Guidelines Implementing Process Management Systems
24
Guidelines for Implementing Process Safety Management Systems CENTER FOR CHEMICAL PROCESS SAFETY of the AMERICAN INSTITUTE OF CHEMICAL ENGINEERS 345 East 47th Street, New York, New York 10017
Transcript of Guidelines Implementing Process Management Systems
Management Systems
CENTER FOR CHEMICAL PROCESS SAFETY of the
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS 345 East 47th Street, New York, New York 10017
dcd-wg
C1.jpg
Management Systems
of the SAFETY
Guidelines for Implementing Process Safety Management Systems Guidelines for Safe Automation of Chemical Pmcesses Guidelines for Engineering Design for Process Safety Guidelines for Auditing Pnxess Safety Management Systems Guidelines for Investigating Chemical Process Incidents Guidelines for Hazard Evaluation Procedums, Second Edition with Worked
Plant Guidelines for Technical Management of Chemical P m s s Safety Guidelines for Technical Management of Chemical Process Safety Guidelines for Chemical Process Quantitative Risk Analysis Guidelines for Process Equipment Reliability Data, with Data Tables Guidelines for Vapor Release Mitigation Guidelines for Safe Storage and Handling of High Toxic Hazard Materials Guidelines for Use of Vapor Cloud Dispersion Models Safety, Health, and Loss Prevention in Chemical Processes: Problems for
Safety, Health, and Loss Prevention in Chemical Pmsses: Problems for
Workbook of Test Cases for Vapor Cloud Sou= Dispersion Models Proceedings of the International Process Safety Management Conference
Proceedings of the International Confemnce on Hazard Identification and
Examples
and Workshop, 1993
Risk Analysis, Human Factors, and Human Reliability in Process Safety, 1992
Mitigating the Consequences of Accidental Releases of Hazardous Materials, 1991.
Proceedings of the International Conference/Workshop on Modeling and
Proceedings of the International Symposium on Runaway Reactions, 1989 CCPS/AIChE Directory of Chemical Process Safety Services Elechnic Chemical Pmcess Quantitative Risk Analysis Bibliography
Guidelines for Implementing Process Safety
Management Systems
CENTER FOR CHEMICAL PROCESS SAFETY of the
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS 345 East 47th Street, New York, New York 10017
Copyright 8 1994 American Institute of Chemical Engineers 345 East 47th Street New York, New York 10017
All rights reserved. No part of this publication may be reproduced, stored in a lptrieval system, or transmitted in any form or by any means, electronic, mechani- cal, photocopying, recording, or otherwise without the prior permission of the copyright owner.
Library of Congress Cataloging-in Publication Data Guidelines for implementing pmcess safety management systems.
p. cm. Includes bibliographical Rferences and index. ISBN0-8169-0590-8 : $120.00 1. Chemical procffses--Safety measures. I. American Institute of
Chemical Engineers. Center for Chemical Process Safety, TP149G838 1993 660' .2804-dc20 93-23165
CIP
~ ~~~ ~ ~
This book is available at a special discount when ordered in bulk quantities. For information, contact the Center for Chemical Process Safety at the address shown above.
It issincerely hoped that theinfonnation presented inthisdocumentwilllead toanevenmoreimpressive safetyrecod for theentire industry; however, the American IwtituteofChemicalEngineers, itsconsult- ants, CCPSsubcommitkemembers, their employers, theiremployers'officersand directors, and Arthur D. Little, Inc.dipclaim makingorgivinganywarrantiesorrep~ntations,expressorimplied,including with respect to fitness, intended purpose, useor merchantability and/orcortwtnessoraccuracyof the contentof the infonnation presented in thisdocument. Asbehveen (1) the American InstituteofChemical Engineers, its consultants, CCPS subcommittee members, their employers, their employera'officers and directors, and Arthur D. Little, Inc. and (2) the user of this document, the user accepts any legal liability ar responsibility wha tsoever for the consequence of its use or misuse.
CONTENTS
ix xi
1.1 Overview and Objective of This Book 1.2 scope 1
1
1 4 4
1.2.1 What Kinds of Companies and Operations Are Covered? 1.2.2 What Information Is in This Book? What Is Not?
1.3 How To Use This Book
2. GET MANAGEMENT COMMITMENT 7
2.1 W h y Get Management Commitment? 2.2 Getting Top-Level Commitment
2.2.1 Selecting the Right Sponsor(s), 2.2.2 Selling the Need for PSM 2.2.3 Selling the Need for Top-level Commitment
2.3.1 Setting Goals for PSM 2.3.2 Communicating the Importance of PSM 2.3.3 Providing Resources
Management
7
a
39
3.1 Introduction 3.2 Select PSM Framework
3.2.1 CCPS Model 3.2.2 Other Models
3.3.1 Who Should Be on the Team? 3.3.2 How Should This Team Work? 3.3.3 Soliciting Team Members' Participation
3.3 Establish a PSM Team
V
vi CONTENTS
3.3.4 Scheduling and Organizing the First Meeting 3.35 Conducting Team Meetings
3.4.1 Characterize Company Management System Appmch 3.42 Define Supervision/Delegation Appmch 3.4.3 Define Documentation Approach 3.4.4 Define Communication Appmach
3.4 Define CompanySpedfic Attributes
4. EVALUATE THE PRESENT STATUS 4.1 Recognize the Objective 4.2 Select an Evaluation Tool
42.1 Audits 4 2 2 Surveys
4.3 Perform the Evaluation 4.4 Identi9 Gaps and Overlaps
5. DEVELOP A PLAN 5.1 Review the Preliminary Plan 5.2 Select an Implementation Strategy
52.1 Companywide Appmach 5 2 2 Facility-Specific Appmach 52.3 "Hybrid" Appmach
5.3.1 Priority Facilities 5.32 Priority Elements 5.3.3 Limitations on the Scope of the Plan
5.4.1 Develop a Pmgram Plan 5.42 Develop a Schedule 5.4.3 Develop a Resoufie Plan
5.3 Define Priorities
5.4 Estimate Resome Needs and Schedule
5.5 Communicate and Get Approval of the Plan Appendix 5-1: h p l e Facility Ranking Process Appendix 5-2 Example of Management Presentation on PSM Plan
6. DEVELOP SPECIFIC PROCESS SAFETY MANAGEMENT SYSTEMS
