Podcast: World’s First Process Safety Management Standard

Traci: Well, before we launch into our topic, I do want to point out that the three of us have an Olympics connection. All three of our countries won medals in the women's pole vaulting. Australia took gold. U.S. took silver, and a little shout-out to my alma mater, Olmsted Falls, where the silver medalist Katie Moon is from. And Canada earned the bronze medal. So, in addition to being on Process Safety With Trish & Traci, we have victory at the 2024 Paris Olympics in common. So, I wanted to point that out. And Trish, do you have any commentary on the Olympics?

Trish: Look, being a true Aussie, we absolutely love our sport, and it is that one time every four years where Australians get really, really excited about being Aussies and getting out there and supporting them. And a shout-out to the Australian Olympic team. Fantastic effort at this last Olympics. Our best result ever finishing fourth on the medal table with more gold than we've ever earned in Olympics as well, so pretty proud Australian at the moment.

How The Canadian Process Safety Standard Came To Be

Traci: Well, good. Yeah, it was fun to watch for sure. Well, let's go ahead and get back to process safety and just to set the groundwork for us. Adrian and Parnian, can you give us some background on how the CSA Z767 standard came to be?

Adrian: Sure. I'll correct you just a little bit. Here, in Canada, we refer to it as Zed 767. So, one of the things that we don't have in common is the way we pronounce that letter that I happen to have in my last name, so I totally get it, bilingual and all that.

The Z767 standard really started off, the history of it goes all the way back to the beginning of PSM. As we started seeing a lot of countries coming into PSM regulation, Canada had a very different approach and it might be a story for another day.

And we ended up with a group under the Process Safety Management Division of the Canadian Society for Chemical Engineering. Sorry, lots of words there. Ended up with all the intellectual property for the guidelines for process safety in the country. And as the regulators started to look at how to come up with regulations, we found they were pulling from lots of other countries, the U.S., the UK, other places, and we wanted to try and establish a context for process safety in Canada.

And so, the Process Safety Management Division, PSMD, wrote a SEED document, and we actually made it a standard of the Society for Chemical Engineering in Canada. And then, we took that to the Canadian Standards Association, CSA, and funded the development of a national standard. And so, over the last eight years, I guess, we've been developing and continuing to develop the standard Z767, which defines what process safety management is for Canada.

Traci: Parnian, do you have anything to add?

Parnian: No, it's just that history is sort of... It does extend really far back, but really since it has become a national standard, it's just really given it the opportunity to get more of a spotlight. It's getting more attention than it was getting probably in its original version that the PSM division wrote. But certainly, the history is how it's very interesting and it's been growing also.

Adrian: Yeah, I think what makes it interesting and unique, and I'm sorry to jump back in there, is really that it was written specifically for regulators to adopt because we were lagging in terms of regulation. And so, rather than having each regulator come up with their own flavor of what PSM was, we wanted to create a document they could just incorporate by reference.

I know that's not completely unique for standards, but it was written as a way to merge together all the different jurisdictions. We have some counties that have their own rules. We have some provinces that had their own rules equivalent to states. We have federal jurisdiction. We have some cities that had their own rules.

So, we really wanted to get ahead of it and put out that this is what PSM means because we were otherwise in this awkward spot of having Canadian regulators trying to point to U.S. regulations or Australian regulations or UK regulations. And it's kind of odd to incorporate another country's regulations by reference.

Industry Input Leads To Updated Safety Standard

Traci: And it's important to have that continuity, for sure. Let's talk a little bit. The first standard came out in 2017, and then just recently this year we have the second edition of this standard. Why was it updated and what do the updates entail?

Parnian: I'll start us off on this one. The original document was the best we could put out and the timeline that it's always the first version of anything could always be better. So, that's kind of what the first edition was. It was the best thing that we could have put together at that time based on all the restrictions that the committee was working with at that time.

Obviously, as people start trying to actually work with the standard and use it in different industries, like Adrian said, the Canadian standard is not limited to any particular industry. So, definitely based on my experience, I worked for a large oil and gas distribution company in Canada, and as I tried to implement them, I ran into a large number of questions, aspects that were confusing, aspects that didn't line up with my understanding of process safety, and that type of feedback is what came back to the committee.

