PSM REGULATORY UPDATE OSHA MARCH 2016

Transcription

1 PSM REGULATORY UPDATE OSHA MARCH 2016 Robert J. Weber, P.E. President/CEO + Houston + Bogota + Kuwait + Lagos + Singapore

2 PRESENTATION OUTLINE Industry Incidents & Lessons Learned Introduction to PSM Auditing PSM Common Deficiencies from Auditing Key Success Factors: What does good look like? Conclusion

3 INDUSTRY INCIDENTS & LESSONS LEARNED

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 in 1961; Process Safety Pioneer

5 FLIXBOROUGH, U.K. (1974) Nypro U.K. Cyclohexane release from temporary bypass pipe and subsequent explosion 28 fatalities, 36 onsite injuries Offsite consequences resulted in 53 reported injuries 1,800 nearby homes damaged $ 425MM USD property loss

6 FLIXBOROUGH, U.K. (1974) CAUSES / LESSONS LEARNED Lack of plant modification / change control. Management of temporary changes. Management of change for organizational change. Lack of design codes for pipework. Lack of land use planning and siting considerations relative to location of the process versus plant buildings and the local community.

7 SEVESO, ITALY (1976) ICMESA (Industrie Chimiche Meda Societa Azionaria) Tetrachlorodibenzoparadioxin ( DIOXIN ) release, a poisonous and carcinogenic by-product of uncontrolled exothermic reaction 25 km North of Milan No fatalities. More than 600 people evacuated; 20 people treated for Dioxin poisoning. Long-term health impacts. Led to development of initial EU Seveso directive.

8 MEXICO CITY (1984) PEMEX LPG Terminal BLEVE (Boiling Liquid Expansion Vapor Explosion) and fire after loss of containment to local sewer system 650+ fatalities, mostly offsite $20MM USD property damages Contributing Factors: Plant layout Active / passive fire protection Emergency isolation Emergency response / spill control

9 BHOPAL, INDIA (1984) Union Carbide India Ltd. (UCIL) insecticide plant Methyl isocyanate release 3,000+ fatalities; 100,000+ injuries Accident a result of poor safety management systems, poor early warning systems, and lack of community preparedness. Considered world s worst industrial disaster Eventually, resulted in demise of Union Carbide, one of the world s largest integrated chemical companies

10 PIPER ALPHA (1988) Occidental Petroleum Platform North Sea 167 fatalities $3.4B USD insured loss Contributing Factors Fire water system bypassed Lack of adequate emergency evacuation and egress

11 PHILLIPS PASADENA (1989) Vapor cloud explosion 85,000 lbs. flammable gas release; explosion with force of 2.4 tons TNT 23 fatalities; 130 injuries Property loss ~ $750MM USD Contributing Factors Human error (manual valve inadvertently left open) Facility siting and plant layout of process, buildings

12 HISTORY OF PROCESS SAFETY Process Safety Management was initiated by U.S. OSHA in 1992 as a way to respond with government regulations / oversight of industries using highly hazardous chemicals (HHCs). Several other countries have followed since.

13 Process Safety Management DEFINITION A management system design to PREVENT the Release of OR MINIMIZE the Consequences of Release of Highly Hazardous Chemicals (HHCs)

14 Process Safety Management ELEMENTS 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

15 HISTORY OF PROCESS SAFETY PERFORMANCE-based regulation, Not Prescriptive Regulation sets forth minimum requirements for compliance (based on 14 Elements) Regulation specifies WHAT TO DO, Not HOW TO IT

16 HISTORY OF PROCESS SAFETY IS IT WORKING?

17 BP TEXAS CITY (2005) Vapor cloud explosion 15 fatalities; 170 injuries Both BP and U.S. Chemical Safety & Hazard Investigation Board (CSB) identified numerous technical and organizational failings at the refinery and within BP corporate

18 WEST FERTILIZER (2013) Retail fertilizer operation in rural Texas Ammonium nitrate explosion 15 fatalities; 160+ injuries Many fatalities were emergency responders. More than 150 nearby buildings and homes damaged or destroyed due to blast USGS recorded explosion as a 2.1 magnitude

19 HISTORY OF PROCESS SAFETY U.S. regulations have NOT changed since their promulgation, but. OSHA Petroleum Refinery Process Safety Management National Emphasis Program (NEP) Directive 2007 OSHA PSM Covered Chemical Facilities National Emphasis Program (NEP) Directive 2011 Executive Order (August 2013) Pending changes by OSHA and EPA to PSM and RMP regulations to expand coverage, respectively More chemicals covered, more facilities covered, lower threshold quantities

20 PSM AUDITING OVERVIEW

21 COMPLIANCE AUDIT OSHA 29CFR (o) Perform audit at least every three (3) years. Conducted by at least one person knowledgeable in the process. A Report of the findings shall be developed. The employer shall document a response to each of the findings. The employer shall document corrective actions to each of the findings. Employer shall retain the two (2) most recent compliance audit reports.