6.1.1 Total Quality Management FQM) Techniques 6.1 2 Using Model Programs 6.1.3 Business Process Redesign
6.1 Select an Approach
73
95
95 95 96 97 99 100 101 104 1 05 106 107 112 112 121 124 126
129
CONTENTS vii
6.2 Select a Team 6.3 Develop the System 6.4 Recheck against Criteria
7. PUT THE SYSTEM INTO PRACTICE 7.1 Pilot Testing
7.1.1 Fadots to Consider in Pilot-Site Selection 7.12 Gaining Local Support for the Pilot Test 7.1.3 Implementing a Successful PSM Pilot 7.1.4 Assessing Pilot Test Results
72.1 Where to Begin Installation 7 2 2 Who Should Manage Installation
7.3.1 Describe System Benefits 7.32 Reinfofie Buy-In from Management 7.3.3 Reinforce Buy-In from Participants
7.4 Design and Provide Training 7.4.1 Training Managers 7.42 Training Trainers 7.4.3 Training Users 7.4.4 Training Others (e.g., Contractors) 7.4.5 Training Methods and Tools
7.2 Plan and Manage Installation
7.3 Sell the System
8. MEASURE AND MONITOR INSTALLATION 8.1 Introduction 8.2 Monitor Installation
82.1 Plant-Level Monitoring 8 2 2 Companywide Monitoring
8.3 "Customer Feedback" and Follow-Up Conclusion
9. EXPANDING BEYOND INITIAL SCOPE 9.1 Introduction 9.2 Expanding Beyond Minimum Requirements 9.3 Involve Other Activities 9.4 Involve Other Functions
142 145 146
147
147 148 149 150 158 159 159 161 161 1 62 163 165 168 169 169 170 171 172 173
175 175 175 176 177 182 185
187 187 187 188 188
viii CONTENTS
9.5 Expand to Other Processes 9.6 Expand Internationally
9.6.1 Evaluate Local Needs 9.62 Establish Priorities 9.6.3 Match Systems to Local Needs
Conclusion
EPILOGUE
Background Introduction Getting Management Commitment Defining Goals Evaluating the Present Status Developing a Plan Developing Specific PSM Systems Putting the System into Practice Measuring and Monitoring Expanding Beyond Initial Scope
BIBLIOGRAPHY
195
197
197 199 200 201 203 204 206 207 209 210
21 3
INDEX 215
PREFACE
The Center for Chemical Process Safety (CCPS) has recognized since its inception that enhancements in chemical process technologies, taken alone, are not sufficient to prevent catastrophic events such as the Bhopal disaster. It is obvious that successful chemical process management technologies need the commitment and participation of top management. Therefore, with sup- port from itsadvisory and managingboards, CCPSestablished a multifaceted program to address the need for technical management commitment and technical management systems to xvduce the potential for exposures to the public and to the environment.
The first document produced under the CCPS program was a bmchure entitled “A Challenge to Commitment,” which was mailed to the CEOs of more than 1500 companies. It provides an overview and an outline of a comprehensive model for the technical management of chemical process safety, characterized by twelve distinct and essential elements.
The second publication was a book entitled Guidefinesfor Technical Manage- ment of Chemical Process Safety. It expands on the twelve elements of the CCPS model and pmvides both the framework and detailed components for a chemical process safety management system, and offers various alternatives for implementation of each of the elements and components of the model. To further supplement and ”customize” the model, American Institute of Chemi- cal Engineers (AIChE) conducts training pmgramsbased on thebook, to teach the use of the CCPS ptocess safety management pmgram.
A third publication, Plant Guidelines for Technical M a n a g h t of Chemical Process Safety, contains highly detailed instructions and example materials suitable for direct implementation at plants. Most of the example materials are taken fmm written pt.ocedurPs currently in place at some of the most pres- tigious U.S. plants. The guidelines axv directed toward all those individuals with responsibility for initiating and/or maintaining any of the elements detailed in Guidelinesfur Technical Management of Chemical Pmess Safety. Video training pmgrams based on these two books have also been produced to help companies ptesent the principles of ptocess safety management to employees. Other CCPS guidelines address individual elements-such as Auditing, Inci- dent Investigation, and Documentation-in greater detail.
This book complements previous work by CCPS in describing how to undertake the design, development, and installation of pmcess safety management systems.
ix
ACKNOWLEDGMENTS
The Center for Chemical Process Safety (CCPS) wishes to thank all the mem- bers of the Technical Management Subcommittee who provided guidance in the preparation of these materials. CCPS also wishes to express its apprecia- tion to members of the Technical Steering Committee for their advice and support.
The Technical Management Subcommittee included the following individ- uals: Alfred Bickum (Goodyear "irr & Rubber Company); John Dowbekin (Exxon Chemical Company); W.J. Fraser (Mexk & Company, Inc.); John Gallamoxt (DOW Chemical); Jeff Gunderson (Chevron ReseaKh &Technology Company); William Helmer (Hoechst Celanese Corporation); Gregory Keeports (Rohm and Haas Company); Anne McGuinness (Chevmn Corpora- tion); John Murphy @ow Chemical Company); Jim Parnell @.I. Dupont De Nemours & Company); Frank Ragonese (Mobil Oil Corporation); E. J. Ryczek (Metrk & Company, Inc.); Stanley Schechter (Rohm & Haas Company); Wayne Scheimann (Nalco Chemical Company); Leslie Scher (Grace Specialty Chemi- cals Company); Thomas Selders (ARCO); Joseph Sweeney (ARCO Chemical); C. R. West (PPG Industries, Inc.); and Sanford Schreiber (CCPS/AIChE).
Arthur D. Little, Inc., Cambridge, Massachusetts, was the contractor who pwpawd these Guidelines. R. Scott Stricoff was Arthur D. Little's Project Director. The principal author was Mary I. Woodell. Key contributors included Henry Ozog and David Webb. Tracey Martensen's contribution to manuscript preparation was invaluable.
