Many industrial processes involve the use of hazardous chemicals. These may be toxic, flammable, reactive or explosive. They may be produced in the core process itself or found in supporting infrastructure, for example, ammonia used in refrigeration plants. Hazardous chemicals are to be found in chemicals manufacturing and mining, oil & gas, pharmaceuticals, and many other industries.

During the life-cycle of the plant, steps are taken to minimise the probability of releasing these chemicals into the environment and limiting the consequences of such a release. During the conceptual design stage, the emphasis is on the inherent safety of the process. During detailed design, the focus is on engineering the plant for safe operation. And during operation, the emphasis is on procedural safety to ensure that people are competent to do the work, procedures are complied with, and appropriate precautions are in place for work on the plant. Above all, a safety culture and one of continuous improvement and learning is vital.

Safety Management Systems

Safety management systems have been developed and improved over the years. These systems are designed for entire industries by standards bodies, industry organisations or regulators. A safety management system is a systematic approach that needs to address the safety policies and related procedures and accountabilities. A safety management system will also address training, competencies, monitoring, supervision and reporting requirements. These systems differ slightly between countries to accommodate legislation and local factors but are all based on the same underlying principles.

Process Safety Management (PSM) was introduced by OHSA (Occupational Health & Safety Administration). PSM is regulated in the United States. However, the principles have been widely adopted in other countries where there are different legal frameworks.

The PSM standard comprises fourteen requirements for process safety.  Although oil/gas well drilling is excluded from the scope, the application is broad and will apply to most manufacturing processes.

Elements of Process Safety Management

The fourteen PSM requirements are applicable across the plant’s life-cycle; however, the emphasis is on the operating phase of the plant, which can be 25 years or longer. While the standard is published in the form of a prescriptive set of regulations, it nevertheless incorporates several best practices for good and effective safety management in a plant or factory.

The 14 elements are summarised below:

1. Process safety information – documentation needs to be in place about hazards, highly hazardous chemicals, technology/process information and detailed equipment information.

2. Employee Involvement – develop a plan for employee participation and employee inclusion in the development of process safety plans.

3. Process Hazard Analysis – needs to be conducted for each application and updated/revalidated every five years. Documentation needs to be maintained over the life-cycle of the plant.

4. Operating Procedures – written procedures need to provide clear instructions that cover the safety aspects of work. These procedures need to cover operating limits, safety/health considerations and functions. They need to be available and accessible to all employees who work on a potentially hazardous process. They need to be reviewed and updated to reflect current operating practice. Operating procedures also need to consider exceptional circumstances such as energy isolation and dangerous activities such as confined space entry.

5. Training – employees operating a potentially hazardous process need to be trained in the operation thereof, and their competence (required skills and knowledge) need to be certified before work takes place.

6. Contractors – there needs to be clear identification of the different responsibilities of site work employer and contractors involved in short term assignments such as maintenance, turnaround, renovation or speciality work. The PSM standard covers responsibility for training and the steps needed to ensure that contractors know the job’s hazards and all related safety and emergency action plans.

7. Pre-startup safety review – the PSM standard requires a safety review for all new facilities to confirm that the plant and equipment “as-built” conforms to all design specifications and incorporates all safety precautions in line with the hazard analysis. When plant modifications are made, management of change needs to be done and include its safety aspects.

8. Mechanical integrity – The on-site employer needs to implement written procedures for the process equipment’s ongoing integrity.

9. Hot work – work on or near a potentially hazardous (“covered”) process needs to be executed under a special hot-work permit.

10. Management of change – The work-site employer needs to implement written procedures that control all change to processes and process equipment. Employees must be informed about the change, trained as appropriate, and all pre-startup checks must be completed, including updating the process hazard analysis.

11. Incident investigation – Employers need to have a system to record incidents and follow these up in a short time frame to ensure that a competent investigation takes place that produces a written report on the incident.

12. Emergency Planning and Response – employers are required to develop and implement an energy action plan for any incident involving releases of hazardous chemicals.

13. Compliance audits – Employers are required to evaluate and certify their compliance with process safety requirements every three years. Deficiencies need to be corrected.

14. Trade Secrets – Covers the situation where PSM requires employees to access trade secrets – typically covered through confidentiality and non-disclosure agreements.

The fourteen elements above cover many of the components of a complete safety management system. However, PSM focuses principally on containing hazardous materials and does not cover all aspects of safety management.  The full implementation of PSM may prove quite challenging in practice, especially as all the elements are interlinked.

Success Factors for Safety Management Systems

There are several pitfalls that in practice can limit the effectiveness of a PSM implementation, for example:

• Not allocating sufficient resources to the implementation. OSHA recommends that companies allocate approximately 3% of gross revenue to implementing the PSM standard.
• Inadequate training and poorly implemented competency assessments. The belief that training will solve all safety issues is flawed because training can usually only address a limited number of theoretical or simulated situations, and people’s behaviour in a real-world situation is sometimes unpredictable.
• Information from the engineering and design is not carried through into operating procedures. This results from poor information transfer from the design phase to operational readiness and into the production phase. Often libraries of design documents are theoretically available but seldom referred to, especially after a few years post-commissioning.
• Overlapping safety management standards. The principles of PSM should dovetail into other safety management standards such as ISO 45001. However, it is crucial when multiple standards are in place that the overlaps and interfaces are carefully considered so that there is no ambiguity.

Adapt IT Manufacturing has developed a range of software applications that cover many aspects of process safety management (and safety management systems in general). These solutions map to specific PSM requirements. Together, Adapt IT’s IntelliPERMIT and OpSUITE solutions leverage a common framework to achieve more with your safety management programme.

For more information on how OpSUITE can help you better manage your process safety please contact the team at Adapt IT.