So, it was a lot of public feedback, a lot of members that just had experience starting to try to use the standard. Those are the bases really for the changes that would've come for the second edition. Some of the major changes, and you can see that if you have a look at the copy of the standard, are summarized at the beginning.

But the most important changes probably would be expanding some of the sections on conduct of operations, so that it now includes operational discipline a little better aligned with, if you're familiar with the CCPS American guidelines, the expansion and renaming of one of the elements around risk management so that it's a little more comprehensive. Now, it provides more detailed explanations of how to do a strong risk assessment, and what its revalidation means, and how that could be done.

And then, probably one of the most major changes is the complete rewriting on the clause on human factors. We had experts that really helped us dig a little deeper and think in the first edition, just we worked with the best that we could get together at that time. And I think the second edition just gave us the time that we needed to start trying to incorporate a little bit more expertise into it, expand it, explain it better because at least in my personal experience, not a lot of process safety engineers truly understand how to do human factors, and they don't quite embrace it the way that they could.

So, these were some of the major changes really that we're going to see in the second edition and hopefully it'll make it easier for people to implement, a little more auditable, a little more guideline like.

Traci: And how has industry embraced this standard?

Parnian: Like I said, I just left an operating company in the oil and gas sector, and I was there for about six years. At the time when I was there, the first edition was out, and I ended up getting involved in the development of the second edition. And during that time, I started trying to use the standard, and the change that I saw over the six years in that sector is really what we're seeing in all of Canada.

In that sector, at the beginning, there was a very slow uptake. It was very difficult for people to even understand what the standard is about. They kind of look at it, shake their heads and look away. And over the course of the last six years, the atmosphere has really changed. It's being taken a little more and more seriously over the course of that time. At some point, it started being used as a reference document by one of the key regulators, which brought it a little more to the spotlight.

As people learned more about this standard, they started taking it more seriously. The way that the 767 standard is written, the vocabulary is not very chemical industry oriented, so it makes it easier for like, oil and gas sector is just a little different. They use a slightly different vocabulary. And that really helped them to better apply that standard probably than they would have, say, they tried to use the OSHA American guidelines.

And so, over time, it has been adopted by one of the regulators out west for the sector and that has really changed the tone of the conversation completely. People are now looking at the standard more seriously. They're trying to figure out how to use it. There's people actually using the word process safety management, which is completely new compared to six years ago. So, it's evolving, it's coming, and I think the same probably is happening in other sectors. I don't know, Adrian, if you can expand on others that have been using it.

Adrian: Yeah, I think actually it's interesting. I think Parnian said earlier that we tried to write the standards so that they are industry agnostic. The U.S. OSHA PSM is really focused primarily on chemical energy sectors. And then, there's threshold quantities, and we wrote this standard so that it was a framework that was agnostic to the hazard or hazardous energy being controlled. So, we've had members from a variety of industries including mining, conventional occupational safety. We've had all different communities involved.

What I've seen is some of the regulators that you wouldn't necessarily expect starting to pick it up. We have a regulator that was looking to try and apply PSM concepts to elevators and escalators. We have an application where they're looking at it for what you would call the state's power engineers or we call here operating engineers, the ones who run power boilers and large-scale compressors. I know Parnian has touched on pipelines and so on, and these are all things that aren't necessarily directly covered by PSM in what some people consider more traditional industries.

What Does a Process Safety Management Standard Mean for the Rest of the World?

Traci: Trish, what are your thoughts and what does having a PSM standard mean for the rest of the world?

Trish: We were quite excited to discover this work happening in Canada because, to my knowledge, this is the only national standard as opposed to legislation for process safety anywhere in the world. And the beauty of a standard is that it sets the bar for, as Adrian and Parnian have described, a whole lot of industries to look at.

