Risk based process safety

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 M   agazine V ol ol. 10 n o. 4

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Risk-Based Risk -Based Pro Process cess Safety: Safety :

The Next-G Nex t-Generation eneration PSM System System

Steve Arendt Director and Vice President Operational Perormance Assurance ABS Consulting

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rocess saety practices and ormal saety management systems have been in place in some companies or many years. Process saety management (PSM) is widely credited or reductions in major accident risk and or improved chemical industry perormance. Nevertheless, inadequate management system perormance, resource pressures and stagnant process saety results continue to challenge many organizations (Figure 1). To promote PSM excellence and continuous improvement throughout industry, the American Institute o Chemical Engineers (AIChE) Center or Chemical Process Saety (CCPS) created Risk-Based Risk-Based Process Saety (RBPS) as the rame ramework or the next generation o PSM. CCPS contracted ABS Consulting to develop this book, which was published in April 2007. The RBPS guidelines provide tools that will help process saety proessionals to build and operate more eective PSM systems. They provide guidance or how to design a PSM system, correct a decient system or improve PSM practices. RBPS Approach The RBPS approach approach recognizes that all hazards and risks are not equal. Consequently, it identies greater hazards and higher risks and a nd helps managers apply resources to those. The main emphasis o the RBPS approach is to put enough energy into each activity to meet the anticipated needs or that activity. In this way, limited company resources can be apportioned optimally to improve both acility saety perormance and overall business perormance. Three RBPS criteria should be considered when seeking to improve a PSM system: 1. An understanding o the hazards ha zards and risks o the acilities and operations 2. An understanding o the demand or and resources used in process saety activities 3. An understanding o how an organization’s process saety culture infuences process saety activities

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Accident Prevention Pillars and RBPS Elements CCPS has established our accident-prevention pillars, which should be implemented at a risk-appropriate level o rigor. Commit to process saety. This is the cornerstone cornerstone o  process saety excellence. A workorce that is convinced the organization ully supports supports saety 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 saety culture • Standards, codes, regulations and laws • Process saety competency • Workorce involvement • Stakeholder outreach Possible Causes of Process Safety Management (PSM) Performance Stagnation • Regulation sometimes leads to a minimum-cost, compliance-based compliance-based approach. • Declining worker injury rates may give management a sense of complacency complacency that the risk of process safety incidents must likewise be declining. • PSM may have been implemented as a separate, 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 have failed to identify underlying causes. • Diminishing resources are devoted to process process safety; facilities face increased pressure to achieve short-term nancial objectives. • Mergers, acquisitions and divestitures have decreased decreased organizational stability. stability. • Success has led to complacency; the absence absence of major accidents reduces a company’s company’s sense of vulnerability.

Figure 1: Possible causes o PSM perormance stagnation; rom Guidelines for Risk Based Process Safety , AIChE Center or Chemical Process Saety (New York: Wiley, 2007).

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

disseminate and maintain an archive o applicable standards, codes, regulations and laws that a ect process saety. The primary objective o this element is to make key inormation easily and quickly accessible to potential users. The critical inormation here comes rom internal and external standards; national and international codes and standards; and local, state and ederal regulations and laws. 3. Process saety competence. The process saety competence element includes three interrelated objectives. The rst is to learn new things continuously. The second is to make sure that appropriate inormation is available to operators and other ront-line personnel in a manner that helps them make sound decisions. The third is to try not to orget what has already been learned. The learning aspect includes eorts to develop, discover or otherwise enhance process saety knowledge. 4. Workorce involvement. The workorce involvement element helps makes sure employees and contractors participate in the design, development, implementation and continuous improvement o the RBPS program. It also includes a means or two-way communication and consultation between management and workers with respect to the RBPS program and input provided by workers.