We gratefully acknowledge the comments and suggestions submitted by the following companies and peer reviewers: Henry Blunt (Shell Oil); Arthur F. Burk (DuPont); Charles Dancer (Allied Signal); J. A. Hoffmeister (Martin Marietta Energy Systems); Robert Ormsby (Air Pmducts and Chemicals); Duane Sanderson (3M); Anthony A. Thompson (Monsanto); and Guy Van Cleve (Petrocon).
xi
Table 2-2
Figure 2-2 Figure 2-2 Figure 2-3 Figure 2 4 Figure 2-5 Figure 2-6 Figure 2-7 Figure 2-8 Figure 2-9 Figure 3-2
Figure 3-2
Figure 3-3
Figure 3-5 Figure 3-6
Figure 3-7 Figure 3-8 Figure 3 -9 Figure 4-1 Figure 4-2 Figure 4-3
LIST OF TABLES, FIGURES, AND APPENDICES
AIChE/CCPS Process Safety Management Elements
PSM Sponsolship Roles PSM Ptesentation Worksheet and Sample Outline Sample Executive Summary Sample Vision Statement Sample Group Charter or Mission Statement Example of Preliminary Company Plan Summary Example of a Preliminary Divisional Plan Summary Sample Skills Matrix Sample Level of Effort Allocation Matrix Chemical Manufacturers Association (CMA) Process Safety Management Elements American Peholeum Institute (API) P m s s Safety Management Elements Environmental Protection Agency (EPA) Risk Management Program Components Occupational Safety and Health Administration (OSHA) P m s s Safety Management Elements Sample PSM Skills/Impact Matrix Sample PSM Team Mission Statement: Outline and Final Version Sample Matrix: Skills Applied to Tasks Sample Matrix: Staff Allocation by Project Phase Sample Agenda for First PSM Team Meeting Process Safety Management Assessment Framework
2
9
16
20
26
27
32
34
36
38
47
48
48
49
52
80 Example Page from an Audit Protocol Format
xiii
XiV
Figure 4-8
Figure 4-9 Figure 4-20 Figure 4-12 Figure 5-1 Figure 5-2 Figure 5-3
Figure 5-4 Figure 5-5
Figure 5-7 Figure 5-8 Figure 5-9 Figure 5-20 Figure 5-22
Figure 5-12 Figure 5-23
Figure 5-24 Figure 6-2
LIST OF TABLES, FIGURES, A N D APPENDICES
Example Page from a PSM Topical Outline Baseline Audit Report for Management of Change Yes/No Questionnaire for PSM P q p m Evaluation Open-Ended Questionnaire for Evaluating Operating Plocedutes Pmgram Sample Management Grid: PSM Elements/Primary Responsibility and Lmation Maturity of PSM Systems and Pmgrams Example of PSM Status Summary Example of an Interim Report from a PSM Task Team Example of Responsibility Matrix for Hybrid Appmch Sample Analysis of Selected PSM Gaps and Priorities Sample Work Bteakdown Structute: Priority Elements and Tasks Example of Intemlated PSM Elements and Priorities Example Matrix : Skills/Tasks Required for Developing PHA Program Example Task Leadership Assignments for PHA Pmgram Development PSM Staffing Needs by Element and Function Final Plan Schedule-Linear limeline Final Plan Schedule for Overall Pmgmm Staff Resoumes Plan for "Develop PHA Process" Example of Ideal Staff Needs vs. Actual Availability Analysis Sample Pmject Plan Table of Contents Example of Pmject Plan Sections on "Installation and Verification" and "Financial Contmls" Sample Report: Resources Used vs. Plan Simplified Example of TQM Team Results: Customer/Supplier Needs Simplified Example of TQM Team Results: Current P m s s Flow Simplified Example of TQM Team Results: Identification of Bteakdown Points Simplified Example of Adaptation of a Model Pmgram Simplified Example of Stakeholder Needs
81
82
84
85
90
91
92
93
99
103
108
109
110
110
111
113
117
118
120
121
122
131
Figure 6-6 Figure 6-7
Figure 6-8 Figure 6-9 Figure 7-1 Figure 7-2 Figure 7-3 Figure 74 Figure 7-5 Figure 7-6 Figure 7-7 Figure 8-1 Figure 8-2 Figure 83 Figure 8 4 Figure 8-5 Figure 8-6 Figure 9-2
Figure 9-2
Figure E-1
Simplified Example of Identifying Bamers 139 Simplified Example of Roles Definition 140
Simplified Example of Redesigned Pmcess Flow 141
Sample Outline for Management System SOP 145
Summary of PSM Pilot Test Goals and Parameters 151
Pilot Test Roles and Responsibilities 1 52
Sample Pilot Test Feedback Questionnaite 153
Sample PSM Pilot Test Interim Report to Management 156
Sample PSM Pilot Test Interim Report to Facility Managers 157 Example of Job Description for Managing PSM Pilot Test 162
164
Example of a Monthly Status Report Used within a Facility 177
Example of Quarterly Status Report 179 180
181
1 82
Example of a PSM System User Feedback Survey 183 Application of PSM Elements to Chemical Distribution Activities 189
Comparison of PSM Elements with Industrial Hygiene Management Needs 191 Stages of Pmcess Safety Management Systems 195
Example of PSM Customer Benefits Grid
Sample On-Site Review Interview Format Example of an Exception Report to Management Example of an Overview Report to Management
Appendix 2-1 Sample Document Ptesenting PSM to Senior Management 39
124 Appendix 5-2 Example Management Pmsentation on PSM Plan 126
Appendix 5-1 Example Facility Ranking Plocess
This page intentionally left blank
INTRODUCTION
1.1 OVERVIEW AND OBFCrIVE OF THIS BOOK
Since its founding in 1985, the American Institute of Chemical Engineers’ Center for Chemical Process Safety (CCPS) has promoted enhanced manage- ment of chemical process safety. Leading the way in recognizing that process safety involves both technology and management, the CCPS pmgram has included a series of initiatives designed to address the concerns and interests of senior management (A Challenge to Commitment), middle management (Guidelinesfor the Technical Management of Chemical Process Safety), and plant- level staff (Plant Guidelinesfor Technical Management of Chemical Process Safety). These materials derive from CCPS’ model for the technical management of chemical process safety, which is presented here as Table 1-1.
Guidelines fur Implementation of Process Safety Management is designed to assist those who are called upon to design, develop, and install p m s s safety management systems within their plants or companies: the people who must “make it happen.” Therefore, this book includes examples and references to assist in the design of a management system for implementation of p m s s safety throughout a plant or company.
The task of processsafety management implementation iscomplexbecause it crosses over several functional areas of a company’s organization. For example, comprehensive process safety management systems influence re- searrh, development, and engineering; facility and process construction, oper- ation, and maintenance; training throughout the organization; p m r e m e n t ; and information management.
