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The Process Safety Management Fundamentals
Safety

The Process Safety Management Fundamentals

By Sphera February 2, 2021

Simon Jones, Sphera’s director of solution consulting for Operational Risk Management, discusses the 10 key areas that companies need to address to achieve Operational Excellence in their Process Safety Management initiatives.

 

The following is an edited transcript of the podcast.

James Tehrani:

Welcome to the SpheraNOW podcast. I’m James Tehrani, Spark’s editor in chief. Today on the program, I’ll be speaking with Simon Jones Sphera’s director of solution consulting for operational risk management. We’ll be talking about process safety fundamentals, and what that means for an operator’s safety culture. Thank you so much for joining me today, Simon.

Simon Jones:

It’s good to be here, James.

James Tehrani:

Well, thank you for taking the time. Can you tell us a little bit about your background before we begin?

Simon Jones:

Yes, so my background is actually in process safety. So I’ve had some operational experience in the chemical industry in the UK, and also been a manager of the European Process Safety Center. But more recently, I’ve been working with technology firms on developing tools to help manage process safety effectively.

James Tehrani:

Great. So I understand that the IOGP recently came out with a list of 10 areas that fit into this process safety fundamentals. Can you go through those real quickly and then we can kind of go more in detail on some of these areas later on in the podcast?

Simon Jones:

Sure. Okay, James. So IOGP published this list of process safety fundamentals, and there are 10 of them. So there’s maintain safe isolation, walk the line, apply procedures, sustain barriers, control ignition sources, recognize change, respect hazards, stay within operational limits, stop if the unexpected occurs and watch for weak signals.

James Tehrani:

Great, and it seems like most, if not all of those really tie into safety culture. So I’m looking forward to really diving in on a few of these.

James Tehrani:

There are two organizations that you mentioned, the International Association of Oil and Gas Producers and the…

Simon Jones:

European Process Safety Center.

James Tehrani:

OK, can you tell me a little bit about those two organizations quickly?

Simon Jones:

Yeah, so the IOGP is a membership organization of Oil & Gas producers. And they set some of the guidelines on all sorts of operational and engineering aspects of the Oil & Gas industry. And one of the major areas that they’ve invested a lot of time in over the last few years has been trying to improve or standardize the approach to process safety incident reporting. And so they’ve got a number of guidelines around that, API754, I think is the main one. But off the back of that data that they started to collect from their members, they’ve actually noticed how a high proportion of the high consequence incidents, i.e. process safety incidents, and even fatalities relate to maybe I think they say around 10 operational practices. So they’ve had a go at writing some fundamental rules around process safety, to address those frontline operational aspects of process safety management. I think one of the pieces of data they reported was that 91% of fatal and process safety events are linked to one of the 10 core process safety fundamentals. So that’s a little bit—

James Tehrani:

Are those the type incidents that you’d see in the Marsh report?

Simon Jones:

Well, actually, yeah, they are. But the ones that actually make it into the Marsh report are huge property damages, which also have fatalities. What that data statistic that I talked about was incidents where there was a loss of life, regrettably. And some of those actually don’t make it into the Marsh report. So their sort of analysis showed that … Yeah, 91% of the incident of the fatalities in the Oil & Gas industry relate to one or more of these 10 key process safety fundamentals.

And then there’s another organization, the European Process Safety Center. Now, this is a membership organization of chemical manufacturing facilities in Europe. And they have been around, well, I guess, about 20 years or more now. And a couple of their members in Europe have had some initiatives around trying to address process safety issues, because there’s been a recognition I suppose, over the last 10 or 15 years that, whilst there’s been a big push on personal safety to try and improve accident statistics, we still are getting these high-consequence events happening.

Simon Jones:

And I think there’s definitely overlap with the IOGP. But there’s actually quite a lot of detail in the EPSC ones. I think they’ve got about 18 process safety fundamentals. But, again, it is the similar sorts of things, the repeating sort of human activities that people undertake when they’re carrying out maintenance on the facility, which leads to these losses of contaminants, and regrettably process safety, accidents and, potentially, fatalities as well.

James Tehrani:

So, this is the thing that really puzzles me. With all we know about process safety, why are we still getting so many of these major incidents? I mean, I know that there’s no blanket statement that can answer every question about every incident, but it seems to me It should be getting better, but it seems like we’re seeing a lot of major incidents, even in the last 10 years, when it should be going the other way where things are getting better. So what’s the issue here?

