Against a background of well documented tragedies, Katherine McCarthy argues the case for establishing meticulous process safety management systems.
In 1984, the release of methyl Isocyanates (MIC) from a gas leak at a pesticide plant caused the Bhopal gas tragedy in India, exposing more than 500,000 people to harmful chemicals and resulting in more than 2,000 deaths.
In 1974, 28 workers were killed and 36 workers suffered from serious injuries at the Flixborough disaster in England, when a pipe leaked cyclohexane, causing an explosion.
More recently in 2010, 11 workers were killed at the Deepwater Horizon explosion in the Gulf of Mexico, and in 2005, 15 workers died and more than 170 workers were injured at the BP Texas City refinery disaster, also just off the coast of the United States.
Hundreds more have been injured or killed at refineries, on rigs, and in other oil and gas facilities over the past several years all over the world.
The unexpected release of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years in various industries that use chemicals with such properties. Regardless of the industry that uses them, there is a potential for an accidental release any time they are not properly controlled, creating the possibility for disaster.
These major, memorable accidents and the severity of their impact on not only the stakeholders within the oil and gas industry, but the people and communities directly involved, have prompted much attention towards process safety management systems (PSM), not only oil and gas activities, but in other process industries as well.
Process Safety Management
In the United States, Process Safety Management is regulated by the Occupational Safety and Health Administration (OSHA) through the Process Safety Management (PSM) Standard, 29 CFR 1910.119, entitled Process Safety Management of Highly Hazardous Chemicals. PSM is a regulation enforced in the United States. It applies to companies that handle any of more than 130 specific toxic and reactive chemicals, including specific quantities of flammable liquids and gases in a covered process.
The standard is divided into 14 elements that are interlinked and interdependent, and the basic objective is to prevent an unwanted release of highly hazardous chemicals by effectively managing the people, technology, and equipment that make up the process.
PSM targets highly hazardous chemicals that have the potential to cause a catastrophic incident, although it is not a regulation that applies directly to oil or gas well drilling or servicing operations. It is encouraged and recommended for safety purposes and to ensure that proper procedures are being used.
In the United States, the American Petroleum Institute (API), which is the trade association representing the oil and natural gas industry, writes recommended safety practises for the industry to voluntarily adopt, but this is not the same as the PSM standard.
The application of process safety management has been steered by organisations like the American Institute of Chemical Engineers and the Center for Process Safety as a management system to manage hazardous processes, raising the question of how these standards, if applied directly, would positively affect the oil and gas companies across the globe.
Learning from the past
As a whole, the refining, gas processing, and petrochemical sectors from all over the world have incurred fewer major property damage losses over the past decade, improving worker safety and environmental risks. This decline could be attributed to the fact that the industry has increased its focus on Process Safety Management, with an overall encouraging level of receptiveness to the standard.
Application of risk management processes in the refining industry has been taking place for many years, and today it is evolving to a more systematic uptake across the industry with more sophisticated reporting procedures/processes and analytics now being built into the system. By taking such initiatives to embrace PSM, the refining, gas processing, and petrochemicals communities are able to employ a variety of tools with greater frequency to create a more robust system.
These improvements include: new construction design, predictive and preventive maintenance, and operator training and management of change.
According to one source, PSM components that play a critical role in loss prevention and loss mitigation include:
• A stronger focus on positive materials’ identification
• An increase in the level of corrosion and/or erosion monitoring
• Aggressive management and auditing of the use of temporary clamps
• Heightened focus on the installation of remote emergency isolation valves based on a systematic analysis of where they can have the greatest impact
• More rigorous operator training and competency assessments
• Stricter controls on temporary safety bypasses
Though with a strong worldwide trend, the effectiveness of PSM has not been in place long enough to reach any firm conclusions that could be statistically validated. Some geographic regions, such as the United States, Australia, and the UK, are integrating processes of PSM with reporting and tracking to promote learning from any type of accident.
Although the absence of major losses over the last decade in an area such as the Middle East could be an indication of continued progress of PSM in the oil and gas sector, it is hard to determine due to the lack of available information. The goal here is to look at the past in order to continue to learn how the entire industry, as well as the various governmental regulatory agencies around the world, can benefit in the future.
Effective PSM system
The oil and gas industry has very specific processes that need constant monitoring and regulation, and governmental regulations differ from country to country. Highly toxic and unsafe chemicals are moving through miles and miles of valves and pipes on a daily basis, causing an imperative need for the properties of process safety management. The goal of employing such methods is simple: to abate unsafe practises to prevent disasters, death and destruction. Implementing the processes to reach these goals can be much more complicated – but with the proper process safety management, these goals can be reached.
An effective process safety management programme requires a systematic approach to evaluating the whole chemical process with identification, prevention, and mitigation of risks associated with hazardous chemicals. This becomes especially important when the workplace could be subject to catastrophic consequences if a release of dangerous chemicals should occur, such as in oil and gas companies.
An evaluation can be given at any time and considers the process design, process technology, process changes, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programmes, and other elements that affect the processes at a specific location.
These evaluations then lead to a comprehensive PSM programme, which under the US regulation covers 14 elements that work to integrate technologies, procedures, and management practises with the goal of lowering or eliminating the hazards involved, and ensuring that the process is continually improved upon.
More specifically, in the oil and gas industry, PSM refers to the replacement and maintenance of equipment; having systems in place to ensure that pipes and machinery are in top condition; adequate training for employees; proper staffing so that workers do not get fatigued and make mistakes due to overtime; maintaining adequate records and information on possible hazards to workers; and making sure that changes to a process are recorded and shared with workers.
