Process Safety Management (PSM) - Prevention through Design (PtD), Process Hazard Analysis, and Continuous Improvement

When the PSM Standard 29 CFR 1910.119 was promulgated by the US Occupational Safety and Health Administration (OSHA) it came with a mandate?that a management system comprising several well-defined elements be established “for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals.” The process safety information (PSI) element of the PSM rule states, “The employer shall document that equipment complies with recognized and generally accepted good engineering practices,” with specific reference given to “relief system design and design basis.”

Although OSHA does not explicitly use the term “continuously improving” in its regulatory standards, it uses equivalent terms such as “accurate, complete, clear and ongoing,” as in the Appendix C compliance guidelines of 29 CFR 1910.119, which uses the term “complete and accurate” in lieu of “continually improving.” Likewise, for the mechanical integrity element of 29 CFR 1910.119, OSHA uses the term “ongoing” to describe the expectation to continually improve.

According to the Center for Disease Control and Prevention (CDC) website, prevention through Design (PtD) seeks to ”prevent or reduce occupational injuries, illnesses, and fatalities through the inclusion of prevention considerations in all designs that impact workers. “Designing out” occupational hazards and risks is the most effective way to protect workers. Without a doubt, the mission of PtD efforts dovetails with the high standards for initial design and continuous improvement required by PSM operators and should be an integral part of the process of designing and writing programs and procedures for a PSM facility.

PtD would be most suited for insertion in to the PSM design process in the very beginning of a project that involves a PSM facility. Stakeholders should be brought to the table along with skilled engineers and safety professionals to discuss each of the system components and any potential issues or flaws that might cause a hazard when a plant goes operational. While PtD can’t predict future issues or upgrades the simple process of providing for PtD design reviews, can set a PSM facility up with room for improvement as the regulatory environment and new technologies come to bear.

However, let us face it. PSM regulations and formal management systems created by individual companies have been in place for sometimes more than 20 years. Because PSM is widely credited for perceived reductions in major accident risk and in improved chemical industry performance, companies struggle to keep continuously improving the system due to resource pressures, inadequate management system audit results, and stagnant process safety incident performance.

Continuous improvement can address performance issues or efficiency issues or both. Companies should continuously seek new ways to improve PSM activities using a programmed, specific process for evaluation such a Process Hazard Analysis (PHA). OSHA characterizes the performance of a?PHA as “:a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals.” If PHA is part of PSM, then it follows that PSM owners need to identify the parts of the PSM chain that pose the greatest risks and begin evaluating those first.

In order to identify the greatest risks, the PHA must be performed in a rigorous and systematic manner in order to identify, evaluate, and control the parts of the process systems involving highly hazardous chemicals. As with PtD, a PHA should look at safeguards that are already designed into the process system and identify areas where risks pose concern and/or are unacceptable. Therefore, continuous improvement is a given. Note that the end goal of performing any PtD review during design or periodic PHAs?is not to label a process as “safe”, but to detect unprotected situations and trigger the necessary safety improvements to reduce or minimize risk.

Many organizations continue to be challenged by the PSM requirement of continuous improvement due to resource pressures, inadequate safety oversight and expertise, lack of adequate or sparingly produced audit results, and failure to take an active stance on safety incident investigation, review, and improvement of post-incident performance. The truth is that most companies claim to advocate for continuous Improvement of their PSM program and associated equipment and systems, but few actually put any substance to the words and requirements of the PSM written programs and procedures, and – resultantly - succeed in practice.

If you are a safety professional that is in charge of the compliance and risk assessment and management of one or more PSM facilities, what then is your plan of attack for continuous improvement. Most certainly, it is a hard road indeed. Here are some practical tips:

? Promote meetings and scheduled reviews such that engineers, designers, safety professionals, management, and other stakeholders can gather together and workshop how to safely prepare the PSM plant components for maintenance, large-scale plant turnarounds, inspections or engineering intervention .

? Ensure all stakeholders have access the right process safety engineering information. Learning from previous designs and improvements can be an onerous task if documentation is not complete and organization, and real-time operational status is not being tracked.?

? Agree with all stakeholders (especially management and operators) that control and shut down of operations must comply with regulatory requirements, but also occur when the slightest intuition of faults in the PSM system or potential risk is noted.?

? Information related to potential hazards of chemicals, processes, technology and equipment must be easily available to everyone in the facility, especially the workers at the line level that must be able to make decisions under pressure at a moment’s notice.

These tips serve as a baseline for the PHA, ongoing hazard analysis, and risk assessment process in PSM facilities. Information provided by the documents maintained from the original design, and documentation of every continuous improvement measure must be sufficient for ant upgrade work, ongoing operations and maintenance. Audit results that find incomplete documentation or flaws in documentation such that additional risk is created must be immediately found and integrated into the institutional knowledge database.

Sound daunting? It is. My experience with PSM consulting has uncovered many of the flaws and pitfalls that organizations experience when trying to initially design the safest system (insert PtD!) and shortcomings associated continuous improvement documentation, design decisions, and audit performance and follow-up. I’ve said it before and I will say it again for those in the back – if you need help with an unfamiliar or daunting risk-filled project like righting the ship with your PSM program and related systems – there is no shame in phoning a knowledgeable colleague or trusted consulting expert.