Process Safety ManagementPROCESS SAFETY INDICATORS CAN DRIVE CHANGE

Hasan Alaradi, RRC International

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Process Safety Indicators

Overview:

• High hazard industries

• Chemical Processing

• Refineries

• Oil & Gas Production

Process Industries

Potential for catastrophic events

• Major fires, explosions, toxic release

• Rare, complex causes, diffi lt t di t

BP Oil Refinery, Texas City, USA (2005)

Explosion and Fire

15 Dead

180 Injured

BP Oil Refinery, Texas City, USA (2005)

Some Immediate Technical Causes

• Drain valve left closed

• Level Indicators did not reflect reality

• High level alarms failed to activate

Some Underlying Causes• Culture of routinely not following procedures (procedures outdated)

• Inadequate process safety performance metrics (emphasis on low personal injury rates)

• Cost-cutting (aging plant "run to failure“)

• Ineffective leadership/Board oversight- Warning signs overlooked for many years

- Incidents not investigated effectivelyF i l t l ( i

Buncefield Oil Depot, UK (2005)

Multiple Massive Explosions

Extensive fire (burned for 5 days)

40 Injured

Buncefield Oil Depot, UK (2005)

Massive Explosion

No Fatalities/Injuries

Tank 912 Overfilled

Overflowed

Ignites

Some Immediate Technical Causes

• Fill gauge became stuck

• High level Switch failed to operate (as did the alarm)

• No other mechanism to alert control room staff of impending overfilling

• Petrol overflowed into bund

• Bund and drains also failed (pollution)

Some Underlying Causes• Inadequate maintenance of critical equipment (e.g. the gauge was known to be unreliable)

• Inadequate management systems for tank filling (these systems were independently audited too!)

• Procedures not properly followed• Work pressures – increased work load and insufficient information to properly manage storage of incoming fuel

• Culture of “keep process operating” at all costs

• Lack of engineering support from

Buncefield Oil Depot, UK (2005)

Unprecedented high explosion overpressures

“Before Buncefield a massive vapour cloud explosion at a tank farm was not deemed a credible major incident risk.”

Industries typically with:

• Large inventories of dangerous substances

• Complex processing (requires careful control)

What is Process Safety?

Focus on Prevention of catastrophic events:

• Major fires, explosions, toxic release

• Major pollution potential

“Hard Hat” safety tends to focus more on:

• Personal Injury (reactive performance measures)

Process Safety

• Analysis of credible (realistically possible) major accident causes and scenarios

What is Process Safety?

Process Safety vs “Hard Hat” safety

What is Process Safety?

Source: OGP

• Process Safety Relies on multiple barriers

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Process Safety Indicators

Overview:

Process Safety Management Elements

Safety Management

System (SMS)

Technical Risk Control (TRC) +

Brings together: Plant, Procedures, People

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Process Safety Indicators

Overview:

The US Federal Model of PSM – Focus on TRC Elements

1. Process Safety Information

• Needed for Hazard Analysis

• Process chemicals (toxicity, flammability)

• Technologies (inventory, operating parameters, process chemistry)

• Equipment (construction materials, design standards)

The US Federal Model of PSM – Focus on TRC Elements

2. Process Hazard Analysis

• Major Accident Hazard Identification

• Assessment of liklihood of specific consequences

• What-if, Checklists, HAZOP, FMEA, FTA, Modelling, Previous Incidents, Existing Controls

• Issue of Foreseeability –i i i

The US Federal Model of PSM – Focus on TRC Elements

3. Operating Procedures

• Safe Systems of Work/Procedures

• Permits

• Covering:

normal (start-up/shut-down)

abnormal (emergency)

Special (maintenance/cleaning/repair)

Pre-start up checks

The US Federal Model of PSM – Focus on TRC Elements

4. Employee Participation

• Consultation

• Cooperation

• Information accessibility

• Positive Safety Culture

The US Federal Model of PSM – Focus on TRC Elements

5. Training

• Competency Matrix

6. Contractor Control

• Contractors widely used in Process Industries

• Selection

• Induction

• Performance Monitoring

The US Federal Model of PSM – Focus on TRC Elements

7. Pre-Startup Safety Review (PSSR)

• New/Modified Processes

• At Simplest – check confirming everything in place

- Design

- PHA

- Procedures

- Training

- Etc

The US Federal Model of PSM – Focus on TRC Elements

8. Asset (Mechanical) Integrity

• Critical equipment fit for purpose

• Correctly installed

• Maintained

• Critical Equipment Identified – PR, ESD, Alarms, Sensors, Pressure Vessels

The US Federal Model of PSM – Focus on TRC Elements

9. Hot-Work Permits

• Hot-work on or near relevant processes

• Link to LOTO10. Management of Change (MoC)

