PSM REGULATORY UPDATE – OSHA MARCH 2016 · 2016-05-17 · • SOPs not written for ALL phases of...

Copyright PSRG Inc. 2016

PSM REGULATORY UPDATE – OSHAMARCH 2016

Robert J. Weber, P.E.President/CEO

+ Houston + Bogota + Kuwait + Lagos + Singapore

PRESENTATION OUTLINE

• Industry Incidents & Lessons Learned

• Introduction to PSM Auditing

• PSM – Common Deficiencies from Auditing

• Key Success Factors: What does good look like?

• Conclusion

INDUSTRY INCIDENTS&

LESSONS LEARNED

INDUSTRY INCIDENTS & LESSONS LEARNED

“It should not be necessary for each generation to rediscover principles of process safety which the generation before discovered. We must learn from the experience of others rather than learn the hard way. We must pass on to the next generation a record of what we have learned.”

~ Jesse C. DucommunVice President, Manufacturing and a director of American Oil Company in 1961; Process Safety Pioneer

FLIXBOROUGH, U.K. (1974)• Nypro U.K. – Cyclohexane

release from temporary bypass pipe and subsequent explosion

• 28 fatalities, 36 onsite injuries• Offsite consequences resulted

in 53 reported injuries• 1,800 nearby homes damaged• $ 425MM USD property loss

FLIXBOROUGH, U.K. (1974)CAUSES / LESSONS LEARNED• Lack of plant modification / change control.

• Management of “temporary changes”.• Management of change for “organizational change”.

• Lack of design codes for pipework.• Lack of land use planning and siting considerations

relative to location of the process versus plant buildings and the local community.

SEVESO, ITALY (1976)• ICMESA (Industrie Chimiche

Meda Societa Azionaria)• Tetrachlorodibenzoparadioxin

(“DIOXIN”) release, a poisonous and carcinogenic by-product of uncontrolled exothermic reaction

• 25 km North of Milan• No fatalities. More than 600

people evacuated; 20 people treated for Dioxin poisoning.

• Long-term health impacts.• Led to development of initial

EU “Seveso” directive.

MEXICO CITY (1984)• PEMEX LPG Terminal• BLEVE (Boiling Liquid Expansion Vapor Explosion)

and fire after loss of containment to local sewer system

• 650+ fatalities, mostly offsite• $20MM USD property damages• Contributing Factors:

• Plant layout• Active / passive fire protection• Emergency isolation• Emergency response / spill

control

BHOPAL, INDIA (1984)• Union Carbide India Ltd. (UCIL) – insecticide plant• Methyl isocyanate release

• 3,000+ fatalities; 100,000+ injuries• Accident a result of poor safety management systems, poor early warning

systems, and lack of community preparedness.• Considered world’s worst industrial disaster

• Eventually, resulted in demise of Union Carbide, one of the world’s largest integrated chemical companies

PIPER ALPHA (1988)

• Occidental Petroleum Platform – North Sea

• 167 fatalities• $3.4B USD insured loss• Contributing Factors

• Fire water system bypassed

• Lack of adequate emergency evacuation and egress

PHILLIPS PASADENA (1989)

• Vapor cloud explosion• 85,000 lbs. flammable gas

release; explosion with force of 2.4 tons TNT

• 23 fatalities; 130 injuries• Property loss ~ $750MM USD• Contributing Factors

• Human error (manual valve inadvertently left open)

• Facility siting and plant layout of process, buildings

HISTORY OF PROCESS SAFETY

• Process Safety Management was initiated by U.S. OSHA in 1992 as a way to respond with government regulations / oversight of industries using highly hazardous chemicals (HHCs).

• Several other countries have followed since.