RBPS Elements The ollowing 20 elements expand upon the original CCPS PSM elements to refect 15 years o experience in PSM implementation, the best practices rom a variety o  industries and worldwide regulatory requirements. 1. Process saety culture. The saety culture element encompasses a system that establishes, evaluates and maintains a corporate and acility culture that places high value on process saety. The leaders o an organization must rst determine the level at which the saety culture currently unctions. Then they must decide where they wish to take the culture. Finally they must chart and navigate a path or maintaining and improving saety culture. This element includes eectively communicating and demonstrating established company saety values to company personnel and providing adequate resources so that process saety goals are achievable. 2. Compliance with standards. Compliance involves a system that can identiy, 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 saety and to establish relationships with other acilities/companies and proessional groups in the area, including neighbors and local, state and ederal organizations. Stakeholder outreach activities also provide inormation about the acility/company and its products, processes, plans, hazards and risks, and they promote the involvement o the acility/company in the local community and communicate inormation and activities that could aect the community. 6. Process knowledge management. The process knowledge management element addresses the storage and retrieval o technical data and process knowledge. This element includes work activities so that the inormation is kept current and accurate, stored in a manner to acilitate easy retrieval and accessible to employees who need it to perorm their duties related to process saety. 7. Hazard identifcation and risk analysis. Hazard identication and risk analysis is a process or identiying hazards and evaluating the risk o processes – throughout their lie 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 o quality, detail and timeliness; having a system in place to make risk decisions; and ollowing 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 perormed and the expected response (and, in some cases, particular responses to dangerous situations). This element includes operating procedures that address all modes o operation, but it does not include sae work procedures and maintenance procedures, which are addressed in the next two elements. 9. Sae work practices. Sae work practices include an integrated system o policies, procedures, permits and practices that control work that is not part o the normal operation (that is, not covered by the operating procedures element). Sae work practices oten are applied to construction work, particularly i the work might aect other operations at a acility. 10. Asset integrity and reliability. Asset integrity and reliability is the programmatic implementation o  activities necessary to make sure that important equipment will be suitable or its intended application throughout the lie o an operation. This element identies and helps prevent the ailure o critical equipment or systems. It includes activities to (1) nd unsae/undetected ailures, (2) measure the rate o component wear or degradation, (3) conrm that saety systems will perorm as intended i needed, (4) dene and ensure quality in written procedures, in the documentation o test results and through proper repairs or replacements as indicated and (5) provide a system to guarantee that deects are not introduced in abrication, installation or repair. 11. Contractor management. The contractor management element assists in making sure that services are procured and provided in a ashion that is supportive o the implementation o the RBPS system and o the organization’s process saety and conventional worker saety perormance goals. It addresses the selection, acquisition, use and monitoring o services. 12. Training and perormance. 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 perormance standards, maintain their prociency or qualiy or promotion to a more demanding position. Perormance assurance is the means by which workers demonstrate that they have understood the training and can apply it in practical situations. 13. Management o change. Change management is a process or reviewing, evaluating and authorizing proposed adjustments to acility design, operations, organization or activities – prior to implementation – to make certain that no unacceptable hazards are introduced and that the risk o existing hazards to employees, the

public or the environment is not increased above a tolerable level. 14. Operational readiness. Operational readiness includes a number o integrated work activities designed to conrm that a process is ready or operation prior to introducing hazardous materials. This element addresses activities to secure equipment readiness, such as conrming that the equipment is abricated 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 o operation and, in some cases, technical support or the startup o new or modied equipment. 15. Conduct o operations. Conduct o operations includes activities to warrant highly reliable human perormance on a day-to-day basis. Whereas written procedures and training tend to be episodic, conduct o operations occurs continuously. It includes activities to (1) conrm that policies and procedures are ollowed, (2) prevent worker-to-worker and shit-to-shit communication errors, (3) communicate management’s priorities and intent (which complements the saety culture element), (4) provide the knowledge needed to recognize when there is a confict between written procedures and management intent and take appropriate action and (5) support eorts to instill the discipline within the organization to do things right, whether the activities aect process saety or other key organizational objectives. 16. Emergency management. Emergency management includes (1) planning or possible emergencies, (2) providing resources to execute the plan, (3) practicing and continuously improving the plan, (4) training or inorming employees, contractors, neighbors and local authorities on what to do, how they will be notied and how to report an emergency and (5) eectively communicating with stakeholders in the event an incident does occur. 17. Incident investigation. Incident investigation is a process or planning or, reporting, tracking and investigating near misses and accidents. It includes the ormal process or investigating risk-signicant incidents, including stang, perorming, documenting and tracking investigations o process saety incidents, and it also involves the tracking o incident and incident-investigation data to identiy risk-signicant recurring incidents. This process manages the resolution and documentation o  recommendations generated by the investigations. These eorts constitute a way o learning rom risk-signicant incidents that occur within the organization over the lie o the acility and communicating lessons learned to internal personnel and external organizations.

18. Measurement and metrics. This element establishes a system or developing and collecting data or process saety metrics. The system establishes the ramework or measuring perormance and eciency through the use o leading and lagging indicators. It describes how the company uses these metrics to improve process saety eectiveness and provides tangible benchmarks or determining whether the company is meeting its continuous-improvement goals. 19. Auditing. The auditing element addresses scheduling, stang, and eectively perorming and documenting periodic audits o the RBPS elements to evaluate whether the management systems are perorming as intended. It also provides a system or managing the resolution o  ndings 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 o RBPS elements to ocus attention and resources on areas where improvements can be made. Management reviews are more requent than audits but less extensive since they tend to spotlight only selected process issues. This element identies sources o inormation typically developed or collected or management review o a PSM element, including recent incidents, current metrics, applicable audit results and corrective-action status. The results o a management review provide direction or continuous improvement and refect on the ecacy, perormance and eciency o  a acility’s process saety program.

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How to Use RBPS The RBPS system may encompass all process saety issues or all operations involving the manuacture, use, storage or handling o hazardous substances or energy. However, each organization must determine which physical areas and phases o the process lie cycle should be included in its ormal management systems, based on its own risk-tolerance considerations, available resources and process saety culture. Figure 2 oers examples o  how work activities may be dened according to RBPS elements and practices. Continually Strive to Do Better – Culture Is t he Key Culture is the result o all the actions and inactions in institutional or workorce memory that infuence individual behaviors and tendencies. The essential eatures o a good saety culture are: • Saety as a core value • Strong leadership • Sense o vulnerability • High standards o perormance • Individuals successully ullling their saety 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

a. Program grooms senior managers.

planning.

b. Program grooms senior managers and technical personnel; it requires at least

d. Program is organization-deepand includes competency

one completed process safety assignment.

maintenance,protection and improvement.

• Deerence to expertise • Open and eective communication • Questioning/learning environment • Continuous monitoring o perormance • Mutual trust • Timely response to saety issues a nd concerns • Formalization o a saety culture emphasis and approach As people strive or zero incidents, they will continue to extract and apply the lessons derived rom those that do occur and look or better ways to assure good perormance. Technical issues can be xed. Management systems issues can be xed. But to generate better, sustainable perormance, organizations must ormally address ways to evaluate and improve individual and organizational process saety culture (Figure 3). Companies will understand that doing all three will lead directly to saer 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 identication 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

c. An initial HIRA is completed, and periodic

d. A series of HIRAs is performed, each specic to

designreview.

updates are performed.

a discrete stage of the life cycle.

15. Management of change (MOC)

5. Provide training on the

a. Informal

b. MOC practice is broadcast

d. MOC initial and refresher

MOC system.

training is

via e-mail one time.

training is provided to

provided.

Incidents

aected personnel.

Precursors

22. Management review and continuous improvement  22.3.1 Maintain a dependable practice Dene roles and responsibilities

Management System Failures

1. Develop a written policy

a. General

b. Detailed guidance addresses

c. Detailed guidance

for management review.

guidance applies to all elements.

specic management review requirements.

addresses specic requirements for each RBPS element.

Figure 2: Examples o how risk aect s the implementation o RBPS work activities; rom Guidelines for Risk Based Process Safety , AIChE Center or Chemical Process Saety (New York: Wiley, 2007).

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“Learn Lower” on the Pyramid Accidents

15.3.1 Maintain a dependable practice Involve competent personnel

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

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Unsafe Behaviors and Attitudes

Culture – Individual and Organizational Tendencies

Figure 3: For sustainable perormance, an organization must ocus on its overall process saety culture.