And I think that's really important because in a lot of different jurisdictions around the world, where there something is deemed to be... So, in the US, whether it's PSM requirement or whether in the safety case sort of performance-based legislation, whether a facility is deemed to be a major hazard facility, there's a whole lot of different facilities and organizations out there that have significant process safety risk that actually don't get covered under a lot of this legislation because they're just below the thresholds or they just don't meet the technical requirement, yet they can still have quite a significant incident.

As an example, a few weeks ago in Melbourne, there was a fire in a factory, and it was a chemical tolling factory. So, they make all sorts of weird and wonderful chemicals in this particular plant, but it's not covered under a major hazard laws because they don't have enough quantities of hazardous substances. However, it burnt for quite some time. It created quite a significant environmental impact as it burnt, took a lot of firefighting resources to bring it under control. Fortunately, no one was killed in the incident, but it was still quite a significant process safety event not covered under our MHF laws.

So, the idea of having these standards, I think, is really important because it sets the benchmark for organizations and particularly having a standards association endorsed one is even better because then we can go down the path of companies can get certified against it.

I'm sure you're familiar with a lot of organizations that are certified to ISO 9001 quality management systems and the like. Well, this is a process safety management system that we can actually now get certified against, certainly from the Canadian perspective. And it's also important, as both Adrian and Parnian have said, that because it is this industry agnostic, the principles that are involved and contained in this standard can be applied to a wide range of industries.

Now, Traci, you and I have talked about that tragic theme park event that happened in the Gold Coast in Australia where four people were killed on a ride. What actually ended up occurring there is the regulator said actually theme parks need to work to process safety standards and major hazard facility legislation. And so now, in the state of Queensland in Australia, every theme park ride has to have its own safety case and be assessed through a safety case-type regime. This sort of standard allows those concepts to be applied to all sorts of different sectors that is going to deliver safer workplaces all over the world.

Adrian: All right. Yeah, I think building on what Trish said, actually here in Canada, one of our more recent landmark incidents was actually a skating rink. There was an ammonia release in British Columbia, so it was near residential. And again, skating rinks typically wouldn't fall within the jurisdiction of PSM regime in a lot of places. It's not a traditional chemical processing facility, but you can imagine what could have happened if the rink was full at the time or if it had gotten out of the mechanical room. I think that there's a lot of interesting lessons that I know Trish and I have talked about over time about applying this to non-traditional industries.

IChemE’s Push for a Safety Standard

Traci: Trish, I know you had mentioned that the IChemE is pushing to have a standard developed. Can you explain the reasons why and how Z767 will help move that forward?

Trish: Yeah. A few years ago, some IChemE members started to speak publicly about the need for a standard in process safety management, and they presented some conference papers and through IChemE's major hazards committee, those members are actually involved in that committee. And we've picked that up and sort of said, "We do think this is something important," and I've put those people in touch with Adrian and Parnian to really understand some of the CSA processes and history that went on behind it.

So, when our committee speaking with British standards, BSI, to look at, "Okay, what can we do to progress through potentially a BSI, but also pushing to get it to the ISO level?" So, the International Standards Organization. Now, the fact that a country's standards association has already created one of these, hopefully makes our path a little bit smoother because we're not talking about something wildly crazy to do. After all Canada's done it, why can't other countries do it?

So, we're talking to BSI around potentially how can we get that process started through the British standards to then really push further for ISO because, as I said, we do think it is an important way to set a baseline for companies and make it really clear what needs to be done for those organizations that still have significant risk but don't get picked up in the traditional legislative framework at the level that perhaps we'd like them to be. That's why we think it's important and that's why we were very pleased of the Canadian progress. I put these groups in contact with each other and, hopefully, we can get a good global outcome here.

Unified Process Safety Standard Benefits

Adrian: What really excites me about that one is that it would make it much easier for companies that operate multinationally to have a unified PSM system. And the thing about having a standard-based system is that the standard can continue to grow and evolve with lessons learned over time.

OSHA was 14 elements and CCPS is now up to 20, and there's all different elements in different places and it's organized a lot of it based on incidents that occur. And so, by having standard, especially at the ISO level or wherever it is, then we have that opportunity to continue to grow and evolve and for regulators around the world to stay somewhat synchronized in terms of what these systems need to look like around the world. It's a great vision.