Process Safety ManagementDEFINITION

A management system design to

PREVENTthe Release of

MINIMIZEthe Consequences of Release

Highly Hazardous Chemicals (HHCs)

Process Safety ManagementELEMENTS

PROCESS SAFETYMANAGEMENT

EmployeeParticipation

Process SafetyInformation

OperatingProcedures

TradeSecrets

EmergencyPlanning and

Response

Managementof Change

MechanicalIntegrity

IncidentInvestigation

Pre-StartupSafety Review

Training

ComplianceAudits

Contractors

Process HazardAnalysis

Hot WorkPermit

HISTORY OF PROCESS SAFETY• “PERFORMANCE-based” regulation, Not

Prescriptive

• Regulation sets forth minimum requirements for compliance (based on 14 Elements)

• Regulation specifies WHAT TO DO, Not HOW TO IT

IS IT WORKING?

BP TEXAS CITY (2005)• Vapor cloud explosion• 15 fatalities; 170

injuries• Both BP and U.S.

Chemical Safety & Hazard Investigation Board (CSB) identified numerous technical and organizational failings at the refinery and within BP corporate

WEST FERTILIZER (2013)• Retail fertilizer operation in rural

Texas• Ammonium nitrate explosion• 15 fatalities; 160+ injuries• Many fatalities were emergency

responders.• More than 150 nearby buildings and

homes damaged or destroyed due to blast

• USGS recorded explosion as a 2.1 magnitude

U.S. regulations have NOT changed since their promulgation, but…….• OSHA Petroleum Refinery Process Safety Management National

Emphasis Program (NEP) Directive – 2007• OSHA PSM Covered Chemical Facilities National Emphasis

Program (NEP) Directive – 2011• Executive Order 13650 (August 2013)• Pending changes by OSHA and EPA to PSM and RMP regulations

to expand coverage, respectively• More chemicals covered, more facilities covered, lower threshold

quantities

PSM AUDITING

OVERVIEW

COMPLIANCE AUDIT• OSHA 29CFR1910.119(o)• Perform audit at least every three (3) years.• Conducted by at least one person knowledgeable in

the process.• A Report of the findings shall be developed.• The employer shall document a response to each of

the findings.• The employer shall document corrective actions to

each of the findings.• Employer shall retain the two (2) most recent

compliance audit reports.

COMPLIANCE AUDIT1 Assemble

Audit Team

2 Pre-Audit Activities

3 Audit 4 Post Audit Activities

COMPLIANCE AUDIT – WHY?• Excellent tool to assess your

organization’s Process Safety effectiveness – written program and implementation

• Assess compliance; benchmark performance with industry

• Identify and mitigate “early warning signs” before a potential incident

• Integral to “PLAN – DO – CHECK – ACT” cycle of continuous improvement

• Meticulous verification required to preserve License-to-Operate, which is a privilege, not a right

PSM AUDITING

COMMON DEFICIENCIES

Common DeficienciesBASIS• 350+ audits / assessments performed• 2000 – 2015• Large, major OPCOs to smaller, niche specialty

chemical companies and industries• Variety of industries:

• Oil & Gas• Petroleum Refining• Gas Processing• Petrochemicals• Chemicals• Pharmaceuticals• NH3

Common DeficienciesEMPLOYEE INVOLVEMENT

• Lack of well-articulated management expectations and defined goals; leading to weak employee morale and decreased employee participation.

• Employees do not know how to access PHAs and other PSM information.

Common DeficienciesEMPLOYEE INVOLVEMENTEXAMPLES OF GOOD EMPLOYEE PARTICIPATION:• Assignment of “PSM Champions” (by Element, by Unit, etc.)• Plant safety steering committee• Toolbox safety meetings• Employee participation in PHAs, PSM audits, incident investigations,

development of SOPs, etc.• Regular communication of action items from PHAs, audits, incidents to

affected employees• Employee feedback; suggestion for improvement boxes• Management consultation with operators on the frequency and content

of training• Regularly-planned emergency action plan drills and exercises with

follow-up and response critique• Behavioral-based safety programs (BBS)

