RISK MANAGEMENT ADOPTING PROCESS SAFETY MANAGEMENT SYSTEM.

INTRODUCTION:

INDUSTRIAL SCENARIO:In less than half a century, rapid strides have been in Our Country (India) to progress from an

Agro-based economy to the current stage of World Class Information Technology Leader and an

emerging Economic powerhouse by collective efforts of all Stakeholders.

Diverse types of Industries such as Exploration & Production, Oil & Gas Processing, Refining,

Petrochemical, Bulk Drugs and Pharmaceuticals, Shipbuilding, Major Port Operations like large

Container Terminals, Mega Steel Plants, Mineral Processing, Heavy Equipment Manufacturing,

Automotive Sector, with related Small Scale and Other Industries form a vast canvas.

Current Status:

However the focus remains on Major Accident Hazard Category Industries such as

Refining, Fertilisers, Chemical and Petro-chemical units. The reasons for this focus are obvious.

They form the bedrock in manufacture of many popular items of common use including

agricultural expansion so to say “Crude to Food”. Hence the concerns of SHE tend to get

magnified here and rightly so.

Modern Industries are Big and Complex. Giant Machinery and intricate Processes (sometimes

with patented technology) coupled with nature of Operations involving High Pressures,

Temperatures and handling of Corrosive, Flammable, Toxic and Explosive substances justifies

the concerns. But the reality is SHE aspects start very much at the Conceptual & Design Stage.

Whether in a Major Hazard Process Industry or otherwise.

In such Process units Process Safety Management System starts with Design integration of

Loss prevention as a Proactive approach rather than Reactive damage control activity.

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Scenario in the era of Globalisation and Economic interdependence

(Only Illustrative and not specific to any region or entity)

--Intense pressure on profitability. Yet Safety is not universally a condition of employment.

--Compliance to safety not negotiable – no compromise (Cardinality not widespread).

--Criteria / weightage in personnel appraisals for Safe Manufacturing is still selectively adopted

--Safety beyond compliance – not just to meet minimum statutory requirements.

Philosophy to gain momentum.

--But Very high standards co-exist due to involvement of Government Regulators/Professional

Auditors, Some societal monitors, MNC, WB, IMF, EU, partnership, Indo-JV, and such.

--Technology / skills a subject of cost interface decision in preference to Upfront Safeguards.

--Responsible care (Good Corporate Citizen Image). Signatory numbers limited.

--Reflection of SHE in Company Mission Statements not widespread.

--Public interest litigation / public liability compensation, driving Reactive remedies instead of

Self-Regulating Proactive approach

--Safety a way of life more remains a slogan unless Off-the-job Risks and Safety is

viewed equally important

-- Safety not equaled as important function of Management as Manufacturing, Finance etc.

-- “Safety is everybody’s responsibility”--observed more to share issues than to identify

prevention remedies.

MANAGEMENT SYSTEM:

Management can be broadly defined as prudent deployment of resources like

Men (not gender specific), Material, Machinery, to generate Wealth, Knowledge & Economic

Value additions from Human and Capital assets, to all stake holders.

Human and Capital Asset:

The human element is inherent as Planner, Designer, Constructor, Occupier and Operator

including Contractors and others such as Regulators, Statutory agencies, Institutions such as the

Underwriters, Funding, Medical and Safety institutions, individuals like Consultants, Auditors.

In short, translating a Design to Destination Safety has a partnership role in Safety.

Conceptualisation:

A Facility is conceived on paper as a Layout. Engineering Design, Layout Planning,

Construction, Trial Runs, Stabilisation, Perfecting and Innovating translate this concept into

reality.

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Process Safety Management (Prelude):

PSM is a systematic approach to Process plant Safety. PSM is part of the

Code of Federal Regulations under Part 1910-119. It is a codification of the general and

permanent rules by the Executive departments and agencies of the Federal Government in USA.

Appendix C to this part contains compliance guidelines and recommendations for PSM.

Elements of PSMS:

1. Process Safety Information 2.Process Hazard Analysis 3.Standard Operating Procedures

4. Training 5.Contractor control 6.Pre-start up safety review 7.Mechanical Integrity

8. Non-routine work authorisations 9.Management of Change 10.Investigation of incidents

11. Emergency Preparedness 12.Compliance audit 13.Employee participation

1.Process Safety Information:

This should include Referenced Design codes and Standards including Relief and Ventilation

design, Materials of Construction, Line flow diagrams, P & IDs,

Process descriptions, Hazard material inventory, MSDS information including incompatibility

data, Equipment particulars, Operating parameters,

Hazardous area classification, Alarms, trips, Interlocks and Programme logic protocols.