22 COMPLIANCE AUDIT 1 Assemble Audit Team 2 Pre-Audit Activities 3 Audit 4 Post Audit Activities

23 COMPLIANCE AUDIT WHY? Excellent tool to assess your organization s Process Safety effectiveness written program and implementation Assess compliance; benchmark performance with industry Identify and mitigate early warning signs before a potential incident Integral to PLAN DO CHECK ACT cycle of continuous improvement Meticulous verification required to preserve License-to-Operate, which is a privilege, not a right

24 PSM AUDITING COMMON DEFICIENCIES

25 Common Deficiencies BASIS 350+ audits / assessments performed Large, major OPCOs to smaller, niche specialty chemical companies and industries Variety of industries: Oil & Gas Petroleum Refining Gas Processing Petrochemicals Chemicals Pharmaceuticals NH3

26 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.

27 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)

28 RACI MATRIX Role PSM Activity COO HSSE Engineering & Construction Operations PSM Supervisor Operators Maintenance All Employees Contractors Applicability - (a) A R C C C I I I I Employee Participation - (c) C C I A R I I I I Process Safety Information - (d) I C R/A C C I I I i Process Hazards Analysis - (e) I A I R C I I I I Operating Procedures - (f) I C C A R C I I Training - (g) I C A R C I I I Contractors - (h) A R C C C C C I I Pre-Startup Safety Review - (i) I R C A C C I Mechanical Integrity - (j) I C C R/A C C C Hot Work Permit - (k) A R C C C C I I Management of Change - (l) A C I R C C C I Incident Investigation - (m) A R I C C C I I Emergency Preparedness & Response - (n) A R C C I I I Compliance Audits - (o) A R C C C I I I I Trade Secrets - (p) A C C R C C i I I

29 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., PI RP520/520 RV sizing contingency analysis )

30 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 ).

31 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

32 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

33 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

34 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.

35 Common Deficiencies PROCESS HAZARDS ANALYSIS Failure to address FACILITY SITING issues. Failure to address HUMAN FACTORS issues.

36 Common Deficiencies PROCESS HAZARDS ANALYSIS Failure to address FACILITY SITING issues. Failure to address HUMAN FACTORS issues. USE INDUSTRY-STANDARD CHECKLISTS!!!

37 Common Deficiencies PROCESS HAZARDS ANALYSIS Previous incidents, including near misses, not considered by the PHA team. Overdue PHA recommendations with no managed schedule for resolution, completion. Incomplete compilation of Process Safety Information prior to performing the PHA.

38 Common Deficiencies OPERATING PROCEDURES SOPs not written for ALL phases of operation (esp., non-routine operations, e.g., purging, cleaning, sampling, emergency operations, etc.) Safe operating limits and consequences of deviation from these limits not well-defined. Steps to correct/avoid deviations not documented. No written procedures for Shift Change / Handover operations. Procedures not reviewed often enough for accuracy; lack of annual certification.

39 Common Deficiencies SAFE WORK PRACTICES No documented Equipment-specific procedures for LOTO, Confined Space. Lack of periodic training for LOTO, Confined Space

40 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.

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

42 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

43 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

44 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

45 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.

46 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.

47 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

48 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.

49 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 (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)

50 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.

51 Common Deficiencies EMERGENCY PREPAREDNESS & RESPONSE Emergency action plan not up-to-date. Emergency evacuation maps with routes and safe distances not posted. No written process for testing and servicing plant alarms; no documentation that alarm testing was completed Lack of documented drills and exercises Lack of coordination of EAP with local community, responders.

52 Common Deficiencies COMPLIANCE AUDITS Compliance audits performed; but not certified in writing. Audits incomplete. Audit action items not tracked or completed in a timely manner.

53 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 %

54 Common Deficiencies OSHA REFINERY NEP ENFORCEMENT STATISTICS Emergency Planning and Response 17 Employee Participation 15 Pre-Startup Safety Review 13 Hot Work Permits 8 Trade Secrets 0 Total PSM Citations 1088

55 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 %

56 Common Deficiencies CHEMICAL NEP PSM ENFORCEMENT STATISTICS Contractors 14 Emergency Planning and Response 7 Pre-Startup Safety Review 5 Hot Work Permits 1 Trade Secrets 0 Total PSM Citations 678

57 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

58 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.

59 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.]

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61 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.

62 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.

63 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.

64 AUDIT & CONTINOUS IMPROVEMENT Company must establish and implement an efficient and effective system to periodically audit and continuously improve process safety performance relative to regulatory requirement and international peers. Plan-Do-Check-Act Documentation Documentation Documentation

65 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.

66 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.

67 GRACIAS! Houston Bogota Singapore

68 PSRG OVERVIEW Established, 1997 (Houston) Member: ARPEL, CCPS More than 80 professionals worldwide averaging 28+ years experience Diverse industry experience on 1,000+ projects with more than 750 customers in 76 countries Hands-on plant operations experience Single source, one stop shop for comprehensive PSM/RMP, and HSSE consulting and training services Tailored solutions to meet and exceed customer expectations Highly qualified resources enable customers to receive value that far exceeds cost of our services