In the 30 years that have passed since Process Safety Management legislation started to appear in various parts of the world, the lowly risk assessment has come a long way.
In the early days, it was a scramble to simply get something down on paper to meet regulatory requirements. Over time, as the methodologies and their limitations became better understood, studies have become sources of raw data that serve as the basis for effective PSM systems in companies across a broad range of industries and geographies. Process Hazard Analysis (PHA) studies were once broad-based, voluminous documents whose merits often seemed to be judged in proportion to their page count. PHAs have since evolved into focussed analyses of true process safety issues. They significantly contribute to defining activities as important and diverse as equipment maintenance and planning, alarm rationalization, employee and contractor training and critical safety system design.
To those of us who have participated in PHA studies—whether as team members, facilitators or scribes—the evolution has been clear. The entire process around PHA studies has improved markedly over time. The benefits of taking the time to ensure a dedicated group of qualified people spend the necessary amount of time to review quality information to fully understand the hazards of a process—and the risk gaps they entail—has become more apparent with each passing year.
Improvements Difficult to Quantify
Unfortunately, in these data-driven times, the improvements have been anecdotal and difficult to quantify. Industry has tried to measure the effectiveness of PSM activities and their improvements, with various standards and metrics. While lagging metrics—measures of performance based on analysis of past results—have generally been easy to identify and analyze, leading metrics have proven to be more elusive. Understanding weaknesses or gaps in processes and management systems before they lead to problems is unquestionably the better way to understand where improvement priorities should be placed. But getting that information has been a challenge.
What we have learned—or maybe it’s better to say, what we have been told—is that if we do everything in a consistent manner, in a single system or tool, we’ll be able to better analyze where we’ve been and where we’re headed.
What we have learned—or maybe it’s better to say, what we have been told—is that if we do everything in a consistent manner, in a single system or tool, we’ll be able to better analyze where we’ve been and where we’re headed. The path will become clear. Technology will be the panacea that gets us back on track. (Never mind that PHA studies are, to a large degree, an analysis of our reactions to technological failures … but that’s another blog). Consistency and commonality are positioned as essential to PSM success. But is that the whole story?
Doing something consistently does not necessarily mean that you are doing it well. It just means you are always doing it in the same way. Remember, you can consistently follow a bad process in an accurate manner. Is it better to follow a bad process well or to follow a good process badly? In an arena as important as process safety—where the health, safety and quality of your personnel, the public, the environment and your business are at stake—can you afford to follow bad processes?
Audits and Assessments
Those familiar with the safety lifecycle approach of ISA 84.1 and IEC 61508/61511 know that effective management requires both audits and assessments. Audits allow you to confirm that you have been correctly following your process. Assessments help you better understand the quality of that process and the activities involved at each step of that process. They will also give you better insight into effectiveness of your processes.
Expanding this concept to larger PSM systems and the drive to monitor, measure and improve their performance, the key point is really this: Do not confuse consistency with quality.
Audits—something with which we’re all familiar—will tell you if everyone is following your PSM approach consistently, or if they are having difficulty. Audit results really tell you if people are following the processes, and if the data captured from those processes is good enough to be analyzed. Assessments—something we’re likely less familiar with—help us to compare the quality of the data collected and how the processes were followed to determine where shortcomings exist, so solutions can be proposed.
We’ve noticed that the community of Sphera clients is increasingly talking about their need and desire to improve consistency in their safety management initiatives. But we’ve noticed confusion in these discussion as well. Sphera’s suite of solutions can help you improve both, but it’s important to understand that consistency and quality are different things to manage, and that you need to manage one before you can understand how well you are managing the other. Simply put, think of lagging metrics as giving you insight into consistency; think of leading metrics as giving you insight into quality.
The PHA is very much the cornerstone of your PSM program. It is where the Major Accident Hazards in your facility are identified and where the scenarios by which each can unfold are developed. Whether a project must be a managed change as part of your Management of Change process will be determined in part by whether it is related to something discussed in your PHA study. Whether an accident or event in your facility requires a formal investigation will also relate, in many cases, to whether it was an issue originally identified or discussed in the PHA. Need a hot work permit? The PHA identified a lot of areas where ignition is part of a Major Accident Hazard scenario. Worried about whether operator intervention in the process can pose safety risks? The PHA should tell you many of those situations as well.