Does a Safety Standard Matter When Legislation is Already in Place?

Traci: Now, you mentioned the folks that aren't covered under traditional legislative framework. What about those that do have legislation? Does the standard matter when legislation is already in place?

Adrian: I think it does matter for two reasons. One is because it's a national standard, the regulators, at least in Canada, are paying attention to the standard. A lot of times for them to write regulation or update regulation, they're in a situation where they need to get some sort of legislative assembly involved in getting changes approved or secretary or minister depending on what country you're in.

And so, I think it matters to them because it actually reduces the effort for them so they can update their regulations using a national standard. And because it's a consensus standard, it makes it easier for them to implement. But if you take it away from that side, even if there's regulations involved, given that the standard is a national standard, it falls under the recognized and generally accepted good engineering practice.

It does have force in civil courts in standard practice. It becomes part of the duty of care for those in the country who say they're doing PSM that they need to defend why, what they're doing is PSM. And if the standard says it's what we say it is, then I think it still has some authority.

Trish: And if I think about the regimes that I'm more familiar with, so where we do have the performance-based, safety case-type legislation, there's a couple of ways that standards come into play in that instance. It is possible for legislation to actually call up and reference a standard. And when that actually happens within the legislative frameworks, that actually makes the standard de facto law. If the standard is called up in legislation, then it actually becomes effectively legislation at that point.

But more importantly, when it's not called up in legislation, we actually see it becoming this state of knowledge, as Adrian said. So, a lot of our safety case-type laws around the world are not only based on what you know about how to manage the hazard, but what you ought to reasonably know as well. And so, in this instance, this standard actually gives a very clear framework of what you ought to reasonably know.

And so, from that perspective, it actually starts to create some consistency so that regulators could actually look at it and say, well, this standard does exist. Therefore, you can't claim you didn't know it was a good idea to do X, Y, and Z. It's there in the standard. So, it's obviously common established knowledge at that point in time. Therefore, you ought to have followed it.

So, you can choose not to follow a standard in the performance-based regime, but the moment you choose not to follow an established standard, you want to have a really good reason for not following it because it's state of knowledge. And why would you not follow what was state of knowledge?

Traci: That brings up a good point. They cannot be followed. Folks can choose not to follow them. What happens then?

Trish: So, from a performance-based regime, it's very simply that if you choose not to follow it, then you could be questioned by the regulator as to why. And you'd need a very good justification because you could be found to have not been using the appropriate knowledge to manage the hazards that you should have. You could still actually face some issues if you choose to ignore a relevant standard. You could certainly still be prosecuted in a performance-based regime for ignoring standards.

Challenges Creating a Process Safety Standard

Traci: Adrian and Parnian, what were the challenges that you faced when drafting and implementing this?

Adrian: I'll take the lead again. I think I was with the committee for a little longer. The challenge that we had was we had a fully matrixed committee, and anyone who's worked with standards development has a sense of what that means. And so, we had a lot of different stakeholders at the table, and everyone had a slightly different perspective on what PSM means.

And it's interesting because you think that it's pretty simple to define terms, but again, if you've ever worked in the standards world, you know how hard it can be. And since we were starting as a clean page reboot, we know what it says in other places, but what should it say was actually a very interesting exercise.

The other part that was interesting about the discussion was what we've touched on before, was really trying to keep it industry agnostic. We kept talking about is it scalable? Can it apply to a small operation like a hockey arena as well as to the traditional large-scale refineries, petrochemical plants? Will it apply equally to a subsurface mine as to a railroad? As to a pipeline?

And so, the challenge in trying to build an industry-agnostic framework was actually really interesting. And the flavor that came along with it as well, because we were borrowing, we were trying to learn from what was done in other areas, the Canadian perspective is broadly protection of the public. OSHA traditionally comes out of protection of the worker, so there is a fundamental shift in perspective of the PSM systems in other places.

Actually, it was a really good process. I think that it was great discussions, and I think that the way that we matrix everything out, and we got that discussion going was really meaningful. And I feel like we've produced something that captures what PSM means on its own without being specific to a specific industry. What'd you think, Parnian?

