During tough economic times many companies reduce their head count either by layoffs or by not replacing personnel who have retired or quit. One of the most affected areas is process safety management (PSM) because lots of firms don't consider the function of the PSM manager or coordinator as critical. Instead, they only view it as a way to incrementally improve process safety performance, mainly to decrease the probability of a regulatory mishap or provide a better corporate image rather than to actually reduce the chances of a serious incident.
Although day-to-day application of process safety principles is line management's responsibility, such managers often lack the essential specialized knowledge of the "why" and "how" of some intermittent activities, e.g., process hazard analysis (PHA), safety analysis in management of change (MOC) and incident investigation. A process safety professional who can tie all these elements together is really needed.
Large and medium-sized companies often can afford such a professional, especially if the person serves as PSM coordinator for many sites. However, small and some medium-sized firms can't justify such a position. They treat PSM as a part-time job to be handled by the environmental, health and safety (EHS) coordinator or a process engineer with some knowledge of process safety.
Many small companies downplay PSM because they view it as non-essential to their business. So, they only dedicate enough resources to PSM to meet regulatory burdens. Some very small companies don't even attempt to address PSM but just try to stay under the U.S. Occupational Safety and Health Administration's radar. This stems from a lack of understanding of the potential impact of not following a process safety program and a fear of the expenses involved in such a program
So, not surprisingly, significant safety incidents continue to occur at plants, and many sites still pose a high potential for catastrophic events.
PREVALENT PROBLEMS
The most common deficiencies in process safety affecting small companies (and many others as well) are:
• Deficient or non-existent MOC. This leads to perfunctory safety analyses, overextended temporary changes, etc.
• Inadequate PHAs. Risk identification and evaluation, etc., are poor.
• No refresher training. Although procedures may exist, personnel don't periodically review them.
• Poor process safety information (PSI). Essential details can't be found or are incorrect or out of date.
Another area where all companies seem to be deficient to a certain degree is mechanical integrity (MI) [1], which remains a common underlying cause of many incidents.
Although all aspects of PSM deserve attention, these areas should get priority and constant review. The challenge is doing this effectively when a company lacks adequate expertise and only can provide modest if not meager resources.
COPING WITH LIMITED RESOURCES
Ensuring smooth operation of a process facility on a daily basis requires at a minimum:
• Operating procedures. The plant can't run unless operators know what to do.
• Trained operators. Operating procedures provide the basis for training.
• Good maintenance. This minimizes outages and maximizes production.
• Safety practices. Preventing incidents and injuries during regular work demands lockout/tagout, hot work permits and other practices.
• Contractor selection. It's important to use only well-trained and safety-conscious contractors.
A good manager will put resources into these areas without question. Other process-safety-related areas may receive less or no attention because they don't seem necessary to the daily running of the plant. So, how do we maximize process safety with minimum resources when a manager is reluctant to hire people to perform the needed activities?
The way to do it is by integrating process safety into operations by making it a line responsibility of the operations manager. The manager will have to become knowledgeable in what's needed to avoid incidents that could injure people or damage the facility. This doesn't mean the manager will have all the technical details on how to implement the process safety program.
A process safety coordinator could provide the expertise and coordinate all the activities — but isn't an absolute necessity. When a permanent position isn't viable, a plant still can fulfill the needs of a process safety program on a continuous basis. Let's look at how to accomplish this for key aspects:
Mechanical integrity. Many plants are adept at the maintenance component of MI but less so at the inspections component, which requires expertise and continuous application. There are firms that provide this service and also take care of the documentation to satisfy regulatory requirements. For example, use of risk-based inspection can help reduce the resources necessary to maintain a good inspection program. Adding maintenance and testing data to an asset database assists in complying with the required frequency of maintenance, decreases the risk of failure, and can help maintain the integrity of instrumentation vital to safety instrumented systems (SIS).
Management of change. This must be well executed to avoid creating or increasing risk to the facility. An effective MOC program requires few resources if implemented correctly and the proper tools are used. These tools should automatically manage the mechanics of the system, including documenting all actions and storing all information, and provide immediate easy-to-understand feedback (such as via graphics), thus allowing site management to concentrate on the quality of the system. It's important to track the number of open and past-due MOCs because they increase the risk to the facility [2]. You can download a demo of a database that fulfills these requirements [3].
Process hazards analyses. If a company doesn't have the expertise to perform a PHA, it can hire a facilitator. However, if the PHA is to succeed, the site must ensure an experienced engineer and a veteran operator are given the time to fully participate. Moreover, the plant must immediately address recommendations coming out of the PHA and implement any accepted changes in its work order system. Lingering action items can only increase risk to the facility. This is an area in which, if in-house resources don't suffice, contracting out may be justified. The facility should use the PHA report as a learning tool and check it when doing an MOC to avoid negating a PHA recommendation.
Process safety information. The PSI should build on the maintenance files and existing process and instrumentation drawings (P&IDs). To ease keeping the system current long term, the plant should require good documentation as part of each contracted activity. Updating P&IDs and equipment files usually demands the largest effort to maintain the PSI. The plant also could contract this out if a large number of changes aren't likely. For a site with many changes and limited resources, a document management system could provide the answer [4, 5] — such systems now are within the means of small companies.
Safety culture. Establishing a good safety culture should reduce the effort of managing process safety because everybody will have a responsibility for safety [6]. Integrating process safety into operations and having line management accountable for everyday and long-term safety shows that management is "walking the walk" and not just "talking the talk." In addition, a plant should consider expanding occupational safety programs and activities such as "toolbox" meetings to include the topic of process safety.
Regulations. A plant should run the PSM system not just to comply with regulations but also to enhance safety in the short and long terms. Implementing a good PSM system will lead to satisfying the regulations but the opposite isn't true. Just complying with regulations may not result in a safe plant. A site should judiciously apply recognized and regularly applied good engineering practices (RAGAGEP); their complexity may thwart safety in the absence of sufficient knowledge or resources.
Finally, a plant also must address other, less frequently occurring process safety aspects such as emergency planning, audits and incident investigation. However, they take much less continuing effort (and, if PSM is successful, there should be no incidents to investigate). The plant also can contract out these parts, eliminating the need for local expertise. Of course, personnel will have to be well trained on the emergency plan and participate in the drills.
BOLSTER SAFETY
Lack of resources shouldn't keep a company from implementing an effective PSM system. The guidelines detailed in this article can lead to a well-functioning process safety system that uses fewer resources.
JACK CHOSNEK, PhD, PE, is president and principal of KnowledgeOne, Houston. E-mail him at [email protected].
REFERENCES
1. Mannan, M.S., "Advantages and Pitfalls of Mechanical Integrity Programs," Meridium APM Advisor, Aug. 2011 (online at www.apmadvisor.com).
2. Chosnek, J., "Managing Management of Change," Process Safety Progress, p. 384, Dec. 2010.
3. "The Great MOC Solution," www.knowledge1.net/psm/Downloads.html.
4. Chosnek, J., "Maintaining the Corporate Memory," J. of Loss Prevention in the Process Industries, p. 796, Vol. 23 (2010). Also in Proceedings, Mary Kay O'Connor Process Safety Center Intl. Symp., Oct. 2009.
5. Chosnek, J., "Organizing Knowledge for Improved Process Safety," Proceedings, Mary Kay O'Connor Process Safety Center Intl. Symp., Oct. 2008.
6. Gambrell, M.R., "Make Safety Second Nature," Chemical Processing, p. 29, Oct. 2011.