RACI MATRIX

PSM Activity

Applicability - (a) A R C C C I I I I

Employee Participation - (c) C C I A R I I I I

Process Safety Information - (d) I C R/A C C I I I i

Process Hazards Analysis - (e) I A I R C I I I I

Operating Procedures - (f) I C C A R C I I

Training - (g) I C A R C I I I

Contractors - (h) A R C C C C C I I

Pre-Startup Safety Review - (i) I R C A C C I

Mechanical Integrity - (j) I C C R/A C C C

Hot Work Permit - (k) A R C C C C I I

Management of Change - (l) A C I R C C C I

Incident Investigation - (m) A R I C C C I I

Emergency Preparedness & Response - (n) A R C C I I I

Compliance Audits - (o) A R C C C I I I I

Trade Secrets - (p) A C C R C C i I I

Common DeficienciesPROCESS SAFETY INFORMATION

• Hazardous effects of inadvertent mixing of different chemicals that could foreseeably occur not addressed

• Lack of complete Electrical Area Classification documentation and field survey

• Design basis information for emergency relief/PSV and flare systems incomplete (e.g., PI RP520/520 RV sizing “contingency analysis”)

• Design basis information for safeguards, which prevent or mitigate a potential release, incomplete (e.g., fire water systems).

• Materials of construction information not on file for all equipment in the “covered process”.

• Lack of reference Plant design codes and standards identified (“RAGAGEP”).

MOST FREQUENTLY REFERENCED RAGAGEPs IN RECENT OSHA INSPECTIONS• API 520: Sizing, Selection & Installation of Pressure-

Relieving Devices in Refineries• API 521: Pressure-Relieving and Depressuring Systems• API RP752: Management of Hazards Associated with

Location of Process Plant Permanent Buildings• API RP753: Management of Hazards Associated with

Location of Process Plant Portable Buildings

MOST FREQUENTLY REFERENCED RAGAGEPs IN RECENT OSHA INSPECTIONS• API 510: Pressure Vessel Inspection Code – In-service

Inspection, Rating, Repair and Alteration• API 570: Piping Inspection Code – In-service

Inspection, Rating, Repair and Alteration of Piping• API 574: Inspection Practices for Piping System

Components• ANSI/ISA S84.01: Functional Safety – Safety

Instrumented Systems for the Process Industry Sector

Common DeficienciesPROCESS HAZARDS ANALYSIS

• PHA fails to comprehensively identify all hazards of the process because:

• Selection of the wrong methodology based on complexity of the process

• Incomplete set of Guidewords + Parameters (“Deviations”) utilized

• Failure to review Startup / Shutdown issues, Abnormal Operations

• Safeguards not independent of the initiating event / cause. Failure to perform Layer of Protection Analysis (LOPA) to assess effectiveness of safeguards.

• Consequences not based on failure of engineering controls, but taking into account safeguards. Failure to assess consequences to “ultimate” loss event assuming safeguards are non-existent or ineffective as designed.

• Failure to address FACILITY SITING issues.• Failure to address HUMAN FACTORS issues.

USE INDUSTRY-STANDARD CHECKLISTS!!!

• Previous incidents, including “near misses”, not considered by the PHA team.

• Overdue PHA recommendations with no managed schedule for resolution, completion.

• Incomplete compilation of Process Safety Information prior to performing the PHA.

Common DeficienciesOPERATING PROCEDURES

• SOPs not written for ALL phases of operation (esp., non-routine operations, e.g., purging, cleaning, sampling, emergency operations, etc.)

• Safe operating limits and consequences of deviation from these limits not well-defined. Steps to correct/avoid deviations not documented.

• No written procedures for Shift Change / Handover operations.

• Procedures not reviewed often enough for accuracy; lack of annual certification.

Common DeficienciesSAFE WORK PRACTICES

• No documented Equipment-specific procedures for LOTO, Confined Space.

• Lack of periodic training for LOTO, Confined Space

Common DeficienciesTRAINING

• Missing records of initial training for qualified operators.

• Refresher training not conducted at least every three (3) years.

• Lack of verification of personnel comprehension of training program.

Common DeficienciesTRAINING

• No written proof that operators consulted on frequency or content of refresher training.

• Refresher training too much focused on “normal” operations.

