Risk Based Process Safety 1n3h5d

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Magazine Vol. 10 No. 4

2008

Risk-Based Process Safety:

The Next-Generation PSM System

Steve Arendt Director and Vice President Operational Performance Assurance ABS Consulting

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rocess safety practices and formal safety management systems have been in place in some companies for many years. Process safety management (PSM) is widely credited for reductions in major accident risk and for improved chemical industry performance. Nevertheless, inadequate management system performance, resource pressures and stagnant process safety results continue to challenge many organizations (Figure 1). To promote PSM excellence and continuous improvement throughout industry, the American Institute of Chemical Engineers (AIChE) Center for Chemical Process Safety (CS) created Risk-Based Process Safety (RBPS) as the framework for the next generation of PSM. CS contracted ABS Consulting to develop this book, which was published in April 2007. The RBPS guidelines provide tools that will help process safety professionals to build and operate more effective PSM systems. They provide guidance for how to design a PSM system, correct a deficient system or improve PSM practices. RBPS Approach The RBPS approach recognizes that all hazards and risks are not equal. Consequently, it identifies greater hazards and higher risks and helps managers apply resources to those. The main emphasis of the RBPS approach is to put enough energy into each activity to meet the anticipated needs for that activity. In this way, limited company resources can be apportioned optimally to improve both facility safety performance and overall business performance. Three RBPS criteria should be considered when seeking to improve a PSM system: 1. An understanding of the hazards and risks of the facilities and operations 2. An understanding of the demand for and resources used in process safety activities 3. An understanding of how an organization’s process safety culture influences process safety activities

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Accident Prevention Pillars and RBPS Elements CS has established four accident-prevention pillars, which should be implemented at a risk-appropriate level of rigor. Commit to process safety. This is the cornerstone of process safety excellence. A workforce that is convinced the organization fully s safety as a core value will tend to do the right things, in the right ways, at the right times – even when no one is looking. • Process safety culture • Standards, codes, regulations and laws • Process safety competency • Workforce involvement • Stakeholder outreach Possible Causes of Process Safety Management (PSM) Performance Stagnation • Regulation sometimes leads to a minimum-cost, compliance-based approach. • Declining worker injury rates may give management a sense of complacency that the risk of process safety incidents must likewise be declining. • PSM may have been implemented as a separate, stand-alone system that was not integrated into the organization’s overall management system or as a one-time project instead of an ongoing process. • Audits have focused on symptoms of problems; they have failed to identify underlying causes. • Diminishing resources are devoted to process safety; facilities face increased pressure to achieve short-term financial objectives. • Mergers, acquisitions and divestitures have decreased organizational stability. • Success has led to complacency; the absence of major accidents reduces a company’s sense of vulnerability.

Figure 1: Possible causes of PSM performance stagnation; from Guidelines for Risk Based Process Safety, AIChE Center for Chemical Process Safety (New York: Wiley, 2007).

Understand hazards and evaluate risks. This is the foundation of a risk-based approach. An organization can use this information to allocate limited resources in the most effective manner. • Process knowledge management • Hazard identification and risk analysis Manage risk. This is the ongoing execution of RBPS tasks. Organizations must (1) operate and maintain processes that pose risk, (2) keep changes to those processes within risk tolerances and (3) prepare for, respond to and manage incidents that do occur. • Operating procedures • Safe work practices • Asset integrity and reliability • Contractor management • Training and performance assurance • Management of change • Operational readiness • Conduct of operations • Emergency management Learn from experience. Metrics, incidents, audits and management reviews provide direct on the workings of RBPS systems. Leading indicators provide early warning signals of ineffective process safety results. When an element’s performance is unacceptable, organizations must use their mistakes – and those of others – as motivation for action. • Incident investigation • Measurement and metrics • Auditing • Management review and continuous improvement

disseminate and maintain an archive of applicable standards, codes, regulations and laws that affect process safety. The primary objective of this element is to make key information easily and quickly accessible to potential s. The critical information here comes from internal and external standards; national and international codes and standards; and local, state and federal regulations and laws. 3. Process safety competence. The process safety competence element includes three interrelated objectives. The first is to learn new things continuously. The second is to make sure that appropriate information is available to operators and other front-line personnel in a manner that helps them make sound decisions. The third is to try not to forget what has already been learned. The learning aspect includes efforts to develop, discover or otherwise enhance process safety knowledge. 4. Workforce involvement. The workforce involvement element helps makes sure employees and contractors participate in the design, development, implementation and continuous improvement of the RBPS program. It also includes a means for two-way communication and consultation between management and workers with respect to the RBPS program and input provided by workers.

