Kp bloch psm preparedness final rev

Process Safety Management

(PSM) Preparedness

changes to expect and how they

affect you

Kenneth P. Bloch

processreliability@gmail.com

Sr. HES Professional in Process Safety

Houston, Texas USA

Personal Background

• Kenneth Bloch – BS Lamar University 1988

– 30 years experience investigating industrial incidents and process / mechanical failures

• Specialty & commodity chemical processes

• Downstream oil & gas / petrochemical

– Reliability & maintenance, process safety, & operations roles in 2 major petroleum refineries

– Lessons learned & hazard mitigation speaker (API, AFPM, AIChE/CCPS)

– Author of Rethinking Bhopal (Elsevier, June 2016) ISBN 978-0128037782

Topic Overview

• The push for PSM reform – Industry performance review

– The call for action

– Change overview

• Significant developments in PSM’s growth – The Bhopal disaster (1984)

– The PSM standard (1992)

– Event order reversal analysis (2016)

• PSM’s future success – What does it require of you?

– Application summary

– Questions & answers

What you will learn

• How to prevent future disasters and minor precursor incidents.

• Why reputable organizations are more likely to incur a catastrophic event.

• What must be done to maintain effective PSM performance when regulatory requirements change.

• How to achieve satisfactory PSM performance before new regulations go into effect.

Part 1

The push for PSM reform

March 23, 2015

A. The 20-year anniversary of industry’s

cooperative effort to eliminate

catastrophic process incidents?

B. A devastating fire and explosion

occurred at a major USA refinery?

A. CCPS’ 20-year Anniversary

2016 CCPS Annual Report - AIChE

B. BP Texas City Refinery

(March 23, 2005)

Photo: CSB

BP Texas City Refinery

Summary

• Catastrophic loss of primary

containment (LOPC)

• Raffinate (naphtha-range) Tower overfill

• 15 fatalities & 180 injuries

• Mechanical integrity, facility siting, and

organizational culture defects

• Mogford Report

• CSB Report

• Baker Panel Report

BP Deepwater Horizon

(April 20, 2010)

Photo: CSB

BP Deepwater Horizon

Summary

• Catastrophic loss of primary containment (LOPC)

• Crude oil spill over 4 million barrels into the Gulf of Mexico

• 11 fatalities, 17 injuries, and serious environmental damage

• Economic damage to multiple adjunct industries

• Mechanical integrity, human error, and organizational culture issues

• Presidential-appointed committee report

• CSB Report

PDVSA Amuay Refinery

(August 25, 2012)

Photo: REUTERS/Hector Silva

PDVSA Amuay Refinery

Summary

• Catastrophic loss of primary

containment (LOPC)

• Propane leak from process pump

• 48 fatalities, 151 injuries

• Mechanical integrity, hazard

awareness, and facility siting defects

West Fertilizer Company

(April 17, 2013)

Photo: Reuters

West Fertilizer Company

Summary

• Fire and explosion

• Detonation of 40 to 60 tons of ammonium nitrate

• 15 fatalities & more than 260 injuries

• Property damage to more than 150 offsite buildings

• Loss of operating license (the company went out of business)

• Hazard awareness, emergency response and planning, and facility siting defects

• CSB Report

DuPont Mercaptan Release

(November 15, 2014)

Photo: CSB

DuPont Mercaptan Release

Summary

• Catastrophic loss of primary containment (LOPC)

• 24,000 pounds of toxic gas released

• 4 fatalities due to asphyxia and acute exposure to toxic chemicals

• Process shut down permanently [1]

• Mechanical integrity, operating procedures, and safety equipment defects (CSB)

• Human error (DuPont Report) [1]

Pemex Petrochemical, Veracruz

(April 20, 2016)

Photo: Getty

Pemex Petrochemical, Veracruz

Summary

• Catastrophic loss of primary

containment (LOPC)

• Vinyl chloride (plastic) plant

• 32 fatalities & 160+ injuries

• More information expected in the future.

Performance Summary

• PSM events are a global concern – Domestic (USA) and international incidents

– Major event frequency of 1.77 years in manufacturing industry’s last 40 years [2]

• Major incidents have damaged the reputation of companies once recognized for PSM superiority (BP, DuPont [1]).

• Mechanical integrity (including maintenance), facility siting, and cultural defects are found in most tragic industrial incidents.

