Role of PSM Audits and Lessons Learned for Modernization of OSHA PSM Regulations

Transcription

1 Role of PSM Audits and Lessons Learned for Modernization of OSHA PSM Regulations Author: Robert J. Weber, P.E. Date: March 29, 2016 GTBR Process Safety Roundtable

2 2 Presentation Outline Industry Incidents and Lessons Learned Introduction to PSM Auditing PSM Common Deficiencies Regulatory Update PSM Key Success Factors Conclusion

3 3 Industry Incidents & Lessons Learned

4 4 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. Ducommun Vice President, Manufacturing and a Director of American Oil Company; Process Safety Pioneer [ ]

5 5 Flixborough, UK (1974) Nypro UK (Cyclohexane release & Explosion) 28 fatalities; 36 injuries onsite; 53 additional injuries offsite. 20 di. Temporary bypass pipe around reactor failed under thermal stress Lack of plant modification / change control. Lack of design codes for pipework. Lack of siting considerations.

6 6 Sevesto, Italy (1976) ICMESA (Industrie Chimiche Meda Società Azionaria) (Tetrachlorodibenzoparadioxin release) Release of a Dioxin, a poisonous and carcinogenic by-product of an 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.

7 7 Mexico City, Mexico (1984) PEMEX LPG Terminal BLEVE (Boiling Liquid Expansion Vapor Explosion) and fire after Loss of Containment in local sewer system Over 650 fatalities, mostly offsite; $20MM damages CONTRIBUTING FACTORS: Plant spacing and layout Active / passive fire protection Emergency isolation Emergency response / spill control

8 8 Bhopal, India (1984) Union Carbide India Limited (UCIL) (Methyl isocyanate (MIC) tank rupture & release) Considered the world s worst industrial disaster. Accident was a result of poor safety management practices, poor early warning systems, and the lack of community preparedness. 3,000+ fatalities; 100,000+ injured Eventually, resulted in the demise of Union Carbide, one of the world s largest integrated chemical companies.

9 9 Piper Alpha North Sea (1988) Occidental Petroleum, Piper Alpha Platform 167 fatalities $3.4B insured loss CONTRIBUTING FACTORS: Lack of adequate emergency evacuation and egress

10 10 Pasadena, Texas (1989) Phillips Pasadena Chemical Complex (Vapor Cloud Explosion) Explosion with a force of 2.4 tons of TNT. 23 fatalities; more than 130 injured. Property damage was $750MM+. The evidence showed that more than 85,000 pounds of highly flammable gases were released through an inadvertently open valve.

11 11 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). PSM emphasizes the management of hazards associated with highly hazardous chemicals and establishment of a comprehensive management program that integrated technologies, procedures, and management practices

12 12 Elements of Process Safety Trade Secrets Process Safety Information Process Hazard Analysis Operating Procedures Employee Participation Training Compliance Audits PROCESS SAFETY MANAGEMENT Contractors Emergency Planning and Response Pre-Startup Safety Review Incident Investigation Management of Change Hot Work Permit Mechanical Integrity

13 13 History of Process Safety IS IT WORKING???

14 14 BP Texas City (2005) (Vapor Cloud Explosion) 15 worker fatalities and more than 170 others were injured. Both the BP and the U.S. Chemical Safety and Hazard Investigation Board identified numerous technical and organizational failings at the refinery and within corporate BP.

15 15 Deepwater Horizon (2010) BP / Transocean / Halliburton (Explosion and sinking of the Deepwater Horizon oil rig followed by oil release) Considered the largest accidental marine oil spill in the history of the petroleum industry. Oil flowed for ~90 days; 134MM- 176 MM barrels spilled. Eleven workers were never found despite a three-day Coast Guard (USCG) search operation.

16 16 West, Texas (April 17, 2013) West Fertilizer Company (Ammonium nitrate explosion) 15 people fatalities; more than 160 people injured. More than 150 buildings and homes were damaged or destroyed due to blast. Investigators have confirmed that ammonium nitrate was the material that exploded. USGS recorded the explosion as a 2.1-magnitude.

17 17 History of Process Safety 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 (August 1, 2013) More chemicals, lower TQs, more covered facilities Stay tuned

18 18 PSM Auditing - Overview

19 19 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

20 20 Compliance Audit Why? Perform audit every three (3) years (OSHA 29CFR ) 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 and document corrective actions. Employer shall retain the two (2) most recent compliance audit reports.

21 21 Process Safety Management (PSM) COMMON DEFICIENCIES

22 22 Common Deficiencies BASIS 350+ audits / assessments performed Large, major operating companies to smaller, niche specialty chemical companies and industries

23 23 Common Deficiencies DEFINITION 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 PSMcovered process and PHA review process (e.g., steam, nitrogen, cooling water, etc.)

24 24 Common Deficiencies DEFINITION 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 PSMcovered process and PHA review process (e.g., steam, nitrogen, cooling water, etc.) SOLUTION: Redline/mark PSM-covered process boundaries on your Facility Plot Plan AND process P&ID(s) AND Communicate.

25 25 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.

26 26 Common Deficiencies Employee Involvement EXAMPLES 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)

27 27 RACI Matrix Role 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 COO HSSE Engineering & Construction 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 Operations PSM Supervisor Operators Maintenance All Employees Contractors

28 28 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)

29 29 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 ).

30 30 Common Deficiencies Process Safety Information 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

31 31 Common Deficiencies Process Safety Information 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

32 32 Common Deficiencies Process 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

33 33 Common Deficiencies Process Hazards Analysis 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.

34 34 Common Deficiencies Process Hazards Analysis Failure to address/update FACILITY SITING API RP 752 (2009) API RP 753 (2012) API RP 756 (2014)

35 35 Common Deficiencies Process Hazards Analysis Previous incidents, including near misses, not considered or documented 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.

36 36 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.

37 37 Common Deficiencies Safe Working Practices No documented Equipment-specific procedures for LOTO, Confined Space. Lack of periodic training for LOTO, Confined Space

38 38 Common Deficiencies Training 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.

39 39 Common Deficiencies Training No written proof that operators consulted on frequency or content of refresher training. Refresher training too much focused on normal operations.

40 40 Common Deficiencies Contractors 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 postselection; contractors only disciplined when something goes wrong

41 41 Common Deficiencies Pre-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

42 42 Common Deficiencies Mechanical 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

43 43 Common Deficiencies Mechanical Integrity Failure to review PHA and include all safeguards in Mechanical Integrity program (e.g., positive pressurization systems for control rooms, etc.) Focus on stationary equipment; less emphasis on Rotating Equipment and Instrumentation & Controls. Lack of fitness for service documentation for aging process equipment. MOC process not used for changes to inspection frequency.

44 44 Common Deficiencies Hot 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.

45 45 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

46 46 Common Deficiencies Management 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 before PSSR completed.

47 47 Common Deficiencies Incident 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 ( lagging ) versus near misses (leading indicator) Level 1 Incidents of greater consequenc e 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)

48 48 Common Deficiencies Incident 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.

49 49 Common Deficiencies Emergency Preparedness & Response Emergency action plan not up-to-date. Emergency evacuation maps with routes and safe distances not visibly 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.

50 50 Common Deficiencies Compliance Audits Compliance audits performed; but not certified in writing. Audits incomplete (i.e., not representative of the entire facility for multi-unit operations). Audit action items not tracked or completed in a timely manner.

51 51 Common Deficiencies OSHA Refinery NEP Enforcement Statistics 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 %

52 52 Common Deficiencies OSHA Refinery NEP Enforcement Statistics Emergency Planning and Response 17 Employee Participation 15 Pre-Startup Safety Review Hot Work Permits 8 Trade Secrets 0 13 Total PSM Citations 1088

53 53 Common Deficiencies Chemical NEP PSM Enforcement Statistics 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 %

54 54 Common Deficiencies OSHA Chemical NEP Enforcement Statistics Contractors 14 Emergency Planning and Response 7 Pre-Startup Safety Review Hot Work Permits 1 Trade Secrets 0 5 Total PSM Citations 678

55 55 Regulatory Update

56 56 Modernization of OSHA PSM Standard - Background AUGUST 2013: President Obama signed Executive Order ordering OSHA, EPA and DHS to improve the safety and security of the chemical industry in the U.S. DECEMBER 2013: OSHA published in the Federal Register a Request for Information (RFI) for comments on 17 areas of possible revision to the PSM Standard. JULY 2014: EPA published in the Federal Register a RFI for comments on 19 areas of possible revisions to the RMP Rule.