• Potential Consequences of change

• Change = Process, Equipment, Personnel etc

• Level of change needs to be d fi d

The US Federal Model of PSM – Focus on TRC Elements

11. Incident Investigation

• Learning from Incidents

• Root Cause Analysis

• Analysis of what might have happened

12. Emergency Planning and Response

• Foreseeability

• ECC + Equipment + ERT

• On-site and Off-site

The US Federal Model of PSM – Focus on TRC Elements

13. Audit

• Internal Compliance

• Feeds to Management Reviews

• Implies Performance Standards/Indicators

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Leadership in PSM

• Process Safety Indicators

Overview:

The EU Federal Model of PSM – For Onshore Major Accident Hazard Sites

• Explicitly Integrates TRC and SMS

• Based on Seveso Incident (Italy, 1976)

• Seveso Directive in place since 1982

• Seveso III

- 2-tier system

- Requirements based on amounts and types of dangerous

The EU Federal Model of PSM – Top Tier Requirements

1. Notify Regulator

2. Major Accident Prevention Policy (MAPP)

• Aims

• Roles/Responsibilities

• Commitment towards Continuously Improving Control of Major Accident Hazards

• Essentially LEADERSHIP

The EU Federal Model of PSM – Top Tier Requirements3. SMS (Proportionate, to support

MAPP)

OH&S Policy

Planning

Implementation and Operation

Checking and Corrective Action

Management Review

Continual ImprovementLeadersh

ip

Hazard Analysis

MoC

Operating within Design Intent

CompetenceContractors

Asset Integrity

EmergencyIncident Investigation

Auditing

The EU Federal Model of PSM – Top Tier Requirements

4. Domino Effects

• Where regulator identifies these

• Must cooperate/exchange information

• Update MAPPs and SMS accordingly

The EU Federal Model of PSM – Top Tier Requirements

5. Safety Report that MUST Demonstrate

• MAPP and SMS implemented

• Major accident hazards and possible major accident scenarios identified

• Prevention and Mitigation Measures in Place

• Safety & Reliability –design, construction,

i i

The EU Federal Model of PSM – Top Tier Requirements

5. Safety Report that MUST Demonstrate

• Internal emergency plans drawn up (including clean-up/restoration)

• Provide information for external emergency services to draw up external plans

• Sufficient information for regulator – planning of further developments

The EU Federal Model of PSM – Top Tier Requirements

6. Regulators MUST

• Take account of Domino effects

• Take account of Land-use planning

• Provide essential information to Public

• Inspect Installations

• Prohibit operation of non-compliant installations

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Process Safety Indicators

Overview:

Process Safety Indicators (PSI)Major Accidents often come as a surprise to top management

• Low Personal Injury rate (no accidents in last 10 million hours..)

• Lots of safety initiatives in place (“hold the hand rail” etc..)

Major Accidents seem Inevitable to operatives (something they get used to):

• Corroding plant

• Process always run outside design intent

Process Safety Indicators (PSI)Small number of good PSIs gives early warning

• Cascade down– set at different levels (organisation, site, specific plant)

• Choose based on factors that might lead to major accident scenarios

• Mixture of leading (active) and Lagging (reactive)

Need monitoring/recording

Process Safety Indicators (PSI)Leading PSIs

• Are things operating as intended?

• Develop for specific areas e.g. MoC, Operating Procedures, Competency (level of training)Example PSIs - Maintenance

• Failure rate of components when tested

• Number of overdue scheduled maintenance tasks

Process Safety Indicators (PSI)Lagging PSIs

• Number of unintended releases

• Authorised operation outside normal operating envelope

• Failure of control devices to operate as intended

Objectives• Why are Process Industries a Special Case? – Examples from History

• What is Process Safety?

• Process Safety Management Elements

The US Federal Model (29 CFR 1910.119)

The EU Federal Model (Seveso III)

• Process Safety Indicators

Summary: