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Ideally the Management of Change element is implemented to ensure that a change in the process is managed in such a way to ensure that process safety risks of the change are addressed…not to create more “paperwork”. If we are completely honest, a lot of facilities complete the “MOC” after the change is already completed, and others use the MOC as the process to make sure everything was updated or addressed. When an MOC is done after the change is completed, the risk of the change itself is never fully evaluated until after the change is implemented making it even harder to revert back to the original design. Another common issue seen during compliance audits is the failure to update Process Safety Information (PSI). This may not seem like a significant issue if all the other items have been addressed but consider the cumulative effects over time. The Process Hazard Analysis (PHA) should be based on accurate and complete PSI, the lack thereof can result in hazards either missed or not evaluated properly which can lead to catastrophic failures. Lastly, there are still way too...more
Process Safety Management or PSM, is all about managing process risks, so it would stand to reason that we need to manage changes since any change can pose significant risks both new and latent. If we follow the Occupation Safety and Health Administrations (OSHA) PSM regulation, we should be very familiar with the Management of Change or MOC element. However, the language of the regulation is unclear and ambiguous. This ambiguity, or lack of clarity in the regulatory language, is evident in the hundreds of PSM program MOC policies and procedures reviewed as part of PSM compliance audits and incident investigations. Analysis obtained from audits and incident investigations would indicate that industries handling highly hazardous materials have room for improvement to fully implement a robust management of change process. Continuous improvement of safety and health management systems, require that we continue to look at policies and procedures and make the necessary corrections and updates. The same process of review and updates should be applied to our MOC policy and...more
There have been a number of articles and discussions recently regarding the United States Court of Appeals for the 10th Circuit decision regarding PSM coverage. It would seem from the many posts, comments, and related articles that this decision expands PSM coverage. However, this is simply not the case, but rather this decision affirms the plain language and intent of the regulation itself.
For background, a typical crude oil refinery will have multiple process “units” where each process unit performs a specific process step for producing finished or intermediate hydrocarbon products. One of those processes is a Fluidized Catalytic Cracker (FCC). The FCC is a significant process operation in most refineries and is the key to profitability of the facility since it converts heavy oils or long chain hydrocarbons into more valuable lighter end petroleum products. The FCC reactor is operated at an extremely high temperature and requires significant amounts of steam. When the heavy oils are fed...more
When it comes to Operating Procedures or SOPS, opinions differ widely on at least two items. The first is how much information or detail should be included, and the second the “Operating Limits”. As for the amount of detail, most will agree that the written SOP’s are not something that the operator will carry around with them, or refer to continuously while operating the process, but will more likely refer to them as needed. This would infer then, that the SOP is mainly used as a training document in most cases, therefore, they should be written in fine detail, and should be updated as operating philosophies, procedures, and steps change. If there is not enough detail, then training will most likely be with little detail as well, and we all know that the outcome of having poorly trained operators can be catastrophic. Whether we want to admit it or not, we all have bad habits. Without detailed SOPs, training may include some of those bad habits. If we assume that the trainee will also add their own bad habits, it would stand to reason than that operational tasks will differ in...more
The Process Hazard Analysis (PHA) is what most believe is the most important element of PSM. If true, then the analysis should reflect that level of emphasis. In order for the PHA to deliver the results desired, there needs to be a good understanding of the hazards that may exist and what risks they pose to employee safety and health. Often, PHA teams do not have the hazard and severity knowledge they need to conduct the proper hazard analysis. For example, is there a difference between the hazard and severity associated with a vessel liquid full at 500 PSIG, and one that is filled with a vapor or a gas at the same pressure. Yes, the “knock-on” hazard might be different when the chemical or material in the vessel is released (fire explosion, toxic exposure), but the hazards associated with a catastrophic vessel failure are much different. Once the severity of the hazard is different, based if the difference in energy between an essentially incompressible liquid and the compress gas/vapor, then it is possible to address hazards and the subsequent severity more succinctly....more
The Process Safety Information (PSI) element within PSM has three different categories that include: Information pertaining to the hazards of the highly hazardous chemicals, Information pertaining to technology, and Information pertaining to the equipment in the process. PSI, in this person’s opinion next to employee participation, is the most important element in process safety management, and in many cases has the most gaps in compliance and understanding.
It is important to understand the three distinct process safety information requirements. To help understand these categories better, it is best to think of the steps that are typically taken in the development of a new or a major process revision. Every new process design starts with some very simple basic concepts to achieve a specific objective. The first item that is normally considered in the design, no matter what the process, is what chemical or material will be involved. Even a simple process, such as a closed loop refrigeration system, will use some type of chemical (refrigerant). The decision on which...more
It is important to know, that the order of the PSM elements in the OSHA Process Safety Management Regulation is relevant. Understanding some reasoning for the order is important from an overall management system standpoint, but also in helping us to better understand PSM in general. Immediately following the scope, application, and definitions within the PSM regulation, is the first of the traditional fourteen (14) “elements” entitled “Employee Participation”. Before delving into this element, it is important to take a step back and see these first elements in the context of a safety and health management system (SHMS).
For those of us who have been involved in project design and installation within the process industry can more fully understand these first six elements and the design process in general. For example, most all process designs, no matter the type or size, go through similar design process steps. The first step, though not always apparent, is the need to have employees participate. The best process designs will always result from utilizing the best from...more
In December 22, 1944, the allies (American troops) were sent a letter from the commander of German forces located outside of the town, demanding “the honorable surrender” of the town within two hours. General McAuliffe, the commander of the American troops reply was brief and to the point:
“To the German Commander:
N U T S!
The American Commander”
We, however, are obviously not in as severe a life or death situation (though it may seem that way), but occasionally we are asked or expected to do things that seem so utterly ridiculous that you can only say, this is NUTS! There are several of those when it comes to ammonia refrigeration systems. You have to wonder if those that developed the requirements have actually had to do this work in the field. This is not to be an indictment against those that developed the standards, but more so in the process at getting input from those that actually carry out the majority of the tasks. This goes to the heart of PSM...more
Most of us, I’m sure, have seen OSHA statistics regarding the most cited elements of the PSM regulation. In the past 10 years, I have conducted well over 250 compliance audits and either led or participated in another 25 plus incident investigations. Based on that experience, I have come to realize that the OSHA data is not an accurate reflection of where the problems lie in process safety. As many of you may know, I spent five (5) years with OSHA as a PSM specialist. During that time, I experienced first-hand the strengths and weaknesses within the agency from a PSM perspective. One of the major weaknesses, in my opinion, is that many of the compliance officers that deal with PSM do not have a process safety, engineering, or process industry background. Without this background knowledge and experience, it is extremely difficult to understand and apply the PSM element’s intent to engineering design principals and then to process safety. Even when it comes to simple processes such as ammonia refrigeration, understanding key engineering concepts is important in applying process...more
We’re all in this together…most of us have undoubtedly heard this repeated over and over in the last couple of months. While it is true that we may be in this together, we are all facing this battle under different circumstances. Some have had their hours extended, while others have been sent home and continue to get their normal paychecks, while others have had to file for unemployment, and face the uncertainty of being able to return to the job they loved. Some have had to become teachers and day care providers, while also trying to work a full-time job from home. Teachers have been plunged into distant learning instructors within a matter of days. Some restaurants have become carry-out or delivery only, some groceries store shelves are bare, while others allow purchases online only. Every one of our businesses, whether an industrial manufacturing facility, restaurant, grocery store, hair salon, or department store, relies on the other in some form to stay in business. As we begin to emerge from this pandemic, now more than ever, we need to assist each other in getting up...more
There is no doubt that right now we are living in a time of a lot of uncertainty. Many are faced with the loss of a job, cut back on the number of hours allowed to work, the potential for illness, and the concern for family and friends. For the most part, these things are out of our own personal control.
However, each of these concerns can weigh heavily on every one of us and can also result in less focus on those risks we can control. Perhaps those of us in process safety management, understand this more so than others. We understand to control risk we must focus on those things that we can control, and not let distractions render our risk reduction efforts mute.
We cannot take a break from process safety. In fact, the last thing any of us need right now is a catastrophic event that results in major injuries, or worst yet, fatalities. Most of us have seen that the EPA has relaxed some of its enforcement activity during this time....more
One important aspect of the OSHA process safety management (PSM) standard that we must keep in mind, is that it was developed and promulgated in the early 1990s, and has not really changed any since then, but our industry has changed a lot.
However, the same principles of process safety management are just as relevant today as they were over 25 years ago. The 14 elements of the PSM standard constitute the framework of a safety and health management system (SHMS). As is the case in all effective management systems, the standard contains the continuous improvement model elements: plan, do, check, and act (PDCA).
The 14 elements of PSM are the “plan” portion, and when implemented, the “do” portion, achieves risk management or process safety. The “check” portion is the OSHA compliance audit element, and the “act” is implementing the recommendations from the compliance audits, incident investigations, and...more
Unfortunately, it is all too common for “good” companies to be lulled into a false sense of security by their past performance in personnel safety and health. They may not realize how vulnerable they are to a major incident, until it happens.