57 57 Modernization of OSHA PSM Standard - Background MAY 2014: EPA, OSHA and DHS issued a report to President recommending: Modernize PSM and RMP Promote safer technology and alternatives Develop guidelines on best practices for process safety Increase civil fines Serious: $7,000 to $12,744 Repeats/willfuls: $70,000 to $125,428

58 58 PSM Modernization: 17 Topics Listed in OSHA s RFI Eliminating the PSM Exemption for Atmospheric Storage Tanks Oil and Gas-Well Drilling and Servicing Resuming Enforcement for PSM-Covered Oil and Gas Production Facilities Expanding PSM Coverage and Requirements for Reactive Hazards Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard Revising the PSM Standard to Require Additional Management-System Elements Re-evaluation of Equipment Based on Evolving RAGAGEP Defining RAGAGEP for Employers KEY Yellow: Changes by Memo Blue: Changes by Court Green: Changes by EPA Expansion of Mechanical Integrity to Any Safety-Critical Equipment Clarifying Paragraph (l) of the PSM Standard with an Explicit Requirement that Employers Manage Organizational Changes Requiring Coordination of Emergency Planning with Local Emergency-Response Authorities Overhauling the Auditing Requirements in Paragraph (o) of the PSM Standard Expansion of to Cover the Dismantling and Disposal of Explosives, Blasting Agents and Pyrotechnics Updating the Flammable Liquid and Spray Finishing Standards Updating the Regulations Addressing the Storage, Handling and Management of Ammonium Nitrate Application of PSM Standard to Retailers that Sell Large or Bulk Quantities of Highly Hazardous Chemicals Changing Enforcement Policy for Highly Hazardous Chemicals Listed in Appendix A of the PSM Standard without Specific Concentrations

59 59 PSM Modernization: 17 Topics Listed in OSHA s RFI 1. Eliminating the PSM Exemption for Atmospheric Storage Tanks 2. Oil and Gas-Well Drilling and Servicing 3. Resuming Enforcement for PSM-Covered Oil and Gas Production Facilities 4. Expanding PSM Coverage and Requirements for Reactive Hazards 5. Updating the List of Highly Hazardous Chemicals in Appendix A of the PSM Standard 6. Revising the PSM Standard to Require Additional Management-System Element

60 60 PSM Modernization: 17 Topics Listed in OSHA s RFI 7. Re-evaluation of Equipment based on evolving RAGAGEP 8. Defining RAGAGAEP for Employers 9. Expansion of Mechanical Integrity to any Safety-Critical Equipment 10.Clarifying Paragraph (l) of the PSM Standard with an Explicit Requirement that Employers Manage Organizational Changes 11.Requiring Coordination of Emergency Planning with Local Emergency-Response Authorities 12.Revamp the Audit Requirements in (o)

61 61 PSM Modernization: 17 Topics Listed in OSHA s RFI 13.Expansion of to Cover the Dismantling and Disposal of Explosives, Blasting Agents and Pyrotechnics 14.Updating the Flammable Liquid and Spray Finishing Standards 15.Updating the Regulations Addressing the Storage, Handling and Management of Ammonium Nitrate 16.Application of PSM Standard to Retailers that sell Large or Bulk Quantities of Highly Hazardous Chemicals 17.Changing Enforcement Policy for HHCs listed in Appendix A of the PSM Standard without Specific Concentrations

62 62 PSM Key Success Factors

63 63 PSM Key Success Factors 1. Process Safety Leadership 2. Process Safety Competency 3. Process Safety Culture 4. Clearly Defined Expectations and Accountability 5. Leading and Lagging Indicators 6. Audit and Continuous Improvement 7. Community Outreach

64 64 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.

65 65 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.]

66 66 Peter Principle

67 67 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.

68 68 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.

69 69 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.

70 70 Audit & Continuous 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

71 71 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.

72 72 Path Forward REALIZE THE BENEFITS: SEVEN (7) KEY STEPS 1. 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.

73 73 Thank you!

74 74 PSRG PSM Forum Facility Siting Challenges and Blast-Resistant Design and Retrofit of Buildings at Refinery and Petrochemical/Chemical Facilities Speakers: Mr. Charles J. King, P.E. - PSRG Mr. Paul B. Summers, P.E., S.E., CPEng, F.ASCE - Simpson Gumpertz & Heger April 20, 2016 East Houston April 21, 2016 West Houston June 1, 2016 Baton Rouge June 2, 2016 Lake Charles