RBPS Elements The following 20 elements expand upon the original CS PSM elements to reflect 15 years of experience in PSM implementation, the best practices from a variety of industries and worldwide regulatory requirements. 1. Process safety culture. The safety culture element encomes a system that establishes, evaluates and maintains a corporate and facility culture that places high value on process safety. The leaders of an organization must first determine the level at which the safety culture currently functions. Then they must decide where they wish to take the culture. Finally they must chart and navigate a path for maintaining and improving safety culture. This element includes effectively communicating and demonstrating established company safety values to company personnel and providing adequate resources so that process safety goals are achievable. 2. Compliance with standards. Compliance involves a system that can identify, develop, acquire, evaluate,

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5. Stakeholder outreach. The stakeholder outreach element includes activities to seek out and engage the local community in a dialogue about process safety and to establish relationships with other facilities/companies and professional groups in the area, including neighbors and local, state and federal organizations. Stakeholder outreach activities also provide information about the facility/company and its products, processes, plans, hazards and risks, and they promote the involvement of the facility/company in the local community and communicate information and activities that could affect the community. 6. Process knowledge management. The process knowledge management element addresses the storage and retrieval of technical data and process knowledge. This element includes work activities so that the information is kept current and accurate, stored in a manner to facilitate easy retrieval and accessible to employees who need it to perform their duties related to process safety. 7. Hazard identification and risk analysis. Hazard identification and risk analysis is a process for identifying hazards and evaluating the risk of processes – throughout their life cycle – to make certain that risks to employees, the public or the environment are understood and consistently controlled within the organization’s risk tolerance. This element includes determining when studies should be done; making sure they are done to an appropriate level of quality, detail and timeliness; having a system in place to make risk decisions; and following up on those decisions through implementation.

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8. Operating procedures. Operating procedures are written instructions that list the activities to be done, the manner in which they are to be performed and the expected response (and, in some cases, particular responses to dangerous situations). This element includes operating procedures that address all modes of operation, but it does not include safe work procedures and maintenance procedures, which are addressed in the next two elements. 9. Safe work practices. Safe work practices include an integrated system of policies, procedures, permits and practices that control work that is not part of the normal operation (that is, not covered by the operating procedures element). Safe work practices often are applied to construction work, particularly if the work might affect other operations at a facility. 10. Asset integrity and reliability. Asset integrity and reliability is the programmatic implementation of activities necessary to make sure that important equipment will be suitable for its intended application throughout the life of an operation. This element identifies and helps prevent the failure of critical equipment or systems. It includes activities to (1) find unsafe/undetected failures, (2) measure the rate of component wear or degradation, (3) confirm that safety systems will perform as intended if needed, (4) define and ensure quality in written procedures, in the documentation of test results and through proper repairs or replacements as indicated and (5) provide a system to guarantee that defects are not introduced in fabrication, installation or repair. 11. Contractor management. The contractor management element assists in making sure that services are procured and provided in a fashion that is ive of the implementation of the RBPS system and of the organization’s process safety and conventional worker safety performance goals. It addresses the selection, acquisition, use and monitoring of services. 12. Training and performance. Training addresses practical education on the job and on task requirements and methods. It may be provided in a classroom or at the workplace, and its objective is to enable workers to meet some minimum initial performance standards, maintain their proficiency or qualify for promotion to a more demanding position. Performance assurance is the means by which workers demonstrate that they have understood the training and can apply it in practical situations. 13. Management of change. Change management is a process for reviewing, evaluating and authorizing proposed adjustments to facility design, operations, organization or activities – prior to implementation – to make certain that no unacceptable hazards are introduced and that the risk of existing hazards to employees, the

public or the environment is not increased above a tolerable level. 14. Operational readiness. Operational readiness includes a number of integrated work activities designed to confirm that a process is ready for operation prior to introducing hazardous materials. This element addresses activities to secure equipment readiness, such as confirming that the equipment is fabricated and installed properly, that systems are operational and that the process equipment is leak tight (where required). This element also addresses equally important activities, such as training, procedures, supervisory oversight during this critical stage of operation and, in some cases, technical for the startup of new or modified equipment. 15. Conduct of operations. Conduct of operations includes activities to warrant highly reliable human performance on a day-to-day basis. Whereas written procedures and training tend to be episodic, conduct of operations occurs continuously. It includes activities to (1) confirm that policies and procedures are followed, (2) prevent worker-to-worker and shift-to-shift communication errors, (3) communicate management’s priorities and intent (which complements the safety culture element), (4) provide the knowledge needed to recognize when there is a conflict between written procedures and management intent and take appropriate action and (5) efforts to instill the discipline within the organization to do things right, whether the activities affect process safety or other key organizational objectives. 16. Emergency management. Emergency management includes (1) planning for possible emergencies, (2) providing resources to execute the plan, (3) practicing and continuously improving the plan, (4) training or informing employees, contractors, neighbors and local authorities on what to do, how they will be notified and how to report an emergency and (5) effectively communicating with stakeholders in the event an incident does occur. 17. Incident investigation. Incident investigation is a process for planning for, reporting, tracking and investigating near misses and accidents. It includes the formal process for investigating risk-significant incidents, including staffing, performing, documenting and tracking investigations of process safety incidents, and it also involves the tracking of incident and incident-investigation data to identify risk-significant recurring incidents. This process manages the resolution and documentation of recommendations generated by the investigations. These efforts constitute a way of learning from risk-significant incidents that occur within the organization over the life of the facility and communicating lessons learned to internal personnel and external organizations.