Common DeficienciesCONTRACTORS

• Lack of due diligence qualification, certification records for contractor employees who perform “specialized skill or craft work”, e.g.,

• Crane and rigging work• Forklift driving, mobile lifts/JLGs• Certified welding• Instrument calibration• Other

• Lack of periodic surveillance of contractors post-selection; contractors only disciplined when something goes wrong

Common DeficienciesPRE-STARTUP SAFETY REVIEW

• PSSR not performed and documented for new plant facilities or process modifications prior to introduction of highly hazardous chemicals

• PSSR not performed and documented for each MOC

• Weak, short-form PSSR checklist used for major changes

Common DeficienciesMECHANICAL INTEGRITY

• “FIX IT WHEN IT BREAKS” mentality• Failure to identify “critical equipment” relative to

the PSM-covered process• Lack of written deficiency management program for

non-conformances identified during inspection and testing activities

• Overdue inspections• Failure to identify and implement RAGAGEP for

inspections and tests

Common DeficienciesMECHANICAL INTEGRITY

• Failure to review PHA and include all “safeguards” in Mechanical Integrity program.

• Focus on stationary equipment; less emphasis on Rotating Equipment and Instrumentation & Controls.

• Lack of “fitness for service” documentation for process equipment.

• MOC process not used for changes to inspection frequency.

Common DeficienciesHOT WORK

• Hot work permit does not clearly identify “object on which hot work being performed”.

• Pre-job Hot Work Checklist not completed.• Missing signature authorizations on hot work

permit form.• No documentation of fire watch

training/qualifications.• Hot work training not performed annually.• Permit-required hot work areas inconsistent

with definition of electrically classified area.

Common DeficienciesMANAGEMENT OF CHANGE

• MOC process not applied for:• Installation of temporary equipment• Decommissioning or taking equipment out-of-

service• Changes to alarm setpoints• Procedural-only changes (e.g., conversion from

paper-based to electronic systems)• Changes in shift work; workforce reductions

Common DeficienciesMANAGEMENT OF CHANGE

• MOC process not institutionalized – may be strong in Operations; but weaker by Maintenance.

• PSI, SOPs, M.I. not updated when affected by the MOC.

• MOC forms completed and signed off beforePSSR completed.

Common DeficienciesINCIDENT INVESTIGATION

• “Near misses” not documented; possibly due to:

• Lack of good, uniform understanding of what the definition of a “near miss”

• Lack of positive culture that promotes reporting of “near misses”

• Focus on reporting and investigation of personnel safety incidents (a “lagging” indicator) versus “near misses” (a leading indicator)

Level 1Incidents of

greater consequence

Level 2 Incidents of lesser

consequence

Level 3 Challenges to safety system

Level 4Operating Discipline & Management System

Performance Indicators.(Not reported yet in RCI)

Common DeficienciesINCIDENT INVESTIGATION

• Incident investigations not commenced within 48 hours of the incident.

• Incident investigation team composition does not include a contractor employee for incidents involving the work of a contractor.

• Failure to identify “root causes” leading to repeat of incidents.

• Failure to communicate the findings and action items resulting from incident investigations.

Common DeficienciesEMERGENCY PREPAREDNESS & RESPONSE

• Emergency action plan not up-to-date.• Emergency evacuation maps with routes and safe

distances not posted.• No written process for testing and servicing plant

alarms; no documentation that alarm testing was completed

• Lack of documented drills and exercises• Lack of coordination of EAP with local community,

responders.

Common DeficienciesCOMPLIANCE AUDITS

• Compliance audits performed; but not certified in writing.

• Audits incomplete.• Audit action items not tracked or completed in

a timely manner.