Simon Jones:

Well, I think the issue is, if you read behind the fundamentals that those organizations list, it is about connecting process safety to the frontline workforce. So people have got to know to stay within safe operating limits. They’ve got to know the purpose for the safeguards are barriers that have been designed into their facilities so that they can maintain them and support them effectively, they’ve got to know to walk the line before they start up facilities or units following major maintenance activities. So it’s very much about the human aspect of operating and maintaining high hazard plants.

James Tehrani:

So when a dynamic risk pathways comes out do you think that’s going to make a major difference in the fundamentals of process safety?

Simon Jones:

Well, I think it will, because on both of the two models of process safety fundamentals, sustaining safeguards or sustaining barriers is a key topic. And I think that a tool or piece of technology that helps highlight the health of those fundamental barriers, will certainly keep that information, that process safety information, and the consequences of not maintaining those barriers, front and center of the operators and maintainers of the facility.

James Tehrani:

And, I mean, it really is a lot about the digital aspect of this that companies didn’t have access to before, but they do now. But then, as we see this digital emergence, do we think that we’re at a tipping point where we will see accidents go down as more and more companies embrace this type of software and technology?

Simon Jones:

I think it should, I think it’s a two-pronged approach. I think these process safety fundamentals documents will help, because they’re aimed at trying to sort of change behaviors, if you like, on the facility, so that the tools include sort of guidance on how to effectively go out onto a facility and have a conversation about the process safety fundamentals, so that human behavioral stuff is good, and it’s important. But the other thing that technology is bringing is the ability to actually connect all the different data sources that relate to the health and hazards of the facility, to people at the front line so that they know about the consequences of intervening on a particular facility or shutting down a particular barrier. Or what’s the potential major accident consequence if we choose to defer maintenance on a critical piece of equipment? So if we put that information into people’s hands and into their monitors and we do that alongside of a sort of behavioral program like is embedded in these process safety fundamentals, I think that two-pronged approach should drive down the frequency and size of the consequences of process safety accidents over time.

James Tehrani:

So how concerned are you about the delay in turnarounds from 2020? Do you foresee the opportunity for more incidents and potentially fatal incidents because of it?

Simon Jones:

Well, I certainly think that’s a risk. I think the fact that organizations are choosing to defer turnaround activity because of either the economic environment or the impacts of COVID on the business environment, does mean that inevitably, some critical maintenance is being deferred. And I think it would be unreasonable to say that it has zero impact on the risk on the facility.

James Tehrani:

So how does communication play into all this? I know you mentioned just a few minutes ago about having a conversation, but are you still seeing issues with communicating risk within organizations?

Simon Jones:

Yeah, I think that’s a fundamental challenge for all high-hazard industries. And I do think that these process safety fundamentals will help because it’ll help people in all levels of the organization to have an everyday kind of conversation around some of these important issues. And I think as the awareness of these process safety fundamentals increases, it’s a natural thing for all of the leaders and managers and team leaders in the organization to seek better quality data on that on the actual hazard status of the facility. And that’s where technology might come in, where technology does come in.

James Tehrani:

And who in an organization is the typical person who would lead that type of conversation?

Simon Jones:

Well, that’s a dilemma in itself. Because typically, in organizations, let’s say, in the past, it would have been somebody who is a dedicated process safety expert, a process safety manager, or a process safety engineer, or an operational integrity engineer. However, there is an analogy here with general personal safety, over the last 15 years there’s been a drive to push personal safety into everybody’s line responsibilities. And I think there’s an analogous thing happening here with process safety, it needs to be everybody’s responsibility. So, whether you’re either the business owner, the asset manager, the unit leader, or the shift supervisor, or even the technician out on the front line, you need to know about these process safety fundamentals, and you need to know about the risk status on your facility today, because that should be informing your everyday decisions.

James Tehrani:

And does that start at the C-suite, with the C suite really pushing for that type of process safety fundamental safety message? Or is it more important that it’s somebody who’s more at the operational level?

Simon Jones:

Well, I think these process safety fundamentals are more at the operational level, but it’s human nature for people out in commercial organizations to pay particular attention to what their immediate manager is interested in. So in that sense, it’s top down. If risk status and process safety status is a board level requirement, it’s something that’s reported on, it will filter down throughout the organization. And then going the other way, these process safety fundamentals tools that are about starting everyday frontline conversations, within these organizations will drive a bottom-up approach as well. And there should be a sort of convergence, I would hope of good process safety practice as a result.

James Tehrani:

As you talk to companies, which of the fundamentals do you think are the hardest to achieve? And why?

