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Process Safety
focuses on people, chemicals, the equipment, and near environment of the chemical plant
OSHA Rules (PSM)
inside fence line
EPA Rules (RMP)
outside of fence line
CCPS PSM
risk-based process safety method
CCPS risk
Hazard, magnitude, frequency
Due-diligence
Just obeying the law doesn’t mean that the law is the best you can do; you and your company can be technically obeying the law and you stil get hurt or die; you can still get sued
General Duty Clause
Companies must know the hazards and assess potential impacts to workers and environment, design and maintain safe facility to prevent accidental releases and accidents, and minimize the consequences of accidents and accidental releases
four elements of process safety
commitment to process safety, understand hazards/risks, manage risk, learn from experience
commit to process safety
four elements of process safety: cornerstone, leadership and workers commitment
understand hazards and risk
four elements of process safety: better able to allocate resources, stable, lower-risk operations; businesses that use resources to understand hazards and risk enjoy longer-term success
managing risk
four elements of process safety: prudently operate/maintain processes, manage changes to those processes, maintain the integrity of equipment using quality materials, fabrication, methods, and repairs, respond and manage incidents that occur
learn from experience
four elements of process safety: monitor and use internal and external information, learn from the company’s incidents and near-misses and other companies’
Process Safety Management System
a set of values, assumptions, concepts, and practices that form a structure for supporting the management and integrity of hazardous operating systems and processes by applying good design principles, engineering, and operational practices
commitment to process safety
process safety culture, compliance w/ standards, process safety competency, workforce involvement, stakeholder outreach
understand hazards and risk
process knowledge management, hazard identification and risk analysis
manage risk
operating procedures, safe work practices, asset integrity & reliability, contractor management, training and performance assurance, management of change, operational readiness, conduct of operations, emergency management
learn from experience
incident investigation, measurement & metrics, auditing, management review and continuous improvement
Process safety culture
the common set of values, behaviors and norms at all levels in a facility or organization that affect process safety (how we do things here, what do we expect here, how do we behave when no one is looking)
process safety culture
maintain a sense of vulnerability (look for warning signs)
process safety culture
avoid normalizing deviations, reluctance to simply explain
process safety culture
confirm risk assessments regularly
process safety culture
reverse the burden of proof → not safe until proven safe
process safety culture
ensure open communications and strong & fast learning capabilities from accidents, near-misses, and other published accidents
process safety culture
Deference to expertise
process safety culture
ensure production pressures are not compromising safety priorities
process safety culture
individual empowerment, mutual trust, responsiveness, different than personal/occupational safety culture
compliance with standards
a system to identify, develop, acquire, evaluate, disseminate and provide access to standards, codes, laws, and regulations that affect process safety
compliance with standards
includes: internal/external codes and standards, national/international standards, Industry Association Guidance → Recognized and Generally Accepted Good Engineering Practices (RAGAGEP)
Recognized and Generally Accepted Good Engineering Practices
RAGAGEP
regulation
an authoritative rule dealing with details or procedure; a rule or order issued by an executive authority or regulatory agency of a government and having the force of law
code
a systematic statement of a body of law especially one given statutory force
standard
established by authority, custom, or general consent as a model or example
performance based
what needs to be accomplished
prescriptive
what to do and how to do it
OSHA Process Safety Management
a US regulation, performance based, covered facilities must comply but need not do more
CCPS 20 Elements of Risk Based Process Safety
an industry standard/guideline (optional), performance based, broader, emphasizes continuous improvement
compliance with standards
sources of standards: specific bodies created to develop standards, consortia of companies w/ similar safety issues, often based on experience/accidents/expert calculations/etc.
Companies can create their own standards
supplement industry standards, fill gaps where there is not an applicable industry standard, define their company management systems, define their engineering practices
process safety competency
combination of knowledge, skill/expertise, and training needed to deem someone as well-qualified and capable relating to process safety
process safety competency
continuously improving knowledge and competency of the company as a whole: knowledge (develop, discover, enhance), competency (inc. knowledge, and disseminate throughout company)
process safety competency
ensuring the appropriate info is available to people who need it
process safety competency
consistently applying what has been learned
process safety competency
proactive as a company (top down approach)
process safety competency
getting info and needed safety out of people’s heads, down on paper, and then disseminated throughout companyw
workforce involvement
enables the active participation of company and contract works in the design, development, implementation, and continuous improvement of the RBPS management system → personnel at all levels and positions of the company should have roles and responsibilities for enhancing and ensuring the safety operations
workforce involvement
the most appropriate people are involved int he review of the workforce down to operators and all feel free to provide candid view W/O fear of adverse consequences to their career
stakeholder outreach
strives to make relevant info available to a variety of individuals or organizations that can be affected (or believe that they’re affected) to engage in dialogue abt PSM
stakeholder outreach
seeking individuals or organizations affect by company decision: establish relationships w/ federal/state/local authorities, establish relationship w/ community organizations/other companies
stakeholder outreach
provide accurate info abt the company and facility’s products, processes, plans, hazards and risks (especially for emergency management)
stakeholder outreach
follows up commitments to stakeholders and solicits feedback
process knowledge management
physical, chemical, and toxicological information related to the chemicals, process, and equipment; used to document the configurations of a process, its characteristics, its limitations and as data for process hazard analyses
process knowledge management
activities associated w/ compiling, cataloging, and making available process safety information
