRA training
Poor planning which delayed the CHRA report submission to
DOSH
Incomplete information (eg. CSDS to determine hazard rating)
To carry out table top exercise for non-routine jobs
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Advantages and Disadvantages of Using Internal
Resources
The advantages were:
Cost savings
Better understanding of work processes
Ownership
Hands on experience on conducting CHRA
The disadvantages were:
Time consuming, resulted in delayed project
Limited expertise to conduct CHRA
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