Lessons Learned from PSM Auditing

Transcription

1 Lessons Learned from PSM Auditing

2 OUTLINE What is an audit? Why are audits important? Regulatory requirements Audit procedure Common deficiencies found in PSM audits Considering a Maturity Model TM

3 WHAT IS AN AUDIT? An audit is a systematic, independent review to verify conformance with established guidelines or standards. It employs a well defined review process to ensure consistency and to allow the auditor to reach defensible conclusions. (Guidelines for Auditing Process Safety Management Systems, 2nd Edition, CCPS 2011) Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled. (ISO 19011:2011(en) Guidelines for auditing management systems)

4 WHAT IS AN AUDIT? An exercise in frustration An interruption of routine A threat to the facility A waste of time An unwanted intrusion into my life The ignorant leading the blind Something THEY do to ME

5 WHY IS AUDITING IMPORTANT? "Progress, far from consisting in change, depends on retentiveness. When change is absolute there remains no being to improve and no direction is set for possible improvement: and when experience is not retained, as among savages, infancy is perpetual. Those who cannot remember the past are condemned to repeat it." George Santayana "Those that fail to learn from history, are doomed to repeat it." Winston Churchill

6 LESSONS FROM THE PAST 1984 Bhopal 1989 Phillips Pasadena 1979 Three Mile Island 1976 Seveso 1974 Flixborough

7 PROCESS SAFETY REGULATIONS 29 CFR , OSHA Process Safety Management of Highly Hazardous Chemicals Promulgated CFR Part 68, EPA Risk Management Program Rule Promulgated 1996

8 ARE THE REGULATIONS WORKING? DuPont Insecticide Plant 2015 West Texas 2013 Deepwater Horizon 2010 Buncefield 2005, BP Texas City 2005

9 WHAT IS BEING DONE? PSM Regulations have not changed since their promulgation, but Letters of Interpretation 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 (August 1, 2013) More chemicals, lower TQs, more covered facilities EPA revised the RMP Rule

10 COMPLIANCE AUDIT WHY? Excellent tool to assess an 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 Required under PSM/RMP

11 Regulatory Requirements

12 ELEMENTS OF PSM 1. Employee Participation 2. Process Safety Information 3. Process Hazard Analysis 4. Operating Procedures 5. Training 6. Contractors 7. Pre-startup Safety Review 8. Mechanical Integrity 9. Hot Work 10. Management of Change 11. Incident Investigation 12.Emergency Planning and Response 13. Compliance Audits 14. Trade Secrets

13 COVERED PROCESSES AND CHEMICALS OSHA (29CFR ) A process which involves a chemical at or above the specified threshold quantities listed in Appendix A of OSHA 29CFR A process which involves a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 o F on site in one location, in a quantity of 10,000 pounds or more EPA (40CFR68) A threshold quantity of a regulated substance listed in is present at a stationary source if the total quantity of the regulated substance contained in a process exceeds the threshold

14 REGULATORY REQUIREMENTS Compliance Audits (o)(1), 68.79(a): Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed (o)(2), (b): The compliance audit shall be conducted by at least one person knowledgeable in the process (o)(3), (c): A report of the findings of the audit shall be developed.

15 REGUATORY REQUIREMENTS Compliance Audits (o)(4), (d): The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. Employers shall retain the two (2) most recent compliance audit reports.

16 CORPORATE GOALS Gap analysis Communication of information and Feedback Performance Measurement Monitoring PSM program continuous improvement Reducing the process safety risk Training of Auditors Sharing successful or best practices

17 Lead Auditor puts a team put together An audit schedule is put together Request for information is sent to the facility An audit protocol is developed Site Tour Audit information is gathered through Interviews Site walk-through Records review 3 RD PARTY AUDIT PROCEDURE Audit results are analyzed and findings are presented to the facility A report is prepared and certified

18 Common Deficiencies

19 COMMON DEFICIENCIES Mechanical Integrity 202 Process Safety Information 189 Process Hazard Analysis 188 Operating Procedures 184 Management of Change 92 Incident Investigation 71 Compliance Audits 47 Contractors 33 Training 29 70%

20 COMMON DEFICIENCIES Emergency Planning and Response 17 Employee Participation 15 Pre-Startup Safety Review Hot Work Permits 8 Trade Secrets 0 13 Total PSM Citations 1088

21 COMMON DEFICIENCIES Mechanical Integrity 156 Process Safety Information 140 Operating Procedures 114 Process Hazard Analysis 106 Management of Change 44 Compliance Audits 35 Training 21 Incident Investigation 19 Employee Participation 16 76%