• A bad enough incident can drive a manufacturing enterprise out of business.

Executive Order (EO) 13650

CSB “Most Wanted”

Timeline

Significant Changes Underway

(Cal/OSHA) [3]

• Process Hazard Analysis (PHA) / Safeguard Protection Analysis (SPA) – SPA is a new element used to gauge the

independence and effectiveness of safeguards against failure scenarios evaluated during a PHA.

• Management of Change (MOC) – New requirement to apply a Hazard Control Analysis

(HCA) prior to implementing a major change.

• Process Safety Management Program (PSMP) – An entirely new PSM element directed at stop work

authorization and criteria for rejecting recommendations.

Significant Changes Underway

(Cal/OSHA) cont’d [3]

• Mechanical Integrity (MI) / Damage Mechanism Review (DMR) – DMR is a new element that utilizes a broad team to

identify any deficiencies associated with damage mechanisms that could degrade equipment or material performance.

• Inherently Safer Technology (IST), Hierarchy of Hazard Control Analysis (HCA), and Safer Technology and Alternatives Analysis (STAA) – New processes for prioritizing hazard mitigation with

the preferred practice of eliminating or minimizing the hazard before resorting to less effective, more human-dependent measures.

Significant Changes Underway

(Cal/OSHA) cont’d [3]

• Process Safety Culture Assessment (PSCA) – A new PSM element related to assessing

cultural safety practices at a production site.

• Human Factors (HF) – A new PSM element that requires assessing

how the complexity of tasks, employee training and skills requirement, human-machine interface design, physical process demands, and the impact of shift work will affect human performance.

Changes also apply to . . . [3]

• Process safety information (PSI)

• Training

• Contractors

• Pre-startup safety review (PSSR)

• Hot work

• Employee participation

• Operating procedures

• Incident investigation – root cause analysis

• Emergency planning & response

• Management of organizational change (MOOC)

More Widespread Action is

Expected

What to Expect

• Mandatory PSM/RMP changes (USA) based on changes in progress (Cal/OSHA)

• Indoctrination of similar practices by EU and APAC, due to networking of best practices by NGOs (CCPS, IChemE, API, AFPM, etc.)

• Additional regulatory requirements without de-emphasizing standing requirements.

• More complex Safety Management Systems (SMS) – Prescriptive tasks

– Reporting commitments

– Industrial accountability

Balancing

compliance with complexity

“. . . a complex SMS Regulatory

Environment can create implementation

challenges for not only industry, but also

for regulators providing oversight. It is an

important objective for regulators to

always minimize unnecessary complexity,

because unnecessary complexity can

erode some of the safety benefits desired

from the promulgation of Modernized

PSM/RMP regulations.” [3]

Regulatory Growth

Relevant questions

• How can I prevent counterproductive results from the impending regulatory changes?

• What must I do to reduce the potential for a process release where I work?

[4]

Part 2

Significant developments in

PSM’s growth

The PSM Movement’s

Development

• Catastrophic loss of primary containment (LOPC)

• 28 tons of toxic gas emitted into the atmosphere

• > 3000 fatalities; > 200,000 injuries

• Residual mortality and environmental impact

• Mechanical integrity, hazard awareness, emergency

response and planning, and facility siting defects

• Organizational culture defects

• Destruction of a successful manufacturing

enterprise

Event order reversal analysis

December 1984 – Catastrophic LOPC incident, Union Carbide India Limited

February 1992 – 29 CFR 1910.119 (PSM Standard USA)

What should we

be doing?

Part 3

PSM’s future success

1. Make no distinction between

internal and external compliance

REGULATORY, VISIBLE TO ALL

• MOC, deviation process, waivers & exceptions, deferrals

• Specifications

• Standards

• Procedures

• Policies

• Asset reliability

• Action items

• Operating limits

• Site auditing

• Disciplinary program

• Management systems

• Administrative controls

?

External Compliance

(Mandatory)

Internal Compliance

(Discretionary)

2. Expand your definition of

mechanical integrity

• Establish and insist on meeting asset performance targets – Reliability limits (pressure, temperature, flow, level,

composition, etc.)