2. Process Hazard Analysis:

There are many types of this and the analysis should be relevant and appropriate to the

complexity and stage of the Process Unit.

HAZARD EVALUATION TECHNIQUES – APPLICATION (TYPICAL LIST)

Cause – Consequence Analysis , Checklist Analysis, Diagraph Analysis, Event Tree Analysis

Failure Mode & Effects Analysis (FMEA), Fault Tree Analysis, Hazard Analysis

Hazard And Operability Studies (HAZOP), Hazard Warning Structure,

Human Reliability Analysis (HRA), Management Oversight And Risk Tree Analysis (MORT)

Multiple Failure Error Analysis, Preliminary/Process Hazard Analysis (PHA)

Relative Ranking, Safety Reviews, Job Safety Analysis, What – If and What – If Checklist

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Typical Applications

Activity Technique

Design PHA

Detailed Engineering Fault Tree / Event Tree Analysis

Construction / Startup Checklist / Safety Review

Pilot Plant Operation / HAZOP

Routine Operation

Decommissioning What – If , Checklist Analysis

Expansion HAZOP / Relative Ranking

R&D What – If

Incident Investigation What – If / FMEA / HRA

CCPS Book (AIChE) on Process Hazard Evaluation Techniques is an excellent reference for proper application. (Recommend Buy Book)Methodology:

The analysis methodology and Team size and composition can vary. Determining the priority of

the system that needs PHA based on the potential severity and likelihood is vital.

Use of Dow and Mond Index should have a thorough understanding of the General Process

Hazards, Special Process Hazards, Process Control factors, Loss control credit factors, Fire

protection system, to derive Base and Actual Maximum Probable Property impact damage

3.Operating procedures:

These should include ranges, limits of Safe Operations, deviation response measures, Normal

Start-up and Planned Shutdown procedures, Upset control procedures, Emergency handling

procedures, PLC security access authorisation, Safety device Bypass and interim hazard

management instructions, and Safety Do’s and Don’ts pertaining to the respective SOP. As a

recommendation, Do’s and Don’ts on Safety can be incorporated in the SOPs as an annex.

SOP review criteria should be established. Typical situations are: change of Process/ chemistry,

change of Operating parameters, Modifications, Equipment changes.

4.Training:

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Training still is mostly emphasised, but causally dealt with subject primarily because of return on

investment on time and effort is only visible in the future. Training process should be structured

with clear Goals and Objectives, based on Task analysis, Skills Gap analysis after objective

personnel evaluation criteria, with a structured calendar, participant profile, venue selection for

ambience, Trainer choice, duration prescribed, with subject topics relevant to the participants.

Levels of Training can be published both for budgetary purposes as well as progress evaluation

It should be treated as an on-going activity preferably with a specified budget and an absentee

profile that would invite serious Management attention. In short it should not be statistic driven.

Identification of trained workers, and a system of recall, refresh and review, reinforcement should

exist. Individual development needs Road Map based on Supervisor/Employee interaction, and

performance appraisal feedback, will ensure attention to specifics.

Video filming of Special works, Mock Drills, Building Evacuation, Training programmes etc can

be cost beneficial with greater impact.

Training Proficiency assessment and quantification is essential to evaluate return on investment.

Identification and grooming of internal Faculty for forming multi-skill Resource Pool of Subject

Matter specialists will serve the Company in Knowledge Management.

Generation of Individual employee training database will track oversights or omissions.

5.Contractor Control:

Safety Orientation and certification should be compulsory before work placement to all

Contractors/Sub-contractors, Temporary and Casual workers. World class Companies issue

Safety tips card to all visitors. As a minimum, Contractors should submit to the following.

Commitment at Tender and Delivery on an agreed periodicity of work assignment:

Safe work methods statements based on JSA

Worker Training and awareness on Site Safety and Fire prevention regulations

Tools certification

Job specific safety PEP-TALKS

Inspection checklists and site audit schedules

Implementation of measures for violation control

On-site safety performance statistics

6.Pre-start up safety review:

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Start-up checks: Typically these include but not limited to the following: Reaffirmation that PHA and Punch list items have been closed

Documented authorisation of Modifications and Changes

P & ID is validated

Equipment and work areas cleared

Internal clean up of equipment and piping using suitable Utilities

De-greasing, acidising and passivating of specific piping systems and equipment

Pressure testing of equipment and pipelines

Check of all panel mounted and field instruments

Functionality checks of fail-safe Engineered controls—E.g. Relays/Alarms/Trips/Interlocks.