Parnian: Yeah, I was actually just going to build on that, and all of these challenges that we're faced when drafting the actual standard and the balance that had to be reached on the implementation side, when I was a process safety practitioner when I went to actually apply the standard, it actually became one of the both advantages and challenges of using the standard as well.

So, it's great because the vocabulary used in the standard means that, for example, a pipeline company can scale up and down, modify it so that it applies meaningfully to their linear assets. The standard does give you sufficient flexibility to interpret it in a way that makes sense for your assets. But at the same time, in order to do that, you really need to have an expert that can help you shift vocabulary, scale it up and down, and really make it work for your particular industry.

So, I think, from an implementation perspective, that was probably one of the biggest challenges that I faced in my role was to take this standard, and now try to figure out what does it mean for a pipeline company and the organization I was in, they had pipelines and facilities, they had distribution assets.

And so, for each of those assets, actually, the vocabulary slightly had to shift. The scaling and the way we applied the standards slightly had to change. And so, in the implementation side, it was an interesting challenge just trying to find the right vocabulary and the right definition of a facility so that the standard can be meaningfully applied and actually delivers, kind of distill each clause to its core intent, and then try to deliver on that core intent without getting worked up in specific words that, say, are nuanced for chemical sector and not so much for a pipeline sector.

What’s Next for Process Safety Standards?

Traci: What is next?

Adrian: Oh, goodness. It's lovely how much we've learned in the process. As we go through each draft, I think we end up developing a lot more questions. There's a lot of things that we're trying to continue to evolve and add more explanation to, more clarity to make it more broadly acceptable.

One of the lessons, I know Trish touched on it earlier about the ISO IEC, and I've worked in that space, and one of the things that I found works very well in that space is the standards all linked together very well.

So now, that we've written what PSM means for Canada, one of the things we're doing is reaching out to the other technical committees to try to see if we can link the standards together better, where they were doing elements of PSM. Now, we're hoping that they can adopt our PSM, and then fill in the blanks for what that means for their particular scope.

So, we're trying to really help build out that CSA standard ecosystem with PSM as one of the elements that go along with it. It'll be a multi-year effort to do that but that's sort of what we're hoping. And of course, we're going to keep getting a lot of feedback from people like Parnian, who actually have some great experience in the industry trying to apply it.

Parnian, do you want to comment on... Actually, Parnian is the Vice Chair of Process Safety Management Division, and I'm hoping she'll be chair soon. And so, that's the organization that actually sponsored and funded the development of this standard. So, Parnian, what's next? You're the boss.

Parnian: Yeah. Well, I'm in charge of absolutely nothing, but yeah, I think in general, the standard right now is as good as we wanted to get it by the time it got out. I think at this point, we are certainly at a point where feedback is very welcome because now we need people who have tried to use it to come back with more challenges that they faced.

But in the meantime, there's challenges that we already know based on trying to implement the first edition. Certainly, I have some issues that I would love to see some more support on. And so, I think a lot of what we still need to figure out how do we deliver on it is how do we support those who want to use the standard but are not necessarily process safety experts, or maybe PSM is not their full-time job, maybe their knowledge of PSM is not as high as maybe in the organizations that have full teams of PSM folks.

So, I think that's the challenge right now that I think, at least for me and especially something that the PSM division can help support, but probably there's others that can work with us. How do we help people understand what the standard means? How do we help people understand how to use these? How do we maybe leverage what already exists in other parts of the world on process safety management to help, say, "This is an example of how you can build this particular element. Here's an example of how you can scale this up and down, and that's the part that I think we really need to work on at this point." So, we'll see if that comes about, but that's certainly what I'm hoping we can start to pull together.

Traci: Well, you certainly have your work cut out for you.

Parnian: Going to be busy.

Traci: Trish, do you have any final thoughts?

Trish: I'd just like to really commend CSA and obviously the work that Adrian and Parnian and the rest of the committee have put into this. This is a world-leading initiative to have a national standard. And well done to the Canadians for getting this done. Thank you for leading the way in such an important area.