Simply stated, process safety is a management system implemented to prevent major incidents involving hazardous materials. It is necessary for managing complex process operations. An effective process safety management system focuses on three important aspects of your business:
This component includes developing accurate process safety information about your equipment and technology, performing process hazard analyses, developing operating procedures and safe work practices, and then managing changes as they arise. It also includes designing manufacturing processes that are inherently safer from their conception.
This aspect focuses on the mechanical integrity of your plant’s equipment and the software that controls it. It includes preventive maintenance programs, performing pre-startup safety and shut down reviews, and aligns with management of change to help ensure continuous safe operation. Good design and maintenance along with periodic safety reviews protect your company’s means of production.
Involving your employees in building and maintaining your process safety program is the best way to communicate its ongoing importance throughout the organization. This involvement by all, including management, sets the tone for a strong PSM culture.
Other process safety elements involving personnel include training employees in process hazards and their job tasks, managing contractors properly, investigating incidents to understand their root causes, implementing actions to prevent recurrence, preparing for emergencies, planning for effective response, and self-auditing to gauge performance and to identify opportunities for improvement in all three of these process safety categories.
Understanding the skills and knowledge required for a job when making changes in work assignments will help reduce errors and improve safe performance.
The personnel aspect of process safety leads companies to minimize turnover of key personnel at all levels and maximize corporate memory of experiences, best practices, and industry lessons.
Evaluate your PSM effectiveness
The nature of the process related businesses is one that requires a high level of managerial, technical and operational discipline. The discipline practiced when implementing and maintaining a healthy process safety program easily translates to other business areas and helps address other business risks.
Some questions you should consider as part of effectiveness evaluation and improvement area identification are listed below. If you can’t answer any of them or your answers don’t lead you to a conclusion that all is well related to PSM, it may be time to consider an in-depth assessment of the “what’s” and “how’s” of PSM in the organization.
- Is PSM formally documented and adopted?
- Are all PSM documents and audits up to date?
- Are there any overdue action items?
- What trends are showing in the monthly effectiveness metrics?
- Are all trends assessed for risk?
- How is organizational capability, staff and facilities, being ensured?
OSHA and risk-based process safety
Before closing, it is important to note that if your firm has been working on PSM per the requirements outlined the current OSHA PSM regulation, 29 CFR 1910.119, this is a good place to start. However, the industrial learning curve has been very active, and new ideas and concepts on PSM have been offered in the 2007 handbook, Guidelines for Risk Based Process Safety1, published by Wiley and Sons and authored by contributors from the AIChE Center for Chemical Process Safety.
In addition to the 14 elements outlined in the OSHA PSM regulation, the CCPS Risk-Based Process Safety (RBPS) Management System outlines 8 more elements, for a total of 22. There is substantial overlap between the two systems, so one can start with OSHA, and build forward towards a full RBPS implementation. For those who may not be familiar, the key differences between the two are found in the following additional subjects:
- Management system review requirements
- Continuous improvement concepts and practice
- Diagnosing and shifting process safety culture
- Stakeholder outreach processes with communities
- “What designates competence” within process safety management
- Conduct of operations
- Performance assurance following training
- Measurement and metrics
One may argue that the OSHA PSM regulation is adequate for a compliance-driven culture, and that may be true; however, smarter operators have been working to improve the regulation since its early 1990’s introduction.
In summary, process safety management is a key part of any hazardous business operation, and a distinct business case exists. If there are doubts, look at the ultimate costs to any oil and gas company that has had an explosion, fire and environmental release. The costs for cleanup and mitigation of the incident far exceed any amount that would have been reasonably spent in prevention. As Trevor Kletz, the father of process safety once stated, “If you think safety is expensive, try having an accident.”2
Read part 1 from ISHN's October 2018 issue
- Guidelines for Risk Based Process Safety, authored by the AIChE Center for Chemical Process Safety, Wiley and Sons, 2007, 698 pp.
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