Harnessing the Power of Process Safety Knowledge

The goals of Process Safety Management (PSM) are fewer risks, fewer accidents, and a better knowledge of why they happen. Nonetheless, I've lost count of the number of times I've read the following in an incident report, “...has repeatedly failed to implement the proposed inherently safer recommendations. Had this been done, the investigation team concluded, the accident could have been prevented.”

Year after year, incident investigations identify inadequate PSM systems as a major challenge. The issues of poor job continuity, knowledge transfer, and training have grave consequences for facility safety. Even if your facility has not suffered a chemical accident, the chances of an undesired event have increased due to the loss of critical process safety knowledge.

When Knowledge Didn’t Transfer

Some of these issues might have appeared recently in your own hazard analysis reports…

2002 First Chemical Corporation reactive explosion and fire ― The results of a 1996 hazard analysis study which indicated that the MNT temperature should be kept below 370°F to avoid decomposition were not used to modify equipment or processes. Their training, procedures, and material safety data sheets (MSDSs) also did not warn of the potential of an explosion. The facility lacked an effective system for evaluating hazards and for sharing safety information between different facility operations.

2005 Buncefield fuel depot fire ― Due to retirements and headcount reduction, knowledge about the design and operation of the tank process safety controls was not passed on from the vendor to the operational maintenance teams. Plant safety relied on the knowledge and experience of those with less than one year of experience onsite. The facility lacked an effective system for retaining, maintaining, and sharing critical knowledge from its installation, commissioning, and initial operation.

2013 Williams Olefins explosion and fire ― Facilities are especially vulnerable during start-up operations. Plant operations personnel were troubleshooting the reduced flow rate in the propylene production unit but lacked knowledge of the operating procedures for the reboiler switching, their PHA study lacked mention of an issue, and their pre-start-up safety review (PSSR) lacked information on the unit, just for a start.

Thermal expansion of a flammable hydrocarbon mixture caused overpressure of the reboiler and it ruptured during start-up operations, releasing over 30,000 pounds of hydrocarbons. The facility lacked an effective system for establishing written operating procedures, delivering adequate training, effectively tracking and completing action items, measuring the effectiveness of the Pre-Startup Safety Review (PSSR), performing PHAs that capture all safety concerns, and improving process safety culture.

Unfortunately, this list of incidents goes on.

Optimize Knowledge Transfer

Most of the gaps in existing safety programs can be attributed to the lack of well-defined workflow, documentation, and information management capabilities. The following are a few ways the Process Safety Enterprise? platform optimizes compliance with Occupational Safety and Health Administration ’s Process Safety Management (PSM) Standard elements.

1. Employee Participation

According to OSHA, covered employers must consult with employees and their representatives on the development and execution of hazard assessments, as well as the development of chemical accident prevention plans, and make these and other records required by the standard available.

How Does PSE Help You?

Task Management – PSE allows you to assign trackable tasks to employees for developing and implementing written operating procedures, such as PHA studies and other activities.

Document Management – Key safety information is secure and easily accessible to any/all employees.

2. Process Safety Information (PSI)

According to OSHA, covered employers must develop and maintain written safety information that identifies workplace chemical and process hazards, as well as process equipment and technology.

Dynamic Forms Management – Captures, stores, and shares all PSI information into a single centralized database. With its drag-and-drop feature, users can easily create powerful and complex online forms. Email notifications are triggered automatically to easily monitor a team’s progress.

Document Management – Enables easy access to PSI documentation in text or graphic format such as P&IDs, materials of construction, ERS design, chemical hazards information, and so on, regardless of file format and tool.

3. Process Hazard Analysis (PHA)

According to OSHA, covered employers must perform a workplace hazard assessment, which includes identifying potential sources of accidental releases, identifying any previous release within the facility that had the potential for catastrophic consequences in the workplace, estimating the workplace effects of a range of releases, and estimating the health and safety effects of such a range on employees, as appropriate.

How Does PSE Help You?

Project Management – Easily manage and communicate actions, identify deficiencies, and share recommendations with operations, maintenance, and other team members.

PSM Workflows – Comprehensive workflows guide users step-by-step through standard PSM processes such as Management of Change, PHA studies, incident investigation, and more, using dynamic forms.

