What process safety risk do you need to manage? Which Major Accident Hazard (MAH) pathways are building? Which risk control systems are not performing?
All companies have some form of Process Safety Management system in place. Some are embedded in their safety management system while some are part of a stand-alone PSM system. Whether it’s the U.S. Occupational Safety and Health Administration (OSHA) 14 Elements or the Center for Chemical Process Safety (CCPS) risk-based PSM elements or even something else, all the elements need to be managed.
Most incidents occur at the front line while performing work. There are two major causes of incidents: equipment failures and human interactions such as preparing for and performing maintenance activities.
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People do not go to work intending to cause incidents, but human factors play the largest part in process safety failures, such as the unplanned release of toxic, reactive or flammable liquids and gases from processes involving highly hazardous chemicals. Incidents continue to occur in various industries for various reasons. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of a disaster occurring, which results in the loss of life, damage to assets and harm to the environment. There are financial costs resulting from these failures as well, whether it’s from loss in revenue, fines or reputation.
The burden of managing process safety systems is especially severe in heavily regulated industries where noncompliance can put both organizations and their leaders at significant risk. Besides maintaining a safe facility, companies must comply with government regulations and reporting to improve performance.
How are the reports managed? Some aren’t even able to link the computer programs with manually prepared reports for government compliance and monthly executive safety meetings. Often, the data is also out of date the day the PowerPoint slide is prepared because the information flow does not stop.
For members of operations management who have Process Safety Management systems in place, how nice would it be as you have your first coffee of the morning to be able to log on to your system and see the status of your PSM system and resulting risk levels throughout your facility?
Being able to address these risks and resulting Major Accident Hazards before they create the possibility of disaster helps prevent the loss of life, damage to assets and harm to the environment while avoiding the human and financial costs resulting from failures, loss in revenue, fines and reputation.
The control room operators and field technicians will also benefit from these risk indicators and required mitigation measures, helping them plan work and control Simultaneous Operations (SIMOPS) throughout the facility.
Team leaders use the pre-job toolbox talk to discuss risk information and required safeguards such as hot work, Permit to Work, isolations and lockout/tagout (LOTO) for the coming shift and shift handover.
With the technology platforms available today either in the cloud or on-premise, it is possible to monitor the process safety system and plant risk levels via a live dashboard and power better decisions such as risk mitigation measures with the use of advanced analytics.
Companies must ask themselves:
- What potential process safety events are hidden in the system?
- What is the best way for operators to mitigate risk from PSM systems while making them an integral part of an efficient and effective operations process? What MAH could come into play? Are risk control systems functioning properly to reduce the risk of a hazard significantly and, combined with other risk reduction measures, reduce the overall risk to a tolerable level?
If each PSM element is managed as silos, constituent risk is singular, that is, if it is even measured at all.
With the technology available today: If each PSM element is aligned via its constituent system, safety critical element and human factors and is merged, a cumulative risk picture becomes available.
As you have that first coffee, what could you see on your dashboard? Let’s look at a potential PSM dashboard that incorporates emerging technology and big data. With those components it’s possible to provide a PSM system status and facility risk visibility.
Technology can give a facility risk and safety status in real time while alerting operators should risk levels rise. This ensures asset integrity is sustained by a safety critical element monitoring in real time with repeatability. For example, with better visibility of corrosion’s impact on the fundamental asset integrity barriers and the operational reality of the asset, organizations can make better-informed decisions that reduce risk, reduce costs and improve productivity risk levels simply by feeding the data into a barrier model.
For each of the process safety elements, data is held somewhere, and by integrating the data and running algorithms the status can be displayed on a dashboard along with the risk levels driven by the fundamental barrier model.
Many operators have undertaken MAH studies to help define the Safety and Environmentally Critical Elements (SECE) and identify the associated critical equipment on their facilities. Performance standards associated with each SECE are also defined, which allows operators to design their risk control systems to ensure that equipment performance is met through adequate inspection, testing and maintenance.
Barrier-based process safety models are quickly becoming the visualization tool of choice for the energy industry. These tools allow everyone from the boardroom to the frontline to consistently see and manage all operational risks across the enterprise. They can relate the collective performance of process safety systems to the real cumulative risk impact on operations at any given time.
From the dashboard we can drill down and can see what is contributing to the risk. We can also navigate from shift to shift to see the evolution of the process safety barrier impact and cumulative risk.
- See the real-time health of the impacted barriers.
- See how equipment health and deviations impact process safety barriers.
Once we are used to seeing risk displayed as potential breaches of fundamental barriers, companies can make more-informed, strategic business decisions about mitigating risk. Depending on what software systems are used to gather and analyze data from a host of available sources.
Summarizing the Discussion
Let’s examine one system as an example of data held in an inspection/asset integrity department database. Yes, reports and risk assessments are available and, hopefully, mitigation measures are in place to manage operational risks from corrosion. How many other silos out there hold data that present a risk to the ?
Risk to a Facility
Other barrier deviations/impairments that could be held in a mechanical inspection system (silo):
|Fundamental Barrier||Deviation Management, Safety Critical Equipment Impairment Examples|
|1. Structural Integrity||Vessel support legs corrosion|
|2. Process Containment||Piping and vessel external corrosion|
|3. Ignition Control||Electrical junction boxes and conduit|
|4. Detection System||Corrosion on sensor heads|
|5. Protection Systems||Corrosion on sprinkler systems|
|6. Shutdown Systems Drilling Well Control Equipment||Corrosion on valve shafts|
|7. Emergency Response||Escape/rescue ladders corroded rungs|
|8. Life-saving Equipment||Life ring supports corroded|
Primary containment, process and engineered systems designed and managed to prevent loss of primary containment and other types of asset integrity or process safety events and mitigate any potential consequences of such events. can be categorized under the following eight main headers:
- Structural Integrity
- Process Containment
- Ignition Control
- Detection Systems
- Protection Systems, Including Deluge and Firewater Systems
- Shutdown Systems, Including Operational Well Isolation and Drilling Well Control Equipment
- Emergency Response
- Life-Saving Equipment, Including Evacuation Systems
Operators will define these slightly differently when it comes to the detail, but the objective is alignment at the header level. An example of hardware barriers and subcategories for operating facilities:
|OSHA 1910 PSM Elements||Affected process safety barriers|
|Employee Participation||Process Containment|
|Process Safety Information||Process Containment|
|Process Hazard Analysis||Process Containment|
|Operating Procedures and Practices||Process Containment|
|Hot Work Permits||Ignition Control|
|Prestartup Safety||Process Containment|
|Management of Change (MOC)||Process Containment|
|Mechanical Integrity||Structural Integrity|
|Incident Investigation||Emergency Response|
|Emergency Planning and Response||Emergency Response|
|Compliance/Safety Audits||All Barriers|
|Trade Secrets||All Barriers|
If operators map the cumulative effect of deviations arising from all risk control systems, including those in place to monitor and manage corrosion, they will be able to see how the deviations are coming together to form Major Accident Hazard pathways through the barriers. This provides the opportunity to proactively identify and prioritize corrective action from a MAH management viewpoint.
Therefore, PSM can become an operational driver rather than just a compliance obligation. Understanding and managing the specific and cumulative risk impact of the deviations or nonconformances because of corrosion with the performance standards of a PSM system in the context of daily operations is key.
Please contact us if you would like more information on scheduling a PSM maturity assessment.