This book provides practical assistance in how to implement the ideas and concepts found in earlier CCPS publications.
1.2 SCOPE
1.2.1 What Kinds of Companies and Operations Are Covered?
These Guidelines are designed to be adaptable to the needs of most operations involved in the storage, transfer, use, and processing of hazardous materials, and the information is intended to be adapted by the rrader.
1
Accountability. Objectivcr and Goals Continuity of operations Continuity of systems (RSOUIWS and finding) Continuity of organizations Company expectations (vision or master plan) Qualitypnxess Control of exceptions Alternative methods (performance vs. specification) Management accessibility Communications
Procar Knowledge and Documentation Process definition and design criteria Pmcess and equipment design Company memory (management information) Documentation of risk management decisions Protective systems Normal and upset conditions Chemical and occupational health hazards
Capital Project Review and Design Procedures (for new or existing plrnta, expansions, and acquiritions)
Appropriation request procedures Riskassessment for investment pu- Hazalds xwiew (including worst credible cases) Siting (relative to risk management) Piotplan Plpcess design and m i e w procedure8 Project management pmcedures
Process Risk Management Hazard identification Riskassessment of existing operations Reduction of risk Residual risk management (in-piant emexgency response and mitigation) Process management during emergencies Encouraging client and supplier companies to adopt similar risk management practices Selection of businesses with acceptable risks
Management of Change Change of technology Change of facility Organizational changes that may havean impact on process safety Variance procedums Temporary changes Pennanmt changes
1.2 SCOPE 3
Process and Equipment Integrity Reliability engineering Materials of construction Fabrication and inspection p m e d u m Installation pmedures Preventive maintenance Pmess, hardware, and systems inspections and testing (pre-startup safety review) Maintenance pmedures Alarm and instrument management Demolition procedures
Human Factors Human error assessment Operator/process and equipment interfaces Administrative controls V e n u s hardware
Training and Performance Definition of skills and knowledge Training programs (e.g., new employees, contractors, technical employees) Design of operating and maintenance pmedutps Initial qualification assessment Ongoing performance and refresher training Instructor program Records management
Incident Investigation
Incident recording
Standards, Codes, and Laws Internal standards, guidelines, and practices (past history, flexible performance
~ Majorincidents
~ Communication
Audits and Corrective Actions Process safety audits and compliance reviews Resolutions and closeout procedures
Enhancement of Process Safety Knowledge Internal and external research Improved pdic t ive systems Pmess safety reference library
4 1. INTRODUCTION
This book primarily addresses process safety management for facilities handling hazardous materials, and describes activities and appmacheswithin medium- to large-size U. S. companies. Howevel; readers will find that many of the principles outlined herp alp equally applicable and lpadily adaptable to smaller operations and single-plant operations. Similarly, although the case study provided at the end of this volume focuses on the chemical industry the principles it illustrates apply to the full range of allied industries such as pulp and paperr electronics, oil and gas, etc. The Guidelines can be seen as a template that can be refined and applied to a wide range of processes, industries, and organizational structures.
To assist you in looking beyond this book, Chapter 9 addmses the expan- sion of process safety management programs and techniques to cover trans- portation and other business activities nquiring environmental, health, and safety contml. Chapter 9 also raises some of the issues that readers should consider in implementing process safety management internationally.
1.2.2 What Znfomultion Is in This Book? What Zs Not?
This book addresses the design, development, and installation of process safety management systems, but does not address subsequent operation and maintenance of those systems. The book's goal is to help you put together a workable, effective pmgram and put it in place within your company or plant.
There is no single "right " way to implement process safety mnngement. Effective programs and systems are fully integrated into an individual company's operations, and reflect its business priorities, cultuR, and organization. For this reason, as you will see, this book does not plpsent formulae or dictate instructions for implementation. Instead, it pmvides information and "how to" examples to help people who have responsibility for developing process safety management programs determine the approach that best fulfills their companies' specific needs.
Some of this information is presented in the form of very specific examples, used to illustrate a range of appmches and methods. This range is not intended to be all-inclusive; your company's pmise organization may not be represented here. However, every effort has been made to address several common structum, including centralized and decentralized operations and "top-down" and "bottom-up" management structures.
1.3 HOW TO USE THIS BOOK
Implementing p m s s safety management (PSM) is a process, each of whose phases builds on previous steps. This book's organization reflects this process chronologically. Chapters 2 through 8 of this book present a step-by-step
1.3 HOW TO USE THIS BOOK 5
discussion of the process of designing a management system for implement- ing pmcess safety.
Each chapter includes other common elements, including
"Hint" boxes, highlighting specific implementation pointers for con-
"Tmubleshooter" boxes, which help identify potential bottlenecks and sideration.
suggest ways to overcome them.
Because of its chmnological presentation, you will pmbably find it most productive to read this book in chapter order. As you undertake the pmcess it describes, you may find that some sections afle particularly relevant to your company, and elect to shafle them with teammates or other colleagues. Similarly, you may find it useful to consolidate hints for discussion inside your company.
At the end of this book you will find a case study describing PSM im- plementation at "Midwest Chemicals and Plastics."
Midwest Chemicals and Plastics (MCP) is an imaginary company, but as described it reflects many characteristics commonly seen in both large and small companies interested in PSM. MCPbeginsexploring PSM without a real understanding of what PSM involves or how to use the concepts. A "cham- pion" is appointed, and under the guidance of the champion and a team of others, MCP ptoceeds thmugh a series of steps including defining the goals, assessing their current status, establishing priorities, preparinga plan for PSM implementation, and designing testing and installing specific PSM systems.
The experience of MCP shows how both centralized and decentralized management approaches can be consistent with implementation of PSM. There is mote than one way to successfully design, develop, and install PSM systems, and in some cases more than one appmach will be needed within the same company.
As MCP proceeds with PSM implementation, the company emphasizes sharing and making effective use of programs that already exist, recognizing that PSM implementation is a big job, and no one can afford to "=-invent the wheel." Even when different divisions of MCP proceed with different ap- proaches to PSM implementation, ongoing communication facilitates sharing of information. As MCP assesses its PSM status and designs PSM systems, the team pays catvful attention to identifyingand using systems already in place.
MCP's success relies on the continuing support and commitment of the company's senior management. It is vital that such support be enlisted at the earliest stages of PSM design. The PSM implementation effort R q u i m resour- ces; given the inevitable competition for limited resouxces within any or- ganization, senior management support is a key success factor.