18. Measurement and metrics. This element establishes a system for developing and collecting data for process safety metrics. The system establishes the framework for measuring performance and efficiency through the use of leading and lagging indicators. It describes how the company uses these metrics to improve process safety effectiveness and provides tangible benchmarks for determining whether the company is meeting its continuous-improvement goals. 19. Auditing. The auditing element addresses scheduling, staffing, and effectively performing and documenting periodic audits of the RBPS elements to evaluate whether the management systems are performing as intended. It also provides a system for managing the resolution of findings and corrective actions generated by the audits. 20. Management review and continuous improvement. This element establishes the process by which management regularly scrutinizes selected aspects of RBPS elements to focus attention and resources on areas where improvements can be made. Management reviews are more frequent than audits but less extensive since they tend to spotlight only selected process issues. This element identifies sources of information typically developed or collected for management review of a PSM element, including recent incidents, current metrics, applicable audit results and corrective-action status. The results of a management review provide direction for continuous improvement and reflect on the efficacy, performance and efficiency of a facility’s process safety program.

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How to Use RBPS The RBPS system may encom all process safety issues for all operations involving the manufacture, use, storage or handling of hazardous substances or energy. However, each organization must determine which physical areas and phases of the process life cycle should be included in its formal management systems, based on its own risk-tolerance considerations, available resources and process safety culture. Figure 2 offers examples of how work activities may be defined according to RBPS elements and practices. Continually Strive to Do Better – Culture Is the Key Culture is the result of all the actions and inactions in institutional or workforce memory that influence individual behaviors and tendencies. The essential features of a good safety culture are: • Safety as a core value • Strong leadership • Sense of vulnerability • High standards of performance • Individuals successfully fulfilling their safety responsibilities RBPS element Key practice Essential feature Work activity

Perceived risk level of process where the RBPS element activity is to be implemented Low

Medium

High

5. Process safety competency 5.3.2 Execute activities that help maintain and enhance process safety competency Plan personnel transitions 17. Consider individual and organizational competency in succession planning.

a. Program grooms senior managers.

b. Program grooms senior managers and technical personnel; it requires at least one completed process safety assignment.

d. Program is organization-deep and includes competency maintenance, protection and improvement.

• Deference to expertise • Open and effective communication • Questioning/learning environment • Continuous monitoring of performance • Mutual trust • Timely response to safety issues and concerns • Formalization of a safety culture emphasis and approach As people strive for zero incidents, they will continue to extract and apply the lessons derived from those that do occur and look for better ways to assure good performance. Technical issues can be fixed. Management systems issues can be fixed. But to generate better, sustainable performance, organizations must formally address ways to evaluate and improve individual and organizational process safety culture (Figure 3). Companies will understand that doing all three will lead directly to safer and more productive operations. n Steve Arendt is the vice president of ABS Consulting’s Operational Performance Assurance group. He is involved with risk management and communication, process safety and site security, and counterterrorism activities associated with the chemical and allied industries. Mr. Arendt has more than 25 years of experience in process safety, risk management and security. Recently he helped develop industry guidelines for performing security vulnerability analyses. He has published many articles and authored several major process safety publications. He is also a coinstructor of security courses and has led numerous industry-sponsored security workshops.

9. Hazard identification and risk analysis (HIRA) 9.3.1 Maintain a dependable practice Integrate HIRA activities into the life cycle of projects or processes 2. Determine when HIRAs should be performed.

a. HIRAs are part of normal design review.

c. An initial HIRA is completed, and periodic updates are performed.

d. A series of HIRAs is performed, each specific to a discrete stage of the life cycle.

15. Management of change (MOC)

a. Informal training is provided.

b. MOC practice is broadcast via e-mail one time.

d. MOC initial and refresher training is provided to affected personnel.

22.3.1 Maintain a dependable practice Define roles and responsibilities a. General guidance applies to all elements.

Management System Failures b. Detailed guidance addresses specific management review requirements.

c. Detailed guidance addresses specific requirements for each RBPS element.

Figure 2: Examples of how risk affects the implementation of RBPS work activities; from Guidelines for Risk Based Process Safety, AIChE Center for Chemical Process Safety (New York: Wiley, 2007).

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Incidents

Precursors

22. Management review and continuous improvement

1. Develop a written policy for management review.

“Learn Lower” on the Pyramid Accidents

15.3.1 Maintain a dependable practice Involve competent personnel 5. Provide training on the MOC system.

Mr. Arendt is a ed professional engineer (P.E.) in the state of Tennessee.

Vol. 10 No. 4 2008

Unsafe Behaviors and Attitudes

Culture – Individual and Organizational Tendencies

Figure 3: For sustainable performance, an organization must focus on its overall process safety culture.