Subsequent investigations of incidents at these “good” companies has typically shown that there were multiple causal factors, and many were known long before the event occurred. In many cases, the company often assumed process safety systems worked as intended, despite the warning signs. They will find examples of “good” performance and assume they represent the whole, while poor examples are overlooked or soon forgotten, rather than digging deeper to understand what is really happening.
A process hazard analysis of failure modes and effects should go beyond the equipment, physical, and information technology systems, and must include human and organizational aspects as well. Recognition of the seriousness of...more
If you look at Bureau of Labor Statistics (BLS) data across the various industries prior to the promulgation of OSHA process safety management (PSM) and EPA risk management plan (RMP) regulations, it will show that oil and gas, refining, and petrochemical industries were much better as an industry than other industrial sectors such as machinery manufacturing, logging, commercial fishing, and food production, from a purely injury and illness standpoint.
If we look at the current BLS data for the same industries today, there has not been near the improvement you would expect. There are a lot of reasons that keep us as a process industry, from achieving a paradigm shift in process safety. One reason is that when a team is given more than one objective to achieve, they fail to achieve any of them in the manner we would like or should expect. It does not mean...more
Unfortunately, it is very common for “good” companies to be lulled into a false sense of security by their performance in personnel safety and health goals. They may not realize how vulnerable they are to a major incident until it happens. Subsequent investigations of incidents at these relatively “good” companies have typically shown there were multiple causes, and many of these causes were known long before the event occurred.
In many cases, people often assume systems work as intended, despite the warning signs. They will find examples of “good” performance and will assume they represent the whole, while poor examples are overlooked or soon forgotten, rather than digging deeper to understand what is really happening.
One of the main causes for a lax process safety culture, is the failure to provide a well-defined “management system” that incorporates the teaching and training that is so crucially needed. For example, how many people in...more
How many times have you heard this statement regarding a major release or fire? “If they would have only implemented or adhered to process safety management (PSM) this would not have happened.” Basically, this comment says “we” do not understand the purpose of PSM very well.
Proper process safety management never has, nor will it ever, result in “zero” incidents. This is because PSM or risk management plans (RMP) are not designed to eliminate risks, but rather it creates programs and systems that must be in place to “manage” the risks associated with facilities that handle highly hazardous chemicals (HHC).
I know that some will say that our goal should be to eliminate incidents and not just manage risk. However, this is not only unrealistic, but most likely not practical either. It would be downright impossible to find anything that we do that does not have...more
Ever wonder how your local grocery store keeps all their produce, meats, drinks, and bread fresh by the time it gets distributed for your weekly grocery run?
Suppliers must refrigerate all food and drinks once the product is made to the time it is delivered to your local HEB or Trader Joe’s. Most people think of freon as a refrigerant, but ammonia is actually the most commonly used commercial refrigerant in the food and beverage industry today.
Ammonia has replaced the more popular use of freon for two essential reasons:
Unlike freon, or otherwise known as chlorofluorocarbons (CFC), ammonia has an ozone depletion rating of 0. Throughout the years, it has been discovered that CFCs have a huge contribution to greenhouse gases that destroy the ozone layer.
In addition to being earth-friendly, ammonia...more
If you work with highly hazardous chemicals at a gas plant or ammonia facility, you may have heard someone mentioning PSM. But what is PSM and why should you care?
PSM stands for process safety management and is a regulation (29 CFR 1910.19) created by OSHA in 1992 due to a rise in catastrophic events.
In 1984, one of the worst incidents in the industry occurred where over 2000 people died due to a chemical release in Bhopal, India. Five years later in 1989, an explosion at a petroleum facility in Pasadena, TX resulted in over a hundred injuries and 23 fatalities. Just a few years later, two deaths occurred from an explosion in Cincinnati, OH in 1990 and eight fatalities due to a chemical release in Sterlington, LA in 1991.
PSM consists of 14 elements intended to help eliminate and/or mitigate the hazards at a facility to ensure a safe...more
A violation of the OSHA 1910.119 standard is considered serious in nature, and therefore can result in a fine ranging from $13,494 to $134,937 each.
A violation of the EPA section 112(r) of the 1990 Clean Air Act standard can result in a penalty as much as $37,500 per violation, per day.
Process & Safety Solutions LLC (PSS) is a veteran-owned process safety consultant based in Pearland, TX, though we serve clients across the country. Our extensive industry and regulatory knowledge are essential for evaluating PSM and RMP programs.
Our lead auditor brings this...more