Simon Jones:

Well, I will I actually think it’s the one that seems the simplest on the IOGP model, it’s “We sustain barriers.” And that’s a very simple statement, but the reality is that there are myriad barriers designed into facilities, and it’s the visibility of those barriers, which is the problem, and the relative importance of those barriers. So any tool set, any ability to surface, the data that represents the health of those barriers or safeguards is going to be key, I think, for improving process safety performance.

James Tehrani:

Let’s kind of go through some of the other fundamentals that we have listed here. So maintain safe isolation, what are the challenges there? That seems like a real safety culture part of this equation.

Simon Jones:

It is. And you’ll see that in the European Process Safety Center’s Process Safety Fundamentals, there’s quite a few that relate to isolation. So there’s applying double isolation, so don’t rely just on one barrier to protect you from high pressure or high temperature or high voltage. There’s ones that relate to emptying and de-energizing equipment or pipe work or electrical devices before actually putting your hand in the machine, I guess, is the analogy. Monitoring and open drains is another one, which all relate to isolation practices, because oftentimes you’re having to isolate equipment in order for you to safely enter it, or drain it. And of course, that’s when humans are actually going to be most likely to encounter the process fluids, or the electricity.

James Tehrani:

So are most of the incidents in this area revolving accidents that are based on carelessness and human error?

Simon Jones:

Well, I guess I could get philosophical on that one and say to err is human-

James Tehrani:

I’d love to hear you be philosophical.

Simon Jones:

To err is human really, so we’ve got to design our procedures and practices to minimize the risk of error. And I think we know how to do that. But it’s the consistency of the application of those procedures, which is the challenge, really. And I think these process safety fundamentals should help because the people will understand why they have to follow the particular procedures or follow the particular steps, because the person is standing in front of the valve, swinging the valve might be the person that gets splashed with the fluid that’s inside, but it could lead to a complete loss of process containment, which then turns into a major that kills many people and destroys a lot of equipment. So, there is that aspect of following the procedures because they’re there, for a reason.

James Tehrani:

Sure. So this is one thing that I’ve often wondered about. So, safety signage is so important in an organization, but how do you combat that becoming white noise, when you see a sign saying, ‘This is the safety procedure here. This is the safety procedure there.’ Eventually, you see that day after day after day, is it easy for people to tune that messaging out? And how do you reinforce that messaging?

Simon Jones:

Well, certainly, I think it is natural, natural human trait to do that. And we probably experience it in our daily lives receiving emails that are flagged as from an external system, you kind of just ignore that after a while. That’s a very topical one for us in our business. But, yes, the same does happen, I think out on these process plants. So then you are trying to address people’s sort of fundamental underpinning knowledge about the consequences of not following these good practices. And that’s for frontline workers and their supervisors. And it’s also for unit leaders as well, because it all contributes to the risk status of the facility.

James Tehrani:

Definitely. So the second one that I thought had a big impact on safety culture was walking the line. Can you tell me a little bit about that, and the risks there?

Simon Jones:

Well, certainly walking the line is an activity that relates to inspecting the facility before you start it up, or the piece of equipment before you start it up, to make sure that all of the equipment is in the state that you expect it to be. So all the isolating points are returned to the isolated state, and all of the safety barriers are available and in place before you actually press the button to start the machine.

James Tehrani:

So, in organizations, do you think organizations do a good job at encouraging people to document risks when they’re walking the line, knowing that if there is a shutdown that’s necessary, it’s a very expensive procedure, but if you see a corroding pipe, do organizations do a very good job at really getting their workers to really raise their hand to say that yes, there is a safety concern here? Or is it something that companies really have to do a better job at?

Simon Jones:

I think there’s always room for improvement. But I will say that that is an area that has improved a lot from a process safety point of view. And it is actually probably driven by organizations like the IOGP because they are encouraging operators to report all of these tiny events that you’re talking about. Because they are, precursors to larger events, so the IOGP is encouraging people to report smaller and smaller volumes of small loss of primary containment, and looking for indicators related to availability of those safety barriers that we talked about. Well, they’re encouraging operators to collect data related to calls on safety systems, because if you’re having more calls on a safety barrier or a safety system, you’ve got to say that’s an indicator of potentially not having full control of that process.

James Tehrani:

Do you have an example of what one of those small primary containments would be?

Simon Jones:

Yeah, so, I could use a Scottish saying here, there’s a… I’m not Scottish, by the way, but there has been  quite a big focus on ‘weeps and seeps’ on the Oil & Gas industry equipment and reporting of those, that is probably a natural consequence of aging Oil & Gas operations equipment in that the equipment’s aging, you’re more likely to get weeps and seeps or small, tiny leaks. And so there’s been some really positive programs around reporting that and benchmarking that in different jurisdictions around the world. Sometimes it’s driven by the industry organizations, and sometimes it’s driven by the regulators in those regions. But I think that’s a pretty healthy indicator that now we’re serious about looking for the early signs of losses of primary containment, which could escalate.