What data goes into the PHA is critically important—knowing if all the data is being captured and if it is accurate, is paramount to the success of the overall PSM system. In other words, you need quality data.
Good Data Needed
How do you know if the data is good quality? In an ideal world, you’d have a standard against which data can be compared. That doesn’t quite work with a PHA. Every plant is different—from its process design to its operational history and experience to its process safety information and even its operating environment. There simply is not one set of data against which you can make a comparison. Instead, you need to compare data from among many studies, facilities and operations. If everyone is doing their studies in different ways, following different methods and developing scenarios using different criteria that makes a valuable comparison very difficult.
Therefore, it is important to have a consistent approach to the PHA to make sure everyone is identifying and analyzing scenarios in roughly the same way. If the approach is the same, that tells you that comparing data from different studies will be a fair comparison. This in turn will allow you to analyze all the components of the approach to determine where factors impacting the quality of the data may exist and if there are parts of the process that discourage people from following the process. The relative quality of the data then also lets you figure out if there are parts of the process that inhibit progress. Knowing how PSM relates to other business processes and management systems, and understanding that PSM is not a true “big data” system, allows you to then compare processes to find roadblocks and figure out if all the data is getting captured in the first place.
Continuous Improvement Process
So, in the PHA world, this means that a continuous improvement process looks something like this:
- Developing and enforcing a consistent process to follow for risk assessments that allows for a sound basis of comparison between studies, no matter what the process, business or geography.
- Comparing results of studies to determine which elements of the methodology and process may be contributing to quality issues—whether that’s related to data accuracy, data completeness or both.
- Comparing results with other business systems to verify that data have not been overlooked or left out and figuring out why if they have.
- Revising the method to address points from above, and continuing in an iterative manner.
Consistent Approach Does Not Always Mean Good Results
Consistency of the approach or method is key. But keep in mind that a consistent approach doesn’t necessarily give you good results; it simply gives you data that can be analyzed to figure out if the results are, in fact, as good as they need to be.
Many people are concerned about the fact that teams might not necessarily be consistently identifying the correct hazardous scenarios, developing consequences consistently or applying effective safeguards in the same way. While consistency issues may be at play here, it’s really more an issue with the data quality. If there was a way to force consistency on scenario development, you could write a computer program to automate the Hazard and Operability study (HAZOP) process. With all the variables related to personnel experience, management philosophy, equipment condition and so on, this really isn’t possible. The team approach is necessary, and the engagement of every member is key.
Your goal shouldn’t necessarily be developing tools that let teams consistently arrive at the same consequences, same severity assessments or same number of safeguards for a given set of process hazards. Instead, it should be about having a consistent method to follow that allows a competent team to arrive at accurate, actual results (not necessarily results that follow a formula). As long as the method followed to get to the conclusions is the same, and it includes the key items you need to assess overall data quality, the journey, as they say, is just as important as the destination. And if laid out well, everyone who needs to will take that journey, and no one will take a shortcut.
Sphera’s solutions can help with all of these challenges. We’ve worked in plants, we’ve facilitated studies, we’ve designed and audited management systems. We know your world. We know everyone’s world is different. Our tools—in combination with our consulting experience—can help adapt our products to develop a solution that’s right for you.
Specifically, in the world of PHA and PSM, our Advanced Risk Assessment (ARA) module of SpheraCloud can:
- Support the use of consistent risk assessment methodologies throughout the organization through complete customization of study templates that align with corporate processes and procedures as well as industry best practices and Recognized And Generally Accepted Good Engineering Practices (RAGAGEP).
- Support the identification and collection of key information from these methodologies that can be used for analysis of data integrity and process completeness.
- Facilitate sharing of information through libraries and linking to other studies to ensure that data captured during assessments is complete and useful.
- Support analysis of scenarios based on your criteria that can be compared across the organization to figure out which data elements are potentially causing overall quality issues.
When all is said and done, you need systems that align with your objectives and help you to achieve them. You need systems that align with the procedures and policies you have in place for good Process Safety Management and that support—rather than inhibit—continuous process improvement. You need systems defined by your process, not processes defined to align with a system. The evolution of Sphera’s tools has followed the evolution of Process Safety Management, so that you can focus on the quality of the data you capture, instead of focusing on how to use a tool. After all, keeping personnel engaged is a key element of process safety. Shouldn’t your systems support that as well?