The MCP example, though fictional, helps to demonstrate how the ap- proaches described in thisbookcan come together to achieve PSM implemen- tation.
This page intentionally left blank
CENTER FOR CHEMICAL PROCESS SAFETY of the
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS 345 East 47th Street, New York, New York 10017
dcd-wg
C1.jpg
Management Systems
of the SAFETY
Guidelines for Implementing Process Safety Management Systems Guidelines for Safe Automation of Chemical Pmcesses Guidelines for Engineering Design for Process Safety Guidelines for Auditing Pnxess Safety Management Systems Guidelines for Investigating Chemical Process Incidents Guidelines for Hazard Evaluation Procedums, Second Edition with Worked
Plant Guidelines for Technical Management of Chemical P m s s Safety Guidelines for Technical Management of Chemical Process Safety Guidelines for Chemical Process Quantitative Risk Analysis Guidelines for Process Equipment Reliability Data, with Data Tables Guidelines for Vapor Release Mitigation Guidelines for Safe Storage and Handling of High Toxic Hazard Materials Guidelines for Use of Vapor Cloud Dispersion Models Safety, Health, and Loss Prevention in Chemical Processes: Problems for
Safety, Health, and Loss Prevention in Chemical Pmsses: Problems for
Workbook of Test Cases for Vapor Cloud Sou= Dispersion Models Proceedings of the International Process Safety Management Conference
Proceedings of the International Confemnce on Hazard Identification and
Examples
and Workshop, 1993
Risk Analysis, Human Factors, and Human Reliability in Process Safety, 1992
Mitigating the Consequences of Accidental Releases of Hazardous Materials, 1991.
Proceedings of the International Conference/Workshop on Modeling and
Proceedings of the International Symposium on Runaway Reactions, 1989 CCPS/AIChE Directory of Chemical Process Safety Services Elechnic Chemical Pmcess Quantitative Risk Analysis Bibliography
Guidelines for Implementing Process Safety
Management Systems
CENTER FOR CHEMICAL PROCESS SAFETY of the
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS 345 East 47th Street, New York, New York 10017
Copyright 8 1994 American Institute of Chemical Engineers 345 East 47th Street New York, New York 10017
All rights reserved. No part of this publication may be reproduced, stored in a lptrieval system, or transmitted in any form or by any means, electronic, mechani- cal, photocopying, recording, or otherwise without the prior permission of the copyright owner.
Library of Congress Cataloging-in Publication Data Guidelines for implementing pmcess safety management systems.
p. cm. Includes bibliographical Rferences and index. ISBN0-8169-0590-8 : $120.00 1. Chemical procffses--Safety measures. I. American Institute of
Chemical Engineers. Center for Chemical Process Safety, TP149G838 1993 660' .2804-dc20 93-23165
CIP
~ ~~~ ~ ~
This book is available at a special discount when ordered in bulk quantities. For information, contact the Center for Chemical Process Safety at the address shown above.
It issincerely hoped that theinfonnation presented inthisdocumentwilllead toanevenmoreimpressive safetyrecod for theentire industry; however, the American IwtituteofChemicalEngineers, itsconsult- ants, CCPSsubcommitkemembers, their employers, theiremployers'officersand directors, and Arthur D. Little, Inc.dipclaim makingorgivinganywarrantiesorrep~ntations,expressorimplied,including with respect to fitness, intended purpose, useor merchantability and/orcortwtnessoraccuracyof the contentof the infonnation presented in thisdocument. Asbehveen (1) the American InstituteofChemical Engineers, its consultants, CCPS subcommittee members, their employers, their employera'officers and directors, and Arthur D. Little, Inc. and (2) the user of this document, the user accepts any legal liability ar responsibility wha tsoever for the consequence of its use or misuse.
CONTENTS
ix xi
1.1 Overview and Objective of This Book 1.2 scope 1
1
1 4 4
1.2.1 What Kinds of Companies and Operations Are Covered? 1.2.2 What Information Is in This Book? What Is Not?
1.3 How To Use This Book
2. GET MANAGEMENT COMMITMENT 7
2.1 W h y Get Management Commitment? 2.2 Getting Top-Level Commitment
2.2.1 Selecting the Right Sponsor(s), 2.2.2 Selling the Need for PSM 2.2.3 Selling the Need for Top-level Commitment
2.3.1 Setting Goals for PSM 2.3.2 Communicating the Importance of PSM 2.3.3 Providing Resources
Management
7
a
39
3.1 Introduction 3.2 Select PSM Framework
3.2.1 CCPS Model 3.2.2 Other Models
3.3.1 Who Should Be on the Team? 3.3.2 How Should This Team Work? 3.3.3 Soliciting Team Members' Participation
3.3 Establish a PSM Team
V
vi CONTENTS
3.3.4 Scheduling and Organizing the First Meeting 3.35 Conducting Team Meetings
3.4.1 Characterize Company Management System Appmch 3.42 Define Supervision/Delegation Appmch 3.4.3 Define Documentation Approach 3.4.4 Define Communication Appmach
3.4 Define CompanySpedfic Attributes
4. EVALUATE THE PRESENT STATUS 4.1 Recognize the Objective 4.2 Select an Evaluation Tool
42.1 Audits 4 2 2 Surveys
4.3 Perform the Evaluation 4.4 Identi9 Gaps and Overlaps
5. DEVELOP A PLAN 5.1 Review the Preliminary Plan 5.2 Select an Implementation Strategy
52.1 Companywide Appmach 5 2 2 Facility-Specific Appmach 52.3 "Hybrid" Appmach
5.3.1 Priority Facilities 5.32 Priority Elements 5.3.3 Limitations on the Scope of the Plan
5.4.1 Develop a Pmgram Plan 5.42 Develop a Schedule 5.4.3 Develop a Resoufie Plan
5.3 Define Priorities
5.4 Estimate Resome Needs and Schedule
5.5 Communicate and Get Approval of the Plan Appendix 5-1: h p l e Facility Ranking Process Appendix 5-2 Example of Management Presentation on PSM Plan
6. DEVELOP SPECIFIC PROCESS SAFETY MANAGEMENT SYSTEMS
6.1.1 Total Quality Management FQM) Techniques 6.1 2 Using Model Programs 6.1.3 Business Process Redesign