– Failure performance (MTBF & life expectancy)

– Investigate deviations

• Understand the concept behind “Inherently Safer Technology.” – “Safety is built into the process or product, not

added on. Hazards are eliminated or significantly reduced, not controlled, and the way they are eliminated or reduced is fundamental to the design that it cannot be changed or defeated without changing the process. In many cases this will result in simpler and cheaper plants.” [5]

3. Understand what “double

jeopardy” means

• Most failure scenarios are much less

rare than you think.

• All simultaneous failures must be

revealed for double jeopardy to apply.

• Common-cause failures tend to be

hidden and make double jeopardy

scenarios highly probable.

4. Do not replace an incident

investigation with an MOC

• Reject workaround solutions.

• Generate recommendations that

preserve the process’ original design

basis.

• Investigate production constraints as

process safety defects.

• Avoid using consequence thresholds as

investigation triggers.

5. Know what your line

organization is doing.

• How is the work getting done?

• Is tribal knowledge creating the false

impression of a reliable process?

• Does “employee participation” focus

around hazard awareness & control or

employee relations?

What is wrong with this picture?

How many people did it take

for this to happen?

6. Clarify Teamwork

Expectations

Stop Work Authorization (card, policy, etc.)

? Internal

(Hidden)

• Line organization’s

courage and PSM

commitment

• Supervision’s visibility

& consistency

External

(Visible)

Teamwork requires going

against the team.

Get the Book

(ISBN 9780128037782)

• Discuss its contents with the line

organization.

• How do they respond under similar

circumstances?

• What they say might surprise you.

• Your success depends on what you know.

• Take steps now to stabilize PSM.

• On sale now for preorder at Elsevier

bookstore and Amazon.

• Expected release date June 6, 2016.

• All royalties go to the “Process Safety

Heritage Trust” science and engineering

scholarship

Application Summary

Action Step: 1 2 3 4 5 6

Process Hazard Analysis (PHA) / Safeguard Protection Analysis (SPA) X X

Management of Change (MOC) X X X X X

Process Safety Management Program (PSMP) X X X X

Mechanical Integrity (MI) / Damage Mechanism Review (DMR) X X X X X

Inherently Safer Technology (IST), Hierarchy of Hazard Control Analysis

(HCA), and Safer Technology and Alternatives Analysis (STAA) X X X

Process Safety Culture Assessment (PSCA) X X X X X

Human Factors (HF) X X X X X X

For More Information

1. Kenneth Bloch, Rethinking Bhopal: a definitive guide to investigating,

preventing, and learning from industrial disasters, 2016.

2. Steven Maher, Aleksandar Metulev, PSM/RMP Modernization

Programs in California (New Developments and Correlation to

Evolution at the Federal Level), 2016 Spring Meeting and 12th Global

Congress on Process Safety, Houston, Texas (USA), April 10-14,

2016. http://www.rmpcorp.com/sms_regulatory_updates/

3. J. Wayne Chastain, Stanley Urbanik, Robert Johnson, John Murphy,

New CCPS Guideline Book: Guidelines for Enabling Conditions and

Conditional Modifiers in LOPA, 2013 Spring Meeting and 9th Global

Congress on Process Safety, San Antonio, TX, April 28 – May 1, 2013.

4. Dennis Hendershot, Inherently Safer Design: The Fundamentals,

Chemical Engineering Progress, 108 (1), 40, 2012.

5. Trish Kerin, Improving learning through interactive case studies, 2016

Spring Meeting and 12th Global Congress on Process Safety,

Houston, Texas (USA), April 10-14, 2016.

References

Mark Collette, DuPont's La Porte plant, site of worker deaths, won't reopen, Houston Chronicle, March 31, 2016.

Chason Coelho, Addressing Human Factors in Process Safety – Corporate and Plant Practices, 2016 Spring Meeting and 12th Global Congress on Process Safety, Houston, Texas (USA), April 10-14, 2016.

Steven Maher, Aleksandar Metulev, PSM/RMP Modernization Programs in California (New Developments and Correlation to Evolution at the Federal Level), 2016 Spring Meeting and 12th Global Congress on Process Safety, Houston, Texas (USA), April 10-14, 2016.

Daniel Crowl, Joseph Louvar, Chemical Process Safety: Fundamentals with Applications, Second Edition, 69, 2002.

Dennis Hendershot, Inherently Safer Design: The Fundamentals, Chemical Engineering Progress, 108 (1), 40, 2012.

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