process knowledge management
focuses on info that can be recorded in documents: written technical documents/specifications, engineering drawing and calculations, chemicals & equipment used (hazards), specifications, selection of safe operating limits, SDS, etc. → requires expertise of a variety of engineers
hazard identification and risk analysis (HIRA)
all activities involved in identifying hazards and evaluation risk at facilities to determine if the risks to employees, the public, and environment are w/in a company’s risk tolerance → that which has not been identified cannot be prevented or mitigateds
hazard identification and risk analysis (HIRA)
some companies use the term Process Hazard Analysis (PHA) to meant the study done to satisfy OSHA PSM standard; while Hazard Assessment means any other study
hazard identification and risk analysis (HIRA)
qualitative tools for hazard analysis: what-if/checklist analysis, Hazards and Operability Analysis (HAZOP), Failure Modes and Effects Analysis (FMEA)
hazard identification and risk analysis (HIRA)
semi-qualitative toolds: failure modes, effects, and criticality analysis (FMECA), layer of protection analysis (LOPA)
operating procedures
written (electronic and hard copy) Standard Operating Procedures (SOPs) and info necessary to operate equipement and processes and includes operating instructions, process descriptions, operating limits, hazards, and safety equipment requirements
operating procedures
should be provided for all operating modes: start-up, shut-down, routine, temporary & emergency (risks from deviations)
operating procedures
jointly developed by engineers and operators, any changes to approved documents fall under management of change (MOC)
safe work practices
an integrated set of policies, procedures, permits, and other systems that are designed to manage risk associated w/ non-routine activities such as performing hot work, opening process vessels or lines, or entering a confined space; formalized process to help control hazards and manage risk associated w/ work NOT directly involved w/ process operations
safe work practices
examples: maintenance & inspections, Lock-Out-Tag-Out (LOTO), Hot work, line break, confined space entry, heavy lifting, etc.
job safety analysis
JSA
job safety analysis
systematically identify hazards associated w/ each step of a job and determine actions for eliminating or controlling those hazards
job safety analysis
one defines the job scope, breaks it down to discrete steps, identifies any potential hazards associated w/ each step, and then eliminates or mitigates those hazards
asset integrity & reliability
systematic implementation of inspections, tests, and maintenance to ensure that equipment & safety devices are properly designed, installed, and remains in proper working order throughout their life
asset integrity & reliability
ex: proper selection of materials, inspections/tests, preventative maintenance, predictive maintenance, repairs
contractor management
a system of controls to ensure that contracted services support both safe facility operations and the company’s safety goals (process & occupational); care must be taken in the selection, acquisition, use and monitoring of contracted services
contractor management
contractors must be trained before starting, authority & responsibility must be clearly defines, periodic monitoring of safety & performance, appropriate recrods
training and performance assurance
practical instruction in job and task requirements and methods to enable workers to meet some minimum initial performance standards, to main their proficiency, or to qualify them for promotion to a more demanding position
performance assurance
the way that a company determines if and how personnel have understood the training in practical situations
Management of Change
MOC
management of change
ensures that changes to a process (equipment, operation & maintenance) do not introduce new hazards or increase existing hazards
management of change
define what is the change
identify hazards and analyze the risk
communicate the change & conduct training before implementation
make change to process safety information
operational readiness
method to confirm current, new or modified processes or equipment are safe to start up (Pre-Startup Safety Reviews PSSRs OSHA)
operational readiness
ensures that: the construction and equipment meet design specs, safety/operating/maintenance/emergency procedures are in place, safeguards that may have been bypassed are verified to be in service, all sensors/instruments/valves/etc. work, training has been completed
conduct of operations
execution of operational, engineering, and management tasks in a deliberate structured manner; real-time manifestation of the Process Safety Culture Every day and day-to-day, beyond operational discipline
operational discipline
the pursuit of a consistent and high level of human performance
conduct of operations
plan the work then work the plan
emergency management
identifying, assessing, planning for emergencies including process safety incidents, natural hazards, and other disruptive events; document in writing, train and drill, obtain needed resources, communicate w/ stakeholders (especially neighbors)
emergencies
process safety incident, natural disasters, incident at neighboring property, pandemic, intentional attack or sabotage
emergency management
emergency planning and response: protect people (onside, offsite, emergency responders), respond appropriately to large accidents (explosions, chemical and energy releases)
emergency management
encompasses activities that occur before, during, and after an emergency
emergency management plan
plan defensive response actions
plan offensive response
develop written plan
provide physical facilities and equipment for response at strategic locations
maintain/test facilities and equipment
determine when operator response is appropriate
train the emergency response team (ERT) members including re-train/refresh
plan communications w/ workers, contractors, neighbors, authorities
inform and train all personnel
periodically review emergency response plan
incident investigation
reporting, investigating, tracking, and learning from incidents and near-misses
incident investigation
used to identify and eliminate causes of incidents
measurements and metrics
establishes performance and efficiency indicators to monitor the effectiveness of the RBPS management program: use leading/lagging indicators, collect/analyze metrics data, present metrics to management
lagging indicators
reactive/follows an event; actual demonstration that a desired safety level was NOT being met
leading indicators
predictive/precedes an event; signals an event has a higher probability of taking place, if no corrective action is taken the event is more likely of occurring
auditing
a systematic, independent review to verify whether management systems are performing as intended and correct gaps before an incident occurs (includes scheduling, staffing, performing, and documenting); resolve recommendations and track completion
management review and continuous improvement
the ongoing evaluation of management system performance by management taht fills the gap between routine evaluation and audits