22 COMMON DEFICIENCIES Contractors 14 Emergency Planning and Response 7 Pre-Startup Safety Review Hot Work Permits 1 Trade Secrets 0 5 Total PSM Citations 678

23 BASIS FOR THESE STATEMENTS 350+ audits / assessments performed Large, major operating companies to smaller, niche specialty chemical companies and industries

24 SITE WALK-THROUGH OBSERVATIONS Cracked Hoses Leaking Liquids

25 SITE WALK-THROUGH OBSERVATIONS Lack of ID for Manual Valves Rusty Pipes Lack of Hazard Communication Signage

26 COMMON DEFICIENCIES DEFINITIONS OF PSM BOUNDARIES Boundaries of PSM-covered process not well-defined or documented; leading to inconsistent interpretation of PSM boundaries across different departments and incomplete PHA assessment Failure to include interconnecting utilities in the PSM-covered process and PHA review process (e.g., steam, nitrogen, cooling water, etc.) Any possible solutions to this problem? SOLUTION: Redline/mark PSM-covered process boundaries on Facility Plot Plan AND process P&ID(s) AND Communicate

27 COMMON DEFICIENCIES PROCESS 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., API RP520/521 RV sizing contingency analysis and flare analysis)

28 COMMON DEFICIENCIES PROCESS SAFETY INFORMATION 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 ).

29 COMMON DEFICIENCIES PROCESS SAFETY INFORMATION Standard API 520 API 521 API 752 API 753 API 510 API 570 API 574 ANSI/ISA S84.01 Title Sizing, Selection & Installation of Pressure-Relieving Devices in Refineries Pressure-Relieving and Depressuring Systems Management of Hazards Associated with Location of Process Plant Permanent Buildings Management of Hazards Associated with Location of Process Plant Portable Buildings Pressure Vessel Inspection Code In-service Inspection, Rating, Repair and Alteration Piping Inspection Code In-service Inspection, Rating, Repair and Alteration of Piping Inspection Practices for Piping System Components Functional Safety Safety Instrumented Systems for the Process Industry Sector

30 COMMON DEFICIENCIES PROCESS HAZARD 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 Can you recall an incident that happened during start-up?

31 COMMON DEFICIENCIES PROCESS HAZARD ANALYSIS PHA performed in the absence of at least one employee who has experience and knowledge specific to the process being evaluated. Failure to assess consequences to ultimate loss event assuming safeguards are non-existent or ineffective as designed. Safeguards not independent of the initiating event / cause. Failure to perform Layer of Protection Analysis (LOPA) to assess effectiveness of safeguards.

32 Previous incidents, including near misses, not considered by the PHA team. Overdue PHA recommendations with no managed schedule for resolution and completion. Incomplete compilation of Process Safety Information prior to performing the PHA. COMMON DEFICIENCIES PROCESS HAZARD ANALYSIS

33 COMMON DEFICIENCIES PROCESS HAZARD ANALYSIS Process hazard analyses were not updated and revalidated at least every five (5) years. Failure to address FACILITY SITING issues. Failure to address HUMAN FACTORS issues. USE INDUSTRY-STANDARD CHECKLISTS!!!

34 COMMON DEFICIENCIES OPERATING PROCEDURES SOPs not written for ALL phases of operation (esp., non-routine operations, e.g., purging, cleaning, sampling, temporary operation, emergency operation, 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 Lack of annual certification

35 COMMON DEFICIENCIES SAFE WORKING PRACTICES No documented Equipment-specific procedures for LOTO, Confined Space Lack of periodic training for LOTO, Confined Space

36 COMMON DEFICIENCIES MANAGEMENT OF CHANGE MOC process not applied for: Installation of temporary equipment Decommissioning or taking equipment out-ofservice Changes to alarm setpoints Procedural-only changes (e.g., conversion from paper-based to electronic systems) Changes in shift work; workforce reductions Why do you think it is important to address organizational changes?

37 COMMON DEFICIENCIES MANAGEMENT OF CHANGE PSI, SOPs, M.I. not updated when affected by the MOC. MOC forms completed and signed off before PSSR completed.

38 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 COMMON DEFICIENCIES MECHANICAL INTEGRITY Failure to identify and implement RAGAGEPs for inspections and tests

39 COMMON DEFICIENCIES MECHANICAL 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.

40 COMMON DEFICIENCIES INCIDENT INVESTIGATION Near misses not recorded; 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 1 Incidents of greater consequence Level 2 Incidents of lesser consequence Level 3 Challenges to safety system Level 4 Operating Discipline & Management System Performance Indicators. (Not reported yet in RCI)

41 Missing records of initial training for qualified operators. Refresher training not conducted at least every three (3) years. COMMON DEFICIENCIES TRAINING Lack of verification of personnel comprehension of training program. No written proof that operators were consulted on frequency or content of refresher training. Refresher training too focused on normal operations.