Rotational checks of machinery

Lubrication and coolant line checks as required

Checking of vents, drains, steam traps

Utility Line and Hose connection checks

Checking of all PPE, Fire fighting equipment

Removal of all restrictions and blinds not required for start-up.

Functional check of all electrical appliances, switchgear, Transformers

Ensuring good communicating systems using work permits per SOP

Checking and dry run of start-up sequence activity

Trial run of equipment to ensure normality

Actual start-up

It should be borne in mind that Safety of Personnel and Asset protection is of paramount

importance and the competence of the Operating personnel during the training and the experience

gained by hands-on work will impose new requirements from to time.

The success of the start-up depends on teamwork and strict adherence to the Standard Operating

and pre-commissioning procedure and comprehensiveness of checklist developed at the site.

7.Mechanical Integrity:

The soundness of the system depends on the baseline data and subsequent data base creation.

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Equipment can be sorted category-wise and assigned individual history card. This can include

Material of Construction, specification sheets, Materials, time consumed, impact, and costing.

Schedule Annual Preventive Maintenance calendar should be drawn, with work instructions.

Values derived using calibrated instruments are to be compared to Design Specification. A ready

comparison sheet between design and P.M readings can be trend graphed in the form of

Paretto Diagram, Scatter Diagram, Histogram and such.

Agreements on deviations to schedules and any resultant impact should be documented.

A good P.M and Operational database can facilitate to generate Mean Time Between Failure

information for increasing On-time service hours. Beneficial accruals will be, base for

Predictive maintenance, Reliability Engineering data for equipment and components/

Plant Life Extension studies/Remnant Life Analysis, Sparing philosophy, to name a few.

The Focus point for effective testing and inspection programme should include

Engineered controls, Vents, drains, Flare lines, Elbows, Bends, Turbulent Spots, Spring hangers,

Pipe supports, Foundation Settlements, Stack top segments, critical isolation valves and

Non-Return Valves.

Inspection techniques vary. Reference to appropriate Inspection Standards is necessary

Individual Competency, Instrument and Result interpretation familiarity is essential

8.Non-routine work activities:

Verbal instructions are to be avoided when work is to be performed in an Owner operator area by

other Service providers. A system of work permits is to be adopted and most importantly

implementation and adherence verified. The nature and type of work permits and formats should

reflect the changing needs and reviewed based on Operational experience, Lessons learnt,

Best Industry standards.

Generally common permits are Routine Cold Work, Hot Work, Confined Space entry,

Line breaking, Excavation, Electrical Line clearance, Lock out/Tag out , Work at heights,

Bye-pass authorisations

9. Management of change:

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There should be a published procedure for any type of change i.e. Emergency change Temporary

change, and Permanent changes. Levels of approval authority should be part of the procedure

including associated checklist with signature provisions. A multi-disciplinary Change

Management Approval Committee should be formed, defined both for membership and tenure.

Approval request should include:

Change basis, Type of change, PHA/HAZOP, accrued benefit, Mention of Code/Standards

referenced, Material Specification Sheets, Design deviations if any, list of drawings such as

Block diagram, P & ID of relevant section, Proposed date of change, External approvals required,

Resource requirement and estimated payout factor without impact on SHE.

After Implementation Closure (Completion report) should address update of Isometric/P & ID.

Publishing Change Management request and approval flow chart will be useful handy reference.

10. Investigation of incidents:

World class Companies adopt the system of investigating all Incidents including Near Miss

and No Injury and publish for the knowledge of all employees and other site Contractors’

workers as lessons learnt to avoid repeat.

The reporting formats are also suited to the investigation methods, which are based on Root

Cause analysis for implementing not just Corrective action but more importantly Preventive

action. The focus is not on fault- fixing but fact- finding. This enables openness and transparency

at different levels to partner, to intervene and eliminate in time potentially lurking hazards, from

progressing to cause greater harm and impact damage.

The approach is not Company Employee focused. The Statistics are non-exclusive of all types of

Contractors workers and visitors.

Anomalies in reporting are reconciled between Plant records, Health centre records, Absentee

records, and insurance claim records.