6.1 Select an Approach
73
95
95 95 96 97 99 100 101 104 1 05 106 107 112 112 121 124 126
129
CONTENTS vii
6.2 Select a Team 6.3 Develop the System 6.4 Recheck against Criteria
7. PUT THE SYSTEM INTO PRACTICE 7.1 Pilot Testing
7.1.1 Fadots to Consider in Pilot-Site Selection 7.12 Gaining Local Support for the Pilot Test 7.1.3 Implementing a Successful PSM Pilot 7.1.4 Assessing Pilot Test Results
72.1 Where to Begin Installation 7 2 2 Who Should Manage Installation
7.3.1 Describe System Benefits 7.32 Reinfofie Buy-In from Management 7.3.3 Reinforce Buy-In from Participants
7.4 Design and Provide Training 7.4.1 Training Managers 7.42 Training Trainers 7.4.3 Training Users 7.4.4 Training Others (e.g., Contractors) 7.4.5 Training Methods and Tools
7.2 Plan and Manage Installation
7.3 Sell the System
8. MEASURE AND MONITOR INSTALLATION 8.1 Introduction 8.2 Monitor Installation
82.1 Plant-Level Monitoring 8 2 2 Companywide Monitoring
8.3 "Customer Feedback" and Follow-Up Conclusion
9. EXPANDING BEYOND INITIAL SCOPE 9.1 Introduction 9.2 Expanding Beyond Minimum Requirements 9.3 Involve Other Activities 9.4 Involve Other Functions
142 145 146
147
147 148 149 150 158 159 159 161 161 1 62 163 165 168 169 169 170 171 172 173
175 175 175 176 177 182 185
187 187 187 188 188
viii CONTENTS
9.5 Expand to Other Processes 9.6 Expand Internationally
9.6.1 Evaluate Local Needs 9.62 Establish Priorities 9.6.3 Match Systems to Local Needs
Conclusion
EPILOGUE
Background Introduction Getting Management Commitment Defining Goals Evaluating the Present Status Developing a Plan Developing Specific PSM Systems Putting the System into Practice Measuring and Monitoring Expanding Beyond Initial Scope
BIBLIOGRAPHY
195
197
197 199 200 201 203 204 206 207 209 210
21 3
INDEX 215
PREFACE
The Center for Chemical Process Safety (CCPS) has recognized since its inception that enhancements in chemical process technologies, taken alone, are not sufficient to prevent catastrophic events such as the Bhopal disaster. It is obvious that successful chemical process management technologies need the commitment and participation of top management. Therefore, with sup- port from itsadvisory and managingboards, CCPSestablished a multifaceted program to address the need for technical management commitment and technical management systems to xvduce the potential for exposures to the public and to the environment.
The first document produced under the CCPS program was a bmchure entitled “A Challenge to Commitment,” which was mailed to the CEOs of more than 1500 companies. It provides an overview and an outline of a comprehensive model for the technical management of chemical process safety, characterized by twelve distinct and essential elements.
The second publication was a book entitled Guidefinesfor Technical Manage- ment of Chemical Process Safety. It expands on the twelve elements of the CCPS model and pmvides both the framework and detailed components for a chemical process safety management system, and offers various alternatives for implementation of each of the elements and components of the model. To further supplement and ”customize” the model, American Institute of Chemi- cal Engineers (AIChE) conducts training pmgramsbased on thebook, to teach the use of the CCPS ptocess safety management pmgram.
A third publication, Plant Guidelines for Technical M a n a g h t of Chemical Process Safety, contains highly detailed instructions and example materials suitable for direct implementation at plants. Most of the example materials are taken fmm written pt.ocedurPs currently in place at some of the most pres- tigious U.S. plants. The guidelines axv directed toward all those individuals with responsibility for initiating and/or maintaining any of the elements detailed in Guidelinesfur Technical Management of Chemical Pmess Safety. Video training pmgrams based on these two books have also been produced to help companies ptesent the principles of ptocess safety management to employees. Other CCPS guidelines address individual elements-such as Auditing, Inci- dent Investigation, and Documentation-in greater detail.
This book complements previous work by CCPS in describing how to undertake the design, development, and installation of pmcess safety management systems.
ix
ACKNOWLEDGMENTS
The Center for Chemical Process Safety (CCPS) wishes to thank all the mem- bers of the Technical Management Subcommittee who provided guidance in the preparation of these materials. CCPS also wishes to express its apprecia- tion to members of the Technical Steering Committee for their advice and support.
The Technical Management Subcommittee included the following individ- uals: Alfred Bickum (Goodyear "irr & Rubber Company); John Dowbekin (Exxon Chemical Company); W.J. Fraser (Mexk & Company, Inc.); John Gallamoxt (DOW Chemical); Jeff Gunderson (Chevron ReseaKh &Technology Company); William Helmer (Hoechst Celanese Corporation); Gregory Keeports (Rohm and Haas Company); Anne McGuinness (Chevmn Corpora- tion); John Murphy @ow Chemical Company); Jim Parnell @.I. Dupont De Nemours & Company); Frank Ragonese (Mobil Oil Corporation); E. J. Ryczek (Metrk & Company, Inc.); Stanley Schechter (Rohm & Haas Company); Wayne Scheimann (Nalco Chemical Company); Leslie Scher (Grace Specialty Chemi- cals Company); Thomas Selders (ARCO); Joseph Sweeney (ARCO Chemical); C. R. West (PPG Industries, Inc.); and Sanford Schreiber (CCPS/AIChE).
Arthur D. Little, Inc., Cambridge, Massachusetts, was the contractor who pwpawd these Guidelines. R. Scott Stricoff was Arthur D. Little's Project Director. The principal author was Mary I. Woodell. Key contributors included Henry Ozog and David Webb. Tracey Martensen's contribution to manuscript preparation was invaluable.