Documented Compliance – Direct importation of PHA studies including findings and recommendations. Track and share action items, assign and schedule tasks, collaborate and store all information.

Increased Productivity – Bundled with our PHAGlobal? software, PSE? enables the comprehensive identification of all possible hazards, assigns and tracks recommendations and action items, and stores all related data, documents, and workflows into one centralized, secure system. HAZOP, LOPA, FMEA, What-If, and Checklist templates are included in PHAGlobal?.

4. Operating Procedures

According to OSHA, covered employers must establish a system to respond to the findings of a workplace hazard assessment that addresses prevention, mitigation, and emergency responses.

How Does PSE Help You?

Procedure Workflow – Workflow streamlines the creation of written operating procedures, updates, reminders, actions, certification, recertification, and management approval.

Document Management – Easy uploading and linking of procedural documents makes the information easily accessible, managed, and updated by any/all users ― including contractor employees. Digitize forms and manage legacy data seamlessly.

5. Employee Training

According to OSHA, covered employers must ensure employees receive the required safety and process training specific to any process they are involved in and have access to ongoing refresher training. Organizations must document all training using either a learning management system or by hand, ensuring that records are updated frequently.

How Does PSE Help You?

Training Workflow – Bundled with our learning management system @Process Safety Learning? (PSL), PSE simplifies the organization, tracking, and management of all training efforts, including refresher training.

Task Management – Assign training and send automated reminders for single or multiple facilities. Reports and updates are received regularly in their email inbox.

Documented Compliance – Capture, store, and share worker training records from one shared database. See employee competency status at a glance via the PSL analytics dashboard.

Customized Training – Custom course authoring services are also available through ioMosaic Corporation to further enhance compliance.

6. Contractor Management

According to OSHA, covered employers must ensure all contractor workers performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process are appropriately informed of any chemical hazards onsite. Contractors must also be adequately trained in safety and the covered process.

How Does PSE Help You?

Contractor Workflow – The workflow easily manages and communicates contractor selection, approvals, updates, reminders, and action items.

Documented Compliance – Track and share action items, assign and schedule tasks, collaborate with contractors, and store all information, including safety, and professional licensing competencies.

Document Management – Easy access to safety data sheets, facility operating procedures, and other information resources deemed necessary for safe operations. Can also restrict permission to files on a per-user, per-file, or per-group basis.

7. Pre-Startup Safety Review

According to OSHA, when covered employers establish a new facility, modify an existing one, or introduce new equipment, they must conduct a safety review. Potential safety hazards are more likely to be detected during an audit if proper documentation and a complete overview of any new process, system, or equipment are provided.

How Does PSE Help You?

Pre-Startup Safety Review (PSSR) Workflow – A workflow guides users step-by-step through standard Pre-Startup and Post-Startup processes using dynamic forms.

Project Management – Manage and communicate checklists, identify deficiencies, and share recommendations with responsible employees. Optional rapid review and approval of emergency PSSRs are included. Track and share action items, assign and schedule tasks, collaborate, and store all information ― including employee training records ― from one shared database.

Documented Compliance – The interconnectivity of our modules, such as Management of Change, PHA studies, incident investigation, and more, simplifies data entry saving you time. Users can directly import findings, recommendations, and action items.

8. Mechanical Integrity

According to OSHA, covered employers must ensure critical process equipment is designed and installed correctly. This is true for storage tanks and vessels, pumps, piping systems, valves, emergency shutdown systems, and controls. Workplace procedures must be developed and applied, and appropriate training must be provided. Equipment flaws must be fixed in a safe and timely manner.

How Does PSE Help You?

Mechanical Integrity Workflow – Workflows make it easy to identify and address deficiencies and streamline the creation of written operating procedures and equipment forms for an effective Mechanical Integrity program. Equipment forms include the option of recording the thickness measurement of equipment such as piping, tubing, pressure vessels, or tanks, to allow for corrosion rates and end-of-life calculations.

Action Tracking – Tracks and documents inspections due and task completions in one shared database, keeping your team aligned with a common roadmap and eliminating confusion. A formal approval flow process makes company safety procedures better and easier for everyone.

Documented Compliance – Easy uploading and linking of associated equipment and inspection documents, mechanical drawings, procedures, etc., making the information accessible to any/all employees and contractor employees.