11. Emergency Preparedness:

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While Incident free operation is the basic objective and goal, in reality layout considerations

do factor likelihood of impact in the event of any incident. To control, contain, mitigate and

eliminate the potential impact of harm an Emergency preparedness plan is published.

The Plan contents include Objectives, Emergency definition and Communication, assigned duties

to the Emergency response team, Resource mobilisation, Control and Protection Measures,

Safe Escape routes, Assembly Points, Facilities and equipment at the Emergency Control Centre.

12.Compliance Audit:

The audits are of many types: Routine walkthrough, Internal scheduled based on checklist,

Specialist Audits, Corporate Audits, Systems audits such ISO, EMS, OHSAS, ISRS, PSM,

Statutory audits, Third party audits, just to name a few.

The purpose of the audit should be for timely identification of potential source of hazards, and

identification of preventive measures before harm is caused. Most importantly, implementation of

recommendations based on audit observations is vital to ensure success of the audit efforts.

Audit Process should include Audit scope, Audit objectives, Audit frequency, Audit team,

Audit techniques, Pre-audit preparation, Audit Time-table, Audit actual, Audit reporting,

Post-audit review, Follow-through closure.

Actual audit should include Physical visit, connected document verification,

Personnel interaction, compliance status of prior audits observations and improvement plans.

The auditor/s should have a keen eye, independence, objectivity and possess the required

knowledge and qualification to conduct the audit and present the report summation logically.

Subsequent to the audit, Key focus areas are to be prioritised, action plan and accountability

assigned and closure followed through by verification. Outstanding items should attract senior

Management attention for closure.

13. Employee participation:

Bottom-up, lateral and Top-down involvement and partnership is vital for success of any On-site

Occupational Safety & Health Programmes. These are nurtured in many ways. Employee being

assigned his own area safety audit, implementing Safety suggestions Scheme, Involvement as

members of site safety committee, organising safety promotional activities, structuring

recognition & reward system with defined criteria, issue Safety newsletters with contributory

inputs from employees, involving employees families in Off-the-Job safety promotion etc

Conclusion:

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Focus on integrated Process Safety Management will enable systematic approach and eliminate

Going Unorganised Eliminating Systematic Study (GUESS), the greater Hazard.

Process Safety Management implemented studiously will add to the bottom line by increasing

yield factors, otherwise lost due to reactive approach. It makes the probability of incidents that

much less likely.

This does not mean that reliance on Administrative measures and PPE is neither done away,

nor substituted for Engineered fail-safe controls. But in most cases the erroneous impression is

that since unsafe conditions formed a smaller percentage of contributory cause for incidences, the

focus gets shifted from this key aspect. In other cases, practice of such measure is resorted to

avoid investment on the cost intensive but highly beneficial built-in Engineered Safety Measures.

Cost Benefits:

The cost benefits of PSM System will come into focus sharply only when a crippling incidence

occurs due to any human error. And after all, TO ERR IS HUMAN. But in such cases the

consequences will be unforgettable and not easily forgiven by those impacted.

Good Corporate citizens however reference PSM as a Self-regulatory activity and as a proactive

measure of Safety Management System. By avoiding high risks, Managing medium risks and live

safely with low risks, the objective is to have the freedom from unacceptable risk towards

incident free Business continuity. Small scale and non-process industry and more particularly

ageing Plants can also suitably adapt PSMS.

Reference Credits: - CFR USA, Centre for Chemical Process Safety (AIChE), Professional Interactions with many in Chemical Industry, EPC Companies, OEMs.

List of Abbreviations

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AIChE American Institute of Chemical Engineers

CFR Code of Federal Regulations

CLI Central Labour Institute

EMS Environment Management System

EPC Engineering, Procurement and Construction

EU European Union

IMF International Monetary Fund

ISO International Organisation for Standardisation

ISRS International Safety Rating System

JSA Job Safety Analysis

JV Joint Venture

MAHAC Major Accident Hazard Category

MNC Multi National Corporation

MSDS Material Safety Data Sheets

NSC National Safety Council

OEM Original Equipment Manufacturer

OHSAS Occupational Health and Safety Assessment Series

P & Ids Piping & Instrumentation Diagram

P.M Preventive Maintenance

PLC Programme Logic Controller

POL Petroleum, Oil and Lube

PSM Process Safety Management

SHE Safety, Health and Environment

SOP Standard Operating Procedure

USA United States of America

WB World Bank

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