We gratefully acknowledge the comments and suggestions submitted by the following companies and peer reviewers: Henry Blunt (Shell Oil); Arthur F. Burk (DuPont); Charles Dancer (Allied Signal); J. A. Hoffmeister (Martin Marietta Energy Systems); Robert Ormsby (Air Pmducts and Chemicals); Duane Sanderson (3M); Anthony A. Thompson (Monsanto); and Guy Van Cleve (Petrocon).
xi
Table 2-2
Figure 2-2 Figure 2-2 Figure 2-3 Figure 2 4 Figure 2-5 Figure 2-6 Figure 2-7 Figure 2-8 Figure 2-9 Figure 3-2
Figure 3-2
Figure 3-3
Figure 3-5 Figure 3-6
Figure 3-7 Figure 3-8 Figure 3 -9 Figure 4-1 Figure 4-2 Figure 4-3
LIST OF TABLES, FIGURES, AND APPENDICES
AIChE/CCPS Process Safety Management Elements
PSM Sponsolship Roles PSM Ptesentation Worksheet and Sample Outline Sample Executive Summary Sample Vision Statement Sample Group Charter or Mission Statement Example of Preliminary Company Plan Summary Example of a Preliminary Divisional Plan Summary Sample Skills Matrix Sample Level of Effort Allocation Matrix Chemical Manufacturers Association (CMA) Process Safety Management Elements American Peholeum Institute (API) P m s s Safety Management Elements Environmental Protection Agency (EPA) Risk Management Program Components Occupational Safety and Health Administration (OSHA) P m s s Safety Management Elements Sample PSM Skills/Impact Matrix Sample PSM Team Mission Statement: Outline and Final Version Sample Matrix: Skills Applied to Tasks Sample Matrix: Staff Allocation by Project Phase Sample Agenda for First PSM Team Meeting Process Safety Management Assessment Framework
2
9
16
20
26
27
32
34
36
38
47
48
48
49
52
80 Example Page from an Audit Protocol Format
xiii
XiV
Figure 4-8
Figure 4-9 Figure 4-20 Figure 4-12 Figure 5-1 Figure 5-2 Figure 5-3
Figure 5-4 Figure 5-5
Figure 5-7 Figure 5-8 Figure 5-9 Figure 5-20 Figure 5-22
Figure 5-12 Figure 5-23
Figure 5-24 Figure 6-2
LIST OF TABLES, FIGURES, A N D APPENDICES
Example Page from a PSM Topical Outline Baseline Audit Report for Management of Change Yes/No Questionnaire for PSM P q p m Evaluation Open-Ended Questionnaire for Evaluating Operating Plocedutes Pmgram Sample Management Grid: PSM Elements/Primary Responsibility and Lmation Maturity of PSM Systems and Pmgrams Example of PSM Status Summary Example of an Interim Report from a PSM Task Team Example of Responsibility Matrix for Hybrid Appmch Sample Analysis of Selected PSM Gaps and Priorities Sample Work Bteakdown Structute: Priority Elements and Tasks Example of Intemlated PSM Elements and Priorities Example Matrix : Skills/Tasks Required for Developing PHA Program Example Task Leadership Assignments for PHA Pmgram Development PSM Staffing Needs by Element and Function Final Plan Schedule-Linear limeline Final Plan Schedule for Overall Pmgmm Staff Resoumes Plan for "Develop PHA Process" Example of Ideal Staff Needs vs. Actual Availability Analysis Sample Pmject Plan Table of Contents Example of Pmject Plan Sections on "Installation and Verification" and "Financial Contmls" Sample Report: Resources Used vs. Plan Simplified Example of TQM Team Results: Customer/Supplier Needs Simplified Example of TQM Team Results: Current P m s s Flow Simplified Example of TQM Team Results: Identification of Bteakdown Points Simplified Example of Adaptation of a Model Pmgram Simplified Example of Stakeholder Needs
81
82
84
85
90
91
92
93
99
103
108
109
110
110
111
113
117
118
120
121
122
131
Figure 6-6 Figure 6-7
Figure 6-8 Figure 6-9 Figure 7-1 Figure 7-2 Figure 7-3 Figure 74 Figure 7-5 Figure 7-6 Figure 7-7 Figure 8-1 Figure 8-2 Figure 83 Figure 8 4 Figure 8-5 Figure 8-6 Figure 9-2
Figure 9-2
Figure E-1
Simplified Example of Identifying Bamers 139 Simplified Example of Roles Definition 140
Simplified Example of Redesigned Pmcess Flow 141
Sample Outline for Management System SOP 145
Summary of PSM Pilot Test Goals and Parameters 151
Pilot Test Roles and Responsibilities 1 52
Sample Pilot Test Feedback Questionnaite 153
Sample PSM Pilot Test Interim Report to Management 156
Sample PSM Pilot Test Interim Report to Facility Managers 157 Example of Job Description for Managing PSM Pilot Test 162
164
Example of a Monthly Status Report Used within a Facility 177
Example of Quarterly Status Report 179 180
181
1 82
Example of a PSM System User Feedback Survey 183 Application of PSM Elements to Chemical Distribution Activities 189
Comparison of PSM Elements with Industrial Hygiene Management Needs 191 Stages of Pmcess Safety Management Systems 195
Example of PSM Customer Benefits Grid
Sample On-Site Review Interview Format Example of an Exception Report to Management Example of an Overview Report to Management
Appendix 2-1 Sample Document Ptesenting PSM to Senior Management 39
124 Appendix 5-2 Example Management Pmsentation on PSM Plan 126
Appendix 5-1 Example Facility Ranking Plocess
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INTRODUCTION
1.1 OVERVIEW AND OBFCrIVE OF THIS BOOK
Since its founding in 1985, the American Institute of Chemical Engineers’ Center for Chemical Process Safety (CCPS) has promoted enhanced manage- ment of chemical process safety. Leading the way in recognizing that process safety involves both technology and management, the CCPS pmgram has included a series of initiatives designed to address the concerns and interests of senior management (A Challenge to Commitment), middle management (Guidelinesfor the Technical Management of Chemical Process Safety), and plant- level staff (Plant Guidelinesfor Technical Management of Chemical Process Safety). These materials derive from CCPS’ model for the technical management of chemical process safety, which is presented here as Table 1-1.
Guidelines fur Implementation of Process Safety Management is designed to assist those who are called upon to design, develop, and install p m s s safety management systems within their plants or companies: the people who must “make it happen.” Therefore, this book includes examples and references to assist in the design of a management system for implementation of p m s s safety throughout a plant or company.
The task of processsafety management implementation iscomplexbecause it crosses over several functional areas of a company’s organization. For example, comprehensive process safety management systems influence re- searrh, development, and engineering; facility and process construction, oper- ation, and maintenance; training throughout the organization; p m r e m e n t ; and information management.
This book provides practical assistance in how to implement the ideas and concepts found in earlier CCPS publications.