9. Hot Work Permit

According to OSHA, covered employers must ensure there is a systematic process for permission and monitoring when working with fire or other sources of ignition.

How Does PSE Help You?

Hot Work Workflow – A workflow guides users step-by-step through operations using dynamic forms, providing permit documentation control, and verifying safety requirements have been met. Managers can choose to renew, extend, or revoke open work permits.

Document Management – Access to open and closed work permits for historical recordkeeping and audits.

10. Management of Change

According to OSHA, covered employers must conduct a systematic review of how changes to processes, equipment, or personnel could affect risk in their facility.

How Does PSE Help You?

Management of Change Workflow – The workflow guides users through a step-by-step process for standard functions such as MOC initiation, approval, PHA revalidation, pre-startup safety review (PSSR), start-up authorization, etc.

Action Tracking – Tracks and documents action items due and task completions, including email notifications with linked documentation, ensuring changes are properly captured and visible. Historical work completed and upcoming work needed is easily identified and visible across the facility.

Hear What a Client Says About PSE Management of Change Workflow

11. Incident Investigation

According to OSHA, covered employers must thoroughly investigate and report on incidents in the workplace to identify the chain of events and root causes. Workplace procedures must be in place for developing corrective actions and tracking action items through to completion.

How Does PSE Help You?

Incident Investigation Workflow – The workflow guides users step-by-step through incident notification, team selection, incident data gathering, incident causal analysis, report approvals and recommendations, and incident classification.

Documented Compliance – Track tasks, share action items, and notify individuals via email, ensuring the investigation proceeds in a timely manner.

Document Management – Secure information collection, distribution, storage, processing, and archiving for one or multiple facilities. File links can be shared for secure collaboration inside and outside the organization. Regular, automated backups and software updates are all managed via the hosting site.

12. Emergency Planning amp; Response

According to OSHA, covered employers must develop and implement an emergency action plan for the entire plant according to OSHA rules. Employees must also be adequately trained to respond to a potential workplace emergency.

How Does PSE Help You?

Documented Compliance – Create evergreen, digital guidelines for workplace emergencies using a drag-and-drop form builder. Add tabs, drop desired components onto the canvas, and adjust the appearance. Recording information on procedures for reporting, evacuation, critical plant operations, employee contact details, etc. is easy and seamless.

Document Management – Easy sharing of emergency action plan (EAP) documentation with workers, contractors, state agencies, and emergency responders. Various file options include text or graphic formats such as P&IDs, materials of construction, facility plans, chemical hazards information, etc. Set permission levels to read, change, or full control, with the ability to add an expiration date.

13. Compliance Audits

According to OSHA, covered employers must review and verify at least once every three years that company procedures and practices meet compliance with the OSHA PSM Standard.

How Does PSE Help You?

Documented Compliance – Search for key safety information such as written operating procedures, Process Hazard Analyses (PHAs), safety reviews, etc., in one central location to access information faster. Track and share action items, assign and schedule tasks, collaborate with employees, and store all information.

Action Tracking – Track and document tasks in one shared database, keeping your team aligned with a common roadmap free from confusion.

14. Trade Secrets

According to OSHA, covered employers must disclose all required process safety information to workers and contractors in order to comply with the OSHA PSM Standard.

How Does PSE Help You?

Document Management – Key safety information is secure and easily accessible to any/all employees. Files can be shared via a link with external parties for secure collaboration inside and outside the organization.

We Can Help You

During mergers, acquisitions, industry redundancies, or job losses, valuable safety knowledge is at risk of being lost. Deloitte Consulting LLP’s analysis of the chemical labor market tells us, “About 106,000 jobs could remain unfilled between 2021 and 2030. The industry workforce is aging. As much as 25% of the industry’s workforce will likely be eligible to retire in the next five years.”

Take a bold step to mitigate. DM me here at Tao Yao or contact me online to discuss how we can better harness the power of safety knowledge at your facility. ioMosaic Corporation can help you manage and reduce episodic risk, maintain compliance, and prevent catastrophic incidents around the world.

#processsafety #knowledgemanagement #OSHAcompliance

References

U.S. Department of Labor. (2000). Process Safety Management. Retrieved from Occupational Safety and Health Administration (OSHA) website: https://www.osha.gov/sites/default/files/publications/osha3132.pdf