Brewing A Process Safety Perfect Storm

Introduction

We find ourselves in April 2020 in unprecedented times globally. Entire countries are shutdown, oil prices are at relatively low values and more people than we would normally expect are unwell in our workforce. This all because of an invisible killer, COVID-19. However there is a potential that this situation we find ourselves in is actually breeding the perfect storm in the process industry and if we are not careful in how we manage our workplaces in the coming months we could further add to the ‘unprecedented’ news reports. In this article I will discuss the areas of focus for the coming months and how these areas played into two overfill scenarios which had disastrous consequences.

Delayed Impact

It is well known and documented that the accidents of today (particularly process safety ones) are generally linked to the mistakes of the past. In general process safety accidents require several failures to occur simultaneously. In an incident one can often identify the final action which led to the incident on that day however further investigation normally reveals that the systems which should have prevented the incident or reduced the severity were not operational or defective and had been for some time. This has been the theme of many of my LinkedIn posts since December 2019.

Already in late 2019 and early 2020 I observed more than the usual reports of incidents on LinkedIn (one included). This may be due to increased use of LinkedIn or it could be in line with the observations from the 2019 Marsh Report that the exodus of older generation in our workforce could be impacting our process safety knowledge transfer?

With this in mind we need to understand that the decisions made during this COVID-19 crisis may impact our operations today or our operations in the future with devastating consequences from health and safety perspective as well as environmental and financial. These decisions are likely to be focused in the following areas:

-       Delayed maintenance activities

-       Personnel performance

-       Delayed project work

In the next sections I will discuss these in turn and some of the impacts on process safety which may or may not be apparent to everyone involved in the decision making. I acknowledge that the OIMs and facility managers are acutely aware of these impacts however there is a large proportion of support staff who may find this useful. As with all my articles this is intended as an educational tool to spark discussion so please do not take offence.

Delayed Maintenance Activities

To reduce manning to only the critical manning required to comply with government guidelines or as a result of illness in the workforce there may be decisions to delay maintenance activities until things ‘return to normal’. This is completely justified in these times and has been done on other occasions in response to large global events such as the 2010 Icelandic Ash Cloud. In doing this though there are some things to keep in mind to ensure that critical activities go ahead before they lead to accidents in the workplace:

-       Each task must be considered individually. Not every relief valve is the same and not every shutdown valve has the same criticality. When large portions of maintenance are delayed there is a potential that tasks which were previously delayed for some other reason or which are related to systems already showing signs of weakness are also included in this delay.

-       A time limit should be applied. These tasks should not be delayed indefinitely. Given the oil prices in the last 5 years there is a potential that your plan has already been stretched to make sure that resources are maximised in the financial climate. Therefore an indefinite delay or delaying the task until the next scheduled event may not be appropriate.

-       Plan for the ramp up. Often after times of hardship focus is given to expansion and growth to maximise future gain however it can be far more economical to conduct the overdue maintenance tasks especially if an incident occurs as a result of not completing them. Use your team who are not out in the field to start planning how the tasks which are critical and have been delayed can be completed efficiently when you ramp back up. This will allow the engineering team to work on the expansion work while the team in the field execute the maintenance if things are well planned. Materials could be on order and may be able to be produced and shipped if social distancing can be observed.

-       Complete a regular review. This may go on for longer or shorter than we expect. A good way to keep a regular review is to record the safety critical exceptions using an operational risk assessment. This would then be reviewed by each new shift coming on (ideally daily but potentially weekly) and therefore can be examined with new information coming from the field. For example if you delayed the maintenance on the high level switch but now found out you’re having problems with the level control instruments you may want to redeploy your resources.

Personnel Performance

In this section I will discuss three items which can be impacting the frontline performance which could lead to a weakening of your process safety management system at this time.

First is the potential that there is personnel substitution. As with any illness people are substituted on site. In this time there is a potential that the number of substitutions are much higher than normal. Couple this with the significant loss of experience from the 2015/16 down manning efforts there is a potential that the person doing your critical tasks, responding to abnormal situations and making split second decisions is not used to, trained or competent to do so. Care must be taken in this substitution process and there may be some call from the frontline to change shifts around or for overtime for critical personnel to accommodate competency gaps.

The second is the potential that manpower has been reduced or that different working practices are employed to accommodate social distancing. In this case people may not have the ullage in the teams to accommodate illness or absence for family reasons which puts a great mental stress on your team if there is pressure to remain operational. As a rule of thumb a stressed operator is ten times less effective compared to a non-stressed operator. New practices may be put in place for critical tasks such as tool box talks or permit issue to reduce contact. This however could have a negative impact on the effectiveness of these procedural controls. From experience when you’re not looking at the same thing you can often form different pictures, this can be especially dangerous when preparing a high risk job. For example sandblasting, the incorrect line could be sandblasted leading to loss of containment.

The third aspect is distractions to staff. Although we are all professional the media coverage and the worry for loved ones would undoubtably introduce a distraction to any person in your workforce. This coupled with the two items mentioned above can significantly impact the performance of the people remaining on your operation. Being kind during this time however being clear as to when the focus needs to remain on can help combat this. This may be a time to consider reduced working times with more shifts to allow people to cope with these unprecedented times if it is possible in your operation.

Delay to projects

There are three main types of projects and delays to them may have different impacts in your operations today as well as in the future.

Delay to improvement projects

Historically improvement projects are the ones which are seen to be dispensable. These are projects which do not increase production on the facility however can ensure that the current facilities remain within the operating envelope. However this has led to several improvement notices and some prohibition notices on offshore platforms, for example when fabric maintenance campaigns are delayed or cancelled due to oil price drop or to accommodate expansion projects. 

Expansion projects are typically those which increase production or are there to maintain the current production baseline. These projects may be delayed at this time due to lack of resources or due to lack of funds to pay engineering teams. There may be a lack of field information as surveys have been cancelled or postponed. This may not have a direct impact on process safety now however in the future these delays will place increased pressures on operations to operate to deliver production. This can (but does not always) result in behaviour which may undermine process safety systems (see Richmond fire).

Greenfield project delays. These projects are new projects to bring additional production online to maintain the production levels in an area or start new supply chains. Delays in these mean that overall the global supply may not be able to meet the demand in the coming years (likely in 2-5 years’ time) which would place increased strain on the existing operations and may result in the behaviours mentioned above which may undermine process safety systems. This may include things such as delaying turn around activity or a general reluctance to shut down a system which may result in a delay in doing the right thing.

Overfill protection

So how does this relate to this month’s topic of overfill protection. Over the next few weeks I will put online examples of where some of the issues mentioned above contributed to large overfill incidents. These incidents happened despite there being generally good process safety management in place. This is because generally overfill protection is included in code requirement when building tanks, pressure vessels etc. Generally, as is seen by the incidents discussed this month, the incident occurs when the designed and installed overfill protection falls into disrepair. In most cases the overfill does not result in severe consequences (for example there have been several incidents of petrol tank overfilling which did not result in a vapour cloud explosion) and therefore this can lead to a lower importance being placed on these protections. However, if the conditions are right the consequences can be severe. 

Keep up to date with what's coming by visiting louisewhiting.online.

Later this month you can expect:

-       A worked example of overfill scenario identification (SARS Webinar)

-       Some examples of what can go wrong (1, 2 and 3)

-       Some audit checks (1 and 2)