1.2 SCOPE
1.2.1 What Kinds of Companies and Operations Are Covered?
These Guidelines are designed to be adaptable to the needs of most operations involved in the storage, transfer, use, and processing of hazardous materials, and the information is intended to be adapted by the rrader.
1
Accountability. Objectivcr and Goals Continuity of operations Continuity of systems (RSOUIWS and finding) Continuity of organizations Company expectations (vision or master plan) Qualitypnxess Control of exceptions Alternative methods (performance vs. specification) Management accessibility Communications
Procar Knowledge and Documentation Process definition and design criteria Pmcess and equipment design Company memory (management information) Documentation of risk management decisions Protective systems Normal and upset conditions Chemical and occupational health hazards
Capital Project Review and Design Procedures (for new or existing plrnta, expansions, and acquiritions)
Appropriation request procedures Riskassessment for investment pu- Hazalds xwiew (including worst credible cases) Siting (relative to risk management) Piotplan Plpcess design and m i e w procedure8 Project management pmcedures
Process Risk Management Hazard identification Riskassessment of existing operations Reduction of risk Residual risk management (in-piant emexgency response and mitigation) Process management during emergencies Encouraging client and supplier companies to adopt similar risk management practices Selection of businesses with acceptable risks
Management of Change Change of technology Change of facility Organizational changes that may havean impact on process safety Variance procedums Temporary changes Pennanmt changes
1.2 SCOPE 3
Process and Equipment Integrity Reliability engineering Materials of construction Fabrication and inspection p m e d u m Installation pmedures Preventive maintenance Pmess, hardware, and systems inspections and testing (pre-startup safety review) Maintenance pmedures Alarm and instrument management Demolition procedures
Human Factors Human error assessment Operator/process and equipment interfaces Administrative controls V e n u s hardware
Training and Performance Definition of skills and knowledge Training programs (e.g., new employees, contractors, technical employees) Design of operating and maintenance pmedutps Initial qualification assessment Ongoing performance and refresher training Instructor program Records management
Incident Investigation
Incident recording
Standards, Codes, and Laws Internal standards, guidelines, and practices (past history, flexible performance
~ Majorincidents
~ Communication
Audits and Corrective Actions Process safety audits and compliance reviews Resolutions and closeout procedures
Enhancement of Process Safety Knowledge Internal and external research Improved pdic t ive systems Pmess safety reference library
4 1. INTRODUCTION
This book primarily addresses process safety management for facilities handling hazardous materials, and describes activities and appmacheswithin medium- to large-size U. S. companies. Howevel; readers will find that many of the principles outlined herp alp equally applicable and lpadily adaptable to smaller operations and single-plant operations. Similarly, although the case study provided at the end of this volume focuses on the chemical industry the principles it illustrates apply to the full range of allied industries such as pulp and paperr electronics, oil and gas, etc. The Guidelines can be seen as a template that can be refined and applied to a wide range of processes, industries, and organizational structures.
To assist you in looking beyond this book, Chapter 9 addmses the expan- sion of process safety management programs and techniques to cover trans- portation and other business activities nquiring environmental, health, and safety contml. Chapter 9 also raises some of the issues that readers should consider in implementing process safety management internationally.
1.2.2 What Znfomultion Is in This Book? What Zs Not?
This book addresses the design, development, and installation of process safety management systems, but does not address subsequent operation and maintenance of those systems. The book's goal is to help you put together a workable, effective pmgram and put it in place within your company or plant.
There is no single "right " way to implement process safety mnngement. Effective programs and systems are fully integrated into an individual company's operations, and reflect its business priorities, cultuR, and organization. For this reason, as you will see, this book does not plpsent formulae or dictate instructions for implementation. Instead, it pmvides information and "how to" examples to help people who have responsibility for developing process safety management programs determine the approach that best fulfills their companies' specific needs.
Some of this information is presented in the form of very specific examples, used to illustrate a range of appmches and methods. This range is not intended to be all-inclusive; your company's pmise organization may not be represented here. However, every effort has been made to address several common structum, including centralized and decentralized operations and "top-down" and "bottom-up" management structures.
1.3 HOW TO USE THIS BOOK
Implementing p m s s safety management (PSM) is a process, each of whose phases builds on previous steps. This book's organization reflects this process chronologically. Chapters 2 through 8 of this book present a step-by-step
1.3 HOW TO USE THIS BOOK 5
discussion of the process of designing a management system for implement- ing pmcess safety.
Each chapter includes other common elements, including
"Hint" boxes, highlighting specific implementation pointers for con-
"Tmubleshooter" boxes, which help identify potential bottlenecks and sideration.
suggest ways to overcome them.
Because of its chmnological presentation, you will pmbably find it most productive to read this book in chapter order. As you undertake the pmcess it describes, you may find that some sections afle particularly relevant to your company, and elect to shafle them with teammates or other colleagues. Similarly, you may find it useful to consolidate hints for discussion inside your company.
At the end of this book you will find a case study describing PSM im- plementation at "Midwest Chemicals and Plastics."
Midwest Chemicals and Plastics (MCP) is an imaginary company, but as described it reflects many characteristics commonly seen in both large and small companies interested in PSM. MCPbeginsexploring PSM without a real understanding of what PSM involves or how to use the concepts. A "cham- pion" is appointed, and under the guidance of the champion and a team of others, MCP ptoceeds thmugh a series of steps including defining the goals, assessing their current status, establishing priorities, preparinga plan for PSM implementation, and designing testing and installing specific PSM systems.
The experience of MCP shows how both centralized and decentralized management approaches can be consistent with implementation of PSM. There is mote than one way to successfully design, develop, and install PSM systems, and in some cases more than one appmach will be needed within the same company.
As MCP proceeds with PSM implementation, the company emphasizes sharing and making effective use of programs that already exist, recognizing that PSM implementation is a big job, and no one can afford to "=-invent the wheel." Even when different divisions of MCP proceed with different ap- proaches to PSM implementation, ongoing communication facilitates sharing of information. As MCP assesses its PSM status and designs PSM systems, the team pays catvful attention to identifyingand using systems already in place.
MCP's success relies on the continuing support and commitment of the company's senior management. It is vital that such support be enlisted at the earliest stages of PSM design. The PSM implementation effort R q u i m resour- ces; given the inevitable competition for limited resouxces within any or- ganization, senior management support is a key success factor.
The MCP example, though fictional, helps to demonstrate how the ap- proaches described in thisbookcan come together to achieve PSM implemen- tation.
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