Tools for Process Safety for Upstream and Offshore Applications. Authors: Robert J. Weber, P.E. Sonny Sachdeva, PhD Date: 03-May-2016

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1 Tools for Process Safety for Upstream and Offshore Applications Authors: Robert J. Weber, P.E. Sonny Sachdeva, PhD Date: 03-May-2016

2 22 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 [ ]

3 3 Elements of SEMS 33 CFR General 10. Emergency Response and Control 2. Safety and Environmental Information 3. Hazard Analysis 12. Auditing 11. Investigation of Incidents 4. Management of Change 13. Record keeping 5. Operating Procedures 14. Stop Work Authority 6. Safe Work Practices 15. Ultimate Work Authority 7. Training 16. Employee Participation Plan 8. Mechanical Integrity 17. Reporting unsafe working conditions 9. Pre-startup Safety Review

4 4 SEMS Elements in common with OSHA PSM Element SEMS (33CFR250) PSM (29CFR ) 1. Safety and Environmental Information Minimally Different 2. Hazard Analysis Update HA after every internal audit SEMS has additional requirements of JSA at operation/task level the results of the JSA in writing and must ensure that records are kept onsite for 30 days must retain JSA records for 2 years 3. Management of Change SEMS has additional requirements for Personnel changes (including contractors) Records must be maintained for 2 years Initial and revalidation every 5 years MOC required for changes to technology, equipment, procedures

5 5 SEM Elements in common with OSHA PSM Element SEMS (33CFR250) PSM (29CFR ) 4. Operating Procedures 5. Employee Participation Plan SOPs must be reviewed at the conclusion of specified periods and as often as necessary to assure they reflect current Operating modes associated with bypassing and flagging out-of-service equipment Operating procedures to include impacts to the human and marine environment identified through hazards analysis Review of and changes to the procedures must be documented and communicated to responsible personnel Minimally Different The employer shall certify annually that these operating procedures are current and accurate.

6 6 SEM Elements in common with OSHA PSM Element SEMS (33CFR250) PSM (29CFR ) 6. Training Periodic training to maintain understanding of, and adherence to, the current operating procedures, using periodic drills Must document your instructors' qualifications Communication requirements 7. Mechanical Integrity Minimally different 8. Pre-startup Safety Review Minimally different Initial and refresher training every 3 years

7 7 SEM Elements in common with OSHA PSM Element SEMS (33CFR250) PSM (29CFR ) 9. Emergency Response and Control 10. Investigation of Incidents Minimally different Incident investigations must be initiated as promptly as possible Retain the findings of investigations for use in the next hazard analysis update or audit; A corrective action program must be established based on the findings to analyze incidents for common root causes Incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. Incident investigation reports shall be retained for five years

8 8 SEM Elements in common with OSHA PSM Element SSEMS (33CFR250) PSM (29CFR ) 11. Contractors/Safe work practices You must ensure that contractors have their own written safe work practices Maintain a contractor employee injury and illness log for 2 years related to the contractor's work in the operation area, and include this information on Form BSEE The employer shall maintain a contract employee injury and illness log related to the contractor's work in process areas

9 SEM Elements in common with OSHA PSM Element SEMS (33CFR250) PSM (29CFR ) 12. Auditing SEMS program must be audited by an accredited ASP Audit team lead must be an employee, representative, or agent of the ASP, and must not have any affiliation with the operator. Audit plan to include ASP qualifications must also identify safety and environmental performance deficiencies Must submit your written Audit Plan to BSEE at least 30 days before the audit Audit Frequency must not exceed 3 years after the 2-year time period for the first audit Must submit an audit report of the audit findings, observations, deficiencies identified, and conclusions to BSEE within 60 days of the audit completion date. 9 Audit shall be conducted every 3 years Two recent audits shall be retained

10 10 How can SEMS learn from PSM Lessons learned from 24+ years of experience of OSHA PSM w (29CFR ) OSHA PSM being a mature system can be said as more prescriptive (because it has developed over past 24 years) compared to SEMS which is more performance based (this provides room for adopting new standards). SEMS can learn from PSM experience (for e.g., PSI: using relief system design experience from downstream to upstream facilities) SEMS can benefit from lessons learned through downstream CSB incident investigations OSHA PSM quality verification has been done through OSHA NEP programs which identify major elements for citations/violations

11 11 11 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 %

12 12 12 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

13 13 13 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 %

14 14 14 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

15 15 Future Direction of SEMS Focus on developing a culture of safety Use of leading and lagging indicators to measure management system gaps and effectiveness Focus on Human factors using both qualitative and quantitative models Focus on active barrier management, measurement and maintenance. Develop an audit protocol that measures effectiveness of management system rather than compliance Drive continuous improvement in offshore safety and environmental records

16 16 Thank you!