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July 18, 2014
Process safety: Evolving protection, persistent challenges

Chemical accidents make headlines and rob families of loved ones. They also cause extraordinary damage to communities and the environment. This Compliance Report focuses on process safety management (PSM), the regulation that aims to prevent unwanted releases of hazardous chemicals.

It’s a vast subject with many moving parts. This article provides an overview of OSHA’s PSM standard, advice on prevention from a respected thought leader on the subject, and perspectives on small business compliance. We also address the topic of safety leadership and the role of company executives in incident prevention.

A brief look back

In May 1992, OSHA promulgated the process safety management standard (29 CFR 1910.119). According to the agency, “Process safety management is the proactive identification, evaluation, and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment.”

The standard came in the wake of several high-visibility chemical incidents. A devastating release in Bhopal, India, in 1984 caused more than 2,000 deaths. In 1989, 23 people died in the Phillips Petroleum Company incident in Pasadena, Texas. But unfortunately, the OSHA standard did not mark an end to process-related tragedies. In 2005, an explosion at the BP oil refinery in Texas City killed 15 workers and prompted OSHA to issue the largest citation and penalty in its history. That same plant would be cited and fined subsequently. In April 2010, an explosion and fire at the Tesoro Refinery in Washington State led to the deaths of seven employees. And in 2013, a tragic explosion at a Texas fertilizer company killed 15 and injured 160.

OSHA stakeholders are currently revisiting the PSM standard. In the wake of the fertilizer plant tragedy, OSHA issued a call for comments in advance of possible changes to PSM. The request came on the heels of an Executive Order for federal agencies to come up with new strategies for preventing chemical accidents.

Recently, a working group of federal agencies including OSHA and the Department of Homeland Security publicized their recommendations. They fall under five categories:

  • Modernizing policies and regulation,
  • Strengthening community planning and preparedness,
  • Enhancing federal operational coordination,
  • Improving data management, and
  • Incorporating stakeholder feedback and developing best practices.

The working group concluded that OSHA should address improvements in the content and enforcement of the standard and incorporate lessons learned over the past two decades.  According to an OSHA spokesman, the agency will work over the next year to:

  • Clarify confusing and misunderstood policies;
  • Revise the interpretation of “retail facilities” to more accurately reflect the intent of the exemption of such workplaces; and
  • Revise the current interpretation of chemical concentrations covered by the PSM standard to more clearly describe what is covered and align better with established practices.

Of particular concern is coverage of thermally unstable materials, which are not currently addressed by PSM.

What’s covered?

Until changes are made, the standard is in force, and affected employers are required to comply. The 14 elements of a PSM program include:

  • Process safety information,
  • Process hazard analysis,
  • Operating procedures,
  • Training,
  • Contractors,
  • Mechanical integrity,
  • Hot work,
  • Management of change,
  • Incident investigation,
  • Compliance audits,
  • Trade secrets,
  • Employee participation,
  • Pre-start-up safety review, and
  • Emergency planning and response.

OSHA advises, “The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each level.”

The PSM standard applies chiefly to manufacturing industries—those involved in chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. PSM is also applicable to pyrotechnics and explosives manufacturers covered under other OSHA rules.

The standard affects businesses that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities. And it includes flammable liquids and gases in quantities of 10,000 pounds (lbs) or more.

PSM clarifies the duties of employers and contractors involved in work that affects or occurs near covered processes to ensure the safety of the plant, employees, and contract workers.

Process safety information is a critically important requirement. Employers must compile relevant written information before conducting any required process hazard analysis. This includes data on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology involved, and information on the equipment involved. Chemical information must address at least:

  • Toxicity,
  • Permissible exposure limits (PELs),
  • Physical data,
  • Reactivity data,
  • Corrosivity data, and
  • Thermal and chemical stability data and hazardous effects of inadvertent mixing of different materials.

Process hazard analysis (PHA) is a thorough and systematic review for identifying, evaluating, and controlling the risks of processes involving highly hazardous chemicals. In essence, PHA is a review of what could go wrong and the safeguards that must be in place to prevent chemical releases. The standard details possible methods to determine and evaluate the hazards. At least every 5 years after the initial PHA, the process must be updated and revalidated.

Another key element of compliance is OSHA’s requirement for employee participation. Under PSM, employers must consult with employees and their representatives on the design and development of process hazard analyses and on development of the other elements of process management.

LEADERSHIP: INVISIBLE BUT ESSENTIAL ELEMENT

Thought leaders like  Sam Mannan, PhD, director of the Mary Kay O’Connor Process Safety Center at Texas A&M University, acknowledge that leadership is essential to reducing process safety incidents.

What does leadership look like at a chemical manufacturing or distribution company? The British-based Chemical Industries Association (CIA) found out by visiting 26 member companies. According to the organization, “The aim of the initiative was to capture best practice in process safety leadership from within our industry, and then to share these lessons widely….”

The following are the best practices they identified:

Getting the board on board. At one company, a process safety director was appointed to give new corporate impetus to safety. Among other tasks, a board leader should ensure that process safety is covered at all board meetings.

Setting safety policy and expectations. Companies with significant risk need to go beyond compliance basics to achieve best practices. A clear statement from the board communicated to all staff should address the importance of process safety. It should include details like expectations and targets and should review arrangements.

Enhancing visibility. Leader visibility can take many forms. In small companies with few sites, the most senior manager can visit often. But at large global companies, this is less likely. Other strategies include e-mail and teleconferences with managers and staff.

Measuring process safety performance. Develop metrics to measure the effectiveness of prevention and control measures (leading indicators) as well as incidents of failure (lagging indicators). Such scorecards keep leaders in tune with the success of the program and reveal areas where improvement is needed.

Planning for process safety improvement. Leaders should be consulted on the development of an annual plan that identifies priorities for systems and hardware to safeguard processes and inventories.

Making safety second nature

One of the most respected voices on process safety management is that of certified safety professional and chemical engineer Sam Mannan, PhD, director of the Mary Kay O’Connor Process Safety Center. As part of the Texas A&M University Engineering Station, the center helps minimize losses within the process safety industry through education, research, and consultation.

The center (http://process-safety.tamu.edu) was established in 1995 by chemical engineer T. Michael O’Connor. His wife Mary Kay, also a chemical engineer, was killed in the Phillips Petroleum explosion in 1989. O’Connor explained that he and Mary Kay were never taught that process safety was part of their work as chemical engineers.

According to Mannan, a professor at Texas A&M who spent decades in industry, the center is extending its reach beyond engineering to students in other disciplines. “Many decisions are made by people in management, accounting, public policy, and other areas. So we are stepping out beyond chemical engineering and petroleum engineering and into those areas.” The O’Connor center is also expanding to offshore locations, with a sister facility now operating in Qatar.

Mannan believes that the key to achieving zero accidents is to make safety second nature. Achieving that, he says, requires an entire organization. From the CEO to front line operators, designers, maintenance people, and those in procurement, safety, and instrumentation—all must have accountability and responsibility for safety.

Safety must be integrated into every task and position. “No one in any organization should say, ‘Safety isn’t part of my job.’ It has to be everyone’s job and it has to be automatic.” He explains this using the example of someone crossing the street. One wouldn’t say, “It’s my job to cross the street, but it’s up to someone else to make sure I do it safely.” It’s second nature for people to cross the street safely, which entails not only walking across, but also checking for traffic in both directions, stepping carefully off the curb, etc.

Similarly, for an individual who designs processes or make chemical products, it’s not enough to execute the design or combine the chemicals. That individual must also ask questions like, Are there safer chemicals that can be substituted?  Can we operate at lower temperatures or flash points? “Everyone has to think like that,” adds Mannan. “Only then can you get to a point where you can move to zero incidents and zero fatalities.”

Recurring themes

Mannan has participated in multiple incident investigations within and outside the chemical industry. Among the most visible of these projects was the inquiry into the Columbia shuttle disaster in 2003–2004. Mannan says he is often asked to identify factors that contribute to catastrophes. He points to the following:

Lack of safety culture. The key element in an effective safety culture is leadership—not just the CEO and a few top executives, but leaders at all levels. Leaders must be constantly engaged in safety and visible in their commitment. Other culture ingredients include employee empowerment and being a continuous learning organization.

Overreliance on human factors. One sign of a problem, says Mannan, is when companies conclude that an incident occurred due to human error and use that as an excuse to stop looking for other shortcomings. “To say that humans make mistakes is to say something as obvious as ‘We fall down because of gravity.’” Mannan encourages organizations to go beyond the inevitability of human error and address systems and processes that contribute to risk.

Professional competence. As a professor, this is a significant issue for Mannan. There are several elements involved—the first is adequate university preparation, which Mannan and his colleagues work to deliver. He also sees a need for continuous training. “Just because you got a degree from a good school doesn’t mean you’re done,” he advises young professionals. “You have to keep up with new research and technology.” Another competence factor is the ability to learn from other companies’ experiences. Learn all you can about what happened and review your own systems and practices in the light of failures at other sites.

Like other experts in the field, Mannan sees many opportunities to eliminate tragedies like the one that gave rise to the O’Connor process safety center. Most important is that the effort involves all stakeholders, including industry, government, regulators, and academia.

What about smaller companies?

Headline-grabbing process safety catastrophes often involve large corporations. But what about the thousands of smaller businesses involved with covered processes? What challenges do they face in reducing the risk for workers and the environment?

Bob Hendry is a research scientist at the Georgia Institute of Technology (Georgia Tech). He also serves as a consultant with OSHA’s free consultation program, which is headquartered there.

“With PSM if you get it wrong, you kill people. So it’s very important to get it right,” Hendry bluntly acknowledges. As a performance-based standard, PSM specifies the goals that must be achieved, not the specifics about how this must be done. For that reason, reading through the standard may not fully reveal the complexity of compliance, Hendry notes.

According to Hendry, smaller businesses struggle to determine (1) if they are covered under PSM and (2) how far that coverage extends. Once an employer finds that a process is covered, it can lead to questions about other processes or systems. Says Hendry, “Once you start pulling on a thread, where does it lead? For example, you think coverage is limited to a control room, but what about the chemicals you’re storing next door?”

Small businesses may find that their PSM compliance status can change quickly. For example, consider a company producing about 600 gallons of a flammable material. Because they’re well under the 10,000-pound threshold, they are not covered under PSM. (Hendry says a gallon equates to between 2 and 3 lbs.)

“The manufacturer is not over 10,000 pounds, but they’re making a good product and they get a big order. Suddenly they’re scaling up to 6,000 gallons.” That means the business is now producing well over 10,000 lbs and must comply with PSM.

Hendry helps businesses determine if they are covered under the standard. He also helps them understand that, in some cases, changes to their process can affect their status. "For example,” he says, “if the process produces 20,000 pounds of non-flammable aqueous product using a container of 6,000 pounds of alcohol with water, one way to avoid reaching the threshold quantity is to add the alcohol to the 12,000 pounds of water so that at no point in the process is there 10,000 pounds of a flammable substance.”

Complying with PSM is time-consuming and costly, especially for a small business. Henry also helps employers understand the importance of properly measuring hazardous chemicals that are delivered to the site. “If you have to know and track every pound that goes in and out, you need proper instrumentation and gauges. And you have to make sure your employees are watching the person who’s filling your tanks.” While everyone wants to get full value from a vendor, there’s a risk in over-filling a tank if that results in exceeding the threshold.

At the end of the day, says Hendry, small businesses need to “own” their PSM process and involve employees at every level. “You have to manage everything—even the placement of the nuts and bolts on the phalange can be incredibly important.”
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