Implementation and components
As mentioned previously, the US Process Safety Management standard has 14 interrelated elements that work together. Though these processes are based on the OSHA regulation, they are applicable to all organisations looking to implement a PSM programme.
At the top of the list is Employee Participation. Through a written plan of action, employers must detail how employees are involved in the programme, or in other words, their roles and responsibilities. In addition, input from employees is sought concerning the development and implementation of the various elements of PSM.
Process Safety Information (PSI) might be considered the foundation of a PSM programme in that it tells you what you are dealing with from both the equipment and the process standpoint. Information on hazardous chemicals as well as the equipment used in each covered process is gathered and put into written form– all affected employees have access to this information in order to help them identify and understand potential hazards.
One of the most important components of PSM is the Process Hazard Analysis. During this analysis, a qualified team evaluates the various parts of a covered process – equipment, instrumentation, utilities, human actions, and external forces are all closely looked at so that potential hazards can be identified and analysed. Using this information, an action plan is developed that provides recommendations for preventing a catastrophic incident.
Operating Procedures are the written instructions for every step of a process. This includes information that’s needed for routine, day to day operations, such as proper startup, shutdown, operating limits and safety system functions, but also includes the appropriate steps to take if faced with an emergency situation.
When working around hazardous chemicals, such as such as hydrochloric acid and ethylene glycol found at petrol sites, it is essential that all employees receive the appropriate Training. For each job function this training must include information about specific safety and health hazards, emergency operations and safe work practises. Under the regulation, employees must receive refresher training periodically, and information must be updated whenever changes are made to the process to stay current.
Before hiring a Contractor, management must have a screening process in place to ensure that temporary workers can perform their tasks without endangering themselves or others. Because every facility is different, it is also important that management makes sure that contract employees have a clear understanding of the facility’s safe work practises, potential process hazards, and emergency response plan. This is especially important when working in a high hazard industry, regardless of the country of origin.
With expansions projected for oil and gas companies, which are occurring more now than ever before in the Middle East, new facilities are being built. When a facility is new, or when a process has been modified enough to require a change in the process safety information, then a Pre-Startup Safety Review is required. Before any new or modified operation begins, this review is used to confirm that employees have received the necessary training, and that all elements of the Process Hazard Analysis have been properly implemented.
Written procedures are required for maintaining the ongoing Mechanical Integrity of process equipment. As with every element in Process Safety Management, the goal is the same: to prevent a hazardous fire, explosion or accidental release of chemicals. Included in the Mechanical Integrity procedures is information on the training of maintenance personnel, and how to inspect and test equipment. When a piece of equipment is discovered to be deficient beyond the defined safe limits, then it must not be used until the problem has been corrected.
When other hazardous work tasks are necessary, ensure best safety practises are followed. These operations may include hot work, such as welding or cutting, confined space entry, and lockout/tagout procedures for equipment that requires repair. OSHA stipulates that as part of PSM these standards must also be followed to ensure the protection of employees working in and around process areas.
Before modifications are made to procedures, equipment, raw materials or processing conditions, it must be verified that safety will not be adversely affected, using a Management of Change system. An evaluation of the proposed modification is performed to make sure that the overall process will remain within safe operating limits. Once the change is approved, updating the Process Safety Information and providing appropriate training for employees is also required.
When an incident either does, or could have, resulted in the release of hazardous chemicals, an Incident Investigation takes place. An investigative team, with knowledge of the process involved, looks for the factors that contributed to the incident. The team’s goal is to determine the accident’s underlying cause, so that corrective measures can be implemented and similar releases can be avoided in the future.
Every facility that uses hazardous chemicals for the various channels and operations of oil and gas needs must have a written Emergency Action Plan. This document provides employees and emergency personnel with a planned out response should an accidental chemical release occur.
Employees assigned the task of handling small releases of hazardous chemicals must be trained in the safe work practises and procedures of cleanup and disposal. If a major incident occurs, outside emergency response assistance may be required. For this reason it is important to communicate with these hazardous response teams in advance so that they are aware of the hazardous chemicals used at the facility.
Under the US regulation, at least once every three years, a Compliance Audit is necessary to evaluate the design and effectiveness of the Process Management System. This audit includes a review of the process safety information, an inspection of the process equipment, and interviews with plant personnel. One of the most important aspects of the audit is follow-up on any recommended corrective actions.
Employers cannot withhold any information that would prevent personnel from complying with the Process Safety Management programme – even if this information reveals a Trade Secret. Before supplying sensitive information, however, companies are able to protect their trade secrets by requiring that individuals enter into a confidentiality agreement.
Safety in process
When discussing the major accidents that have occurred within the oil and gas industry, one question consistently comes to mind – what went wrong? In response, it can be said that their occurrences are connected to issues concerning PSM systems.
Why? Mostly because modern oil and gas processing facilities have become increasingly more complex – and so have the risks in managing greater capacity refineries. Though Process Safety Management is not a regulation that applies directly to oil or gas well drilling or servicing operations, it is highly encouraged to implement these procedures into your company’s safety programme to ensure the safety of employees, the environment, and physical plant assets in the event of an unexpected process excursion. Its merit goes beyond the prevention of accidents to increase productivity, quality improvement, waste, and cost reduction – and to save lives.
The development of new techniques and technologies designed to improve operational safety has evolved to meet the challenges of the ever changing safety landscape of oil and gas companies. Operating companies are increasing efforts to reduce the risk of catastrophic events such as the release of toxic, reactive or explosive chemicals that can damage the environment or plant assets, as well as cause injury or death to employees and the general public.
Published: 22nd Jul 2013 in Health and Safety Middle East