James Tehrani:

That’s kind of my follow-up question. Can you explain how you go from a weep and seep to something that is a larger incident? I mean, is that something that could happen over weeks, or months, or even days?

Simon Jones:

Well, yeah, I guess it depends on the stage that it’s at, but all responsible operators now would want to have a program of operational integrity or asset integrity monitoring, where this kind of situation would be monitored, risk-assessed and managed. But the other point about this, though, relates to simultaneous work in an area. So whilst your asset integrity inspectors might be going out and capturing data in their asset integrity system or maintenance management system related to these minor weeps and seeps, you’ve also got another part of the organization that might be planning to do work in that area. And one of the natural escalation paths, of course, would be planning to do hot work in an area where you have got these minor weeps and seeps, and that could lead to a fire, which could lead to more significant loss of primary containment. So again, it comes back to the silos of information in the organization that really could be kept better connected to minimize that risk of escalation.

James Tehrani:

And I remember, I can’t remember which incident it was, but I had heard about an incident where knowledge was not transferred to contractors. So if there is that sort of weep and seep going on, and then there’s some work being done by contractors who are not used to being in the facility or aren’t in the facility very often, it seems like that could be a dangerous situation for the contractors.

Simon Jones:

Yes, potentially, it depends on the nature of the work and then it comes down to the Control of Work, that the contract supervisor and the asset owner or unit leader is permitting in an area, and all of those daily decisions by the contract supervisor, by the unit leader or shift supervisor, should be informed by real time information about the health of all of the critical safeguards on the facility. So the shift supervisor will know not to issue the hot work to the guy doing the welding activity at a location where there are potential hydrocarbons, for instance, would be the natural sort of SIMOPS view on that.

James Tehrani:

Definitely, and as I’m going through this list, I’m starting to realize that pretty much all of these are related to safety culture. So I don’t know if we’ll get through all of these, but the next one on the list was apply procedures.

Simon Jones:

Yeah. So almost follow procedures is the point. So there are incident reports associated with this, you could interpret the actions, let’s say, as ‘Real men don’t use procedures.’ There’s that kind of bravado that you might see at a major hazard plant. But the reality-

James Tehrani:

Really? Even today?

Simon Jones:

Yeah, maybe that’s something from 15 years ago, but there is this idea, it comes back to this blindness, if you like, if you followed the same procedure every day for 220 working days of your working life in a year, how much value is the procedure? Well, the procedure exists to actually catch the nonstandard situation and deal with it safely. And the example that’s often given is the checklists that exist in the cockpit of an aircraft. I’m sure if you were a passenger on an airplane, you wouldn’t want to see the pre-startup checklist being filled out by the pilot as you disembark at the end of your journey. It is a pretty fundamental error-avoidance mechanism. And it needs to be treated that way in all major hazard endeavors.

James Tehrani:

So you talked about the same procedure 220 days in a row, and that makes total sense. You have your checklist or whatever, and it’s easy to follow. But how often are these types of organizations dealing with the management of change? Because, is it something that doesn’t happen very often that they have to do, considering their fundamental process safety? Or is it something that happens less frequently?

So there you go, you could say that the procedures are there to help you both manage the normal every day, but also recognize when you’re deviating from that normal procedure. And that’s the time at which these MOC procedures need to come in. And it depends on the nature of the facility, but I would say at a greater or lesser level organizations are constantly dealing with change, whether it’s a huge business change driven by economics or COVID, or a tiny change to the formulation of a chemical that you intend to use as part of a batch reaction. So it’s almost… Managing change is a fundamental aspect of managing risk, from my point of view.

James Tehrani:

Are those formulation changes, just because of human error? Or are they intentional changes that you’re talking about?

Simon Jones:

Well, it depends on the nature of the business, I mean, let’s just say there’s less small changes that would happen in a high volume, continuous process, but if you’re dealing with batch processes in a chemical facility, you might have to be dealing with changes to formulation or temperature for a particular batch reaction. Equally, you might be working in a sort of pharmaceutical environment where there’s really, really tight procedures in place to drive quality, which means you can’t deviate from the formulation. So it depends on the nature of the business, I suppose, about the relative scale of MOC, but I think it’s a fundamentally important business process from a process safety point of view.

 

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