Common DeficienciesOSHA REFINERY NEPENFORCEMENT STATISTICS2007-2011

Mechanical Integrity 202Process Safety Information 189Process Hazard Analysis 188Operating Procedures 184Management of Change 92Incident Investigation 71Compliance Audits 47Contractors 33Training 29

855 79%

Common DeficienciesOSHA REFINERY NEPENFORCEMENT STATISTICS2007-2011

Emergency Planning and Response 17Employee Participation 15Pre-Startup Safety Review 13Hot Work Permits 8Trade Secrets 0

Total PSM Citations 1088

Common DeficienciesCHEMICAL NEP PSMENFORCEMENT STATISTICS2011-2015

Mechanical Integrity 156Process Safety Information 140Operating Procedures 114Process Hazard Analysis 106Management of Change 44Compliance Audits 35Training 21Incident Investigation 19Employee Participation 16

516 76%

Common DeficienciesCHEMICAL NEP PSMENFORCEMENT STATISTICS2011-2015

Contractors 14Emergency Planning and Response 7Pre-Startup Safety Review 5Hot Work Permits 1Trade Secrets 0

Total PSM Citations 678

PSMKEY SUCCESS FACTORS

1. Process Safety Leadership2. Process Safety Competency3. Process Safety Culture4. Clearly Defined Expectations and

Accountability5. Leading and Lagging Indicators6. Audit and Continuous Improvement7. Community Outreach

PROCESS SAFETY LEADERSHIP• The executive leadership must provide and

demonstrate effective leadership and establish clear process safety goals and objectives.

• Management and leadership must clearly demonstrate their commitment to process safety by articulating a consistent message on the importance of process safety.

• Policies and actions should match that message.

PROCESS SAFETY COMPETENCY• Company must establish and implement a

system to ensure that its executive management, its line management, and all employees – including managers, supervisors, workers, and contractors –possess the appropriate level of process safety knowledge and expertise to prevent and mitigate accidents.

• Avoid falling subject to the “Peter Principle”. [Dr. Laurence J. Peter, 1968.]

PROCESS SAFETY CULTURE

• Company must involve employees at all levels in order to develop a sustainable, positive, trusting, and open process safety culture.

• Company must promote a culture of individual ownership of the Process Safety program.

• Process Safety should be EVERYONE’s responsibility; not just the responsibility of the Process Safety Manager or HSE Department.

CLEARLY DEFINED EXPECTATIONS & ACCOUNTABILITY

• Company must clearly define expectations and strengthen personnel accountability for process safety.

• At all levels of the organization – the executive leadership, management, supervisors, line employees, contractors, etc.

LEADING & LAGGING INDICATORS

• Company should develop and implement an integrated set of Key Performance Indicators (KPIs), including leading and lagging metrics for more effectively monitoring the performance of the process safety management system.

• KPIs should be realistic and measurable.• KPIs should also be regularly monitored and

periodically updated to reflect industry changes, best practices, and lessons learned around the world.

AUDIT & CONTINOUS IMPROVEMENT

• Company must establish and implement an efficient and effective system to periodically audit and continuously improve process safety performance relative to regulatory requirement and international peers.

• Plan-Do-Check-Act• Documentation Documentation Documentation

COMMUNITY OUTREACH

• Company should out and work closely with local community leaders to promote its Process Safety image.

• Will lead to increased reputation and goodwill, improved safety and quality performance of workers and suppliers.

• More adequate preparedness and response in case of a catastrophic emergency,

• Part of corporate social responsibility.

PATH FORWARD

REALIZE THE BENEFITS: SEVEN (7) KEY STEPS1. Assign personnel who will be accountable.2. Adopt a personalized Company philosophy of

process safety.3. Learn more about process safety.4. Take advantage of strong synergy process safety

has with your other business drivers.5. Set achievable process safety goals.6. Track your performance.7. Revisit your process safety program / continuous

improvement.

Houston Bogota

Singapore

GRACIAS!

WWW.PSRG.COM

PSRG OVERVIEW• Established, 1997 (Houston)• Member: ARPEL, CCPS• More than 80 professionals worldwide

averaging 28+ years experience• Diverse industry experience on

1,000+ projects with more than 750 customers in 76 countries

• Hands-on plant operations experience

• Single source, one stop shop for comprehensive PSM/RMP, and HSSE consulting and training services

• Tailored solutions to meet and exceed customer expectations

• Highly qualified resources enable customers to receive value that far exceeds cost of our services

PSM REGULATORY UPDATE – OSHA MARCH 2016 · 2016-05-17 · • SOPs not written for ALL phases of...

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