42 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 COMMON DEFICIENCIES CONTRACTORS Lack of periodic surveillance of contractors postselection; contractors only disciplined when something goes wrong

43 COMMON DEFICIENCIES EMPLOYEE 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.

44 Considering the Maturity Model PSRG s Maturity Model TM is an extension of the business practice of examining the maturity of a business process by comparison to a set of indicators and assigning a score. Its best and highest use is to align Process Safety Management as a business practice in the minds of corporate executives.

45 MATURITY MODEL Based on Levels 1-4 where 1 is Reactive and 4 is Optimized (Best-in-Class) Ability to gauge overall as well as individual PSM element performance Model defines Best-in- Class Safety Management System Level Definition 1 Reactive/Initial 2 Dependent/Defined 3 Managed/ Independent Managed 4 Optimized/ Interdependent

46 MATURITY MODEL Level 1: Reactive/Initial Level 2: Dependent/Defined Level 3: Managed/ Independent Managed Level 4: Optimized/ Interdependent Immature safety system, procedures reviewed when needed. Employer meets less than 80% of the criteria developed in Level 4. Structured and documented policies with focus on following procedures Good understanding of the requirements outlined in 29 CFR The employer meets at least 80% of the criteria developed in Level 4 Individuals use wide range of tools and behaviors to care for themselves with managers taking action when needed. The employer meets at least 90% of the criteria developed in Level 4. Everyone takes proactive approach, peer to peer focus, assessment through continuous improvement. The employer has consistently achieved 98% of the criteria developed for the past three PSM audits as certified by external auditors.

47 EXAMPLE CHECKLIST MATURITY MODEL Element Level 1 Level 2 Level 3 Level 4 Process Hazard Analysis Hazards inadequately addressed Lack of full team member ID and Expertise No system to promptly address recommendations Actions not communicated to working groups Not timely updated/revalidated within 5 years Not retrievable Procedure developed with methodologies Subsequent PHAs timely updated or revalidated Employees trained in leadership or PHA participation Pre-formatted industry standard templates used Team members and areas of expertise identified Comprehensive reports System to promptly communicate recommendations PHA revalidated every 5 years Records Retrievable Procedure developed with methodologies including LOPA Subsequent PHAs timely updated or revalidated before 5-year anniversary Employees trained in leadership or PHA participation Pre-formatted industry standard templates used Team members and areas of expertise identified Comprehensive reports System to promptly communicate recommendations Tracking System for actions includes metrics System to promptly communicate actions/findings 5 year PHA schedule developed Procedure developed with methodologies including LOPA Subsequent PHAs timely updated or revalidated before 5-year anniversary Employees trained in leadership or PHA participation Pre-formatted industry standard templates used Team members and areas of expertise identified Comprehensive reports System to promptly communicate recommendations Tracking System for actions includes metrics Findings/Actions communicated to affected workforce 5 year PHA schedule developed, reviewed annually for planning and team assignment

48 COMPARISON TO STYLES OF BENCHMARKING Level Target (Best-in-Class) C A B D Maturity Level Between Level 1 & 2 Level 2 Between Level 2 & 3 Score 1 (Below Compliance) 2 (Compliance) 3 (Compliance plus) 0 Facility Levels 1-4 where 1 is below par and 4 is Best-in-Class Level 4 4 (Best-in-Class)

49 IN SUM Why is Auditing Important Regulatory Requirements Common PSM Audit Deficiencies PSRG s Process Safety Management Maturity Model

50 SOME REFERENCES Guidelines for Auditing Process Safety Management Systems, 2nd Edition, CCPS (Center for Chemical Process Safety), 2011 (ISO 19011:2011(en) Guidelines for auditing management systems) U.S. Chemical Safety and Hazard Identification Board, Investigation report, report No I-TX, Refinery Explosion and Fire, 2007 The Environmental Health and Safety Auditor s Handbook (Greeno et al., 1987)

51 WHAT IS AN AUDIT? An exercise in frustration An interruption of routine A threat to the facility A waste of time An unwanted intrusion into my life The ignorant leading the blind Something THEY do to ME

52 3 RD PARTY PERSPECTIVE FOR A SUCCESSFUL AUDIT SOMETHING THEY DO TO ME MUST BECOME SOMETHING WE DO TOGETHER

53 THANK YOU