OSHA Process Safety Management Research Articles

Under investigation; wanted, missing Risk‐Based Process Safety elements

AbstractWhen the 20 elements of CCPS Risk‐Based Process Safety (RBPS) were published in 2007, they represented a major improvement in risk management over the 14 elements of the OSHA Process Safety Management (PSM) regulation. Not only were several additional elements added, but the scope of many of those elements common with OSHA PSM was broadened. The author has successfully applied RBPS to facilities in countries that do not have process safety regulations and to industries in the United States that are not covered by OSHA PSM (Broadribb, 2020). The author has also previously presented a paper on additional elements that could broaden the scope of RBPS further to promote and drive greater risk reduction where appropriate (Broadribb, 2017). Audits of worldwide facility incident investigations have found quite often that symptoms and events were mistakenly identified as the root cause(s). This failure to identify the true underlying root causes often results in recommendations that are unlikely to prevent the recurrence of the subject incident. To assist companies in correctly identifying the underlying root causes, the author has developed a root cause analysis (RCA) technique that not only systematically drives the RCA to the fundamental, underlying management system weaknesses but also covers occupational safety, health, and environment; the 20 elements of RBPS; and some of the additional elements from the author's previous paper (such as human factors and engineering project phases). This paper describes the issues and solutions in detail with examples illustrated from the RCA technique.

Assessment on process safety management implementation maturity among major hazard installations in Malaysia

Despite the widespread process safety management (PSM) implementation among major hazard installations (MHI) in Malaysia, an assessment on current PSM implementation maturity had never been conducted. This study aims to provide such assessment, through the utilisation of PSM elements under the OSHA PSM standard. The study first involved the measurement of PSM implementation achievement grades as well as, the development of PSM implementation related process safety maturity model and process safety assessment rubrics. Both the achievement grades and maturity model were then utilised for the assessment on PSM implementation maturity among MHI in Malaysia. Suitable recommendations for improvements in effectiveness of PSM implementation were finally proposed with reference to the assessment rubrics. From the individual PSM elements implementation assessment results, the Pre-Startup Safety Review element registered the highest representative percentage of 24 %, of MHI in Malaysia having PSM implementation maturity below the predefined acceptable maturity levels. From the overall PSM implementation assessment results, it was found that a representative percentage of 40 % of MHI in Malaysia displayed PSM implementation maturity below the similar predefined acceptable maturity levels. However, the study emphasised that future improvements to the PSM implementation maturity could be achieved through the implementation of the proposed recommendations.

Minimizing Audit Findings by increasing Operational Discipline and Process Safety Culture

Many major accidents have taken place in the chemical and petrochemical industry over the past 40 years (e.g. Bhopal (India, 1984), Texas City (USA, 2005)), which have been key driving forces for issuing new regulations (governments), publishing standards (industry groups), developing policies (companies), and ultimately for improving Loss Prevention strategies and Process Safety Management (PSM). On this context, a key standard is the OSHA PSM (29 CFR 1910.119), a process-based program aiming at preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.The present paper focuses on the results from several PSM audits performed between 2010 and 2016, at several different Chemical Process Industry (CPI) facilities. On the one hand, we have evaluated how well these facilities complied with the requirements of the OSHA PSM Standard. On the other hand, the data from the audit findings has been compiled and statistically processed in order to compare the main common findings with the results of those analyzed by OSHA's Refinery and Chemical National Emphasis Programs (NEP) in 2012.Key audit findings from the CPI are a valued source of information for understanding current safety weaknesses. The lessons learned from this study help us to identify operational discipline and process safety leadership and culture benefits towards minimizing or avoiding audit findings, and therefore, to contributing to an optimized and sustainable Process Safety management system.

Compliance tracking system for training element of OSHA process safety management

Studies show that many accidents have happened in process industries such as in chemical plants that have taken many peoples’ lives. One of the contributing factors of such accidents happening is because of inadequate training provided to employees in particular operational training. One of the established standards highlighting this issue is the training element of OSHA Process Safety Management 29 CFR1910.119(g). Apparently the demand for effective ways to implement Process Safety Management (PSM) is on the rise. Basically the efficiency of standard implementation programme process mostly depends on the systematic framework, which means that all the requirements must be considered, ensuring continuity and completing the implementation process. This paper presents a system to track the performance of PSM training programme based on compliance percentage. Furthermore, the system helps process industries to manage and track information, documentations and required actions regarding the PSM training programme in systematic manner. Besides, it also provides a basis for gap analysis to be carried out for programme improvement. Implementation of this system could serve as a lagging indicator for improvement and to ensure the desired competency of plant personnel.

Managing Employee Participation based on OSHA’s Process Safety Management Requirements

A report published on 25 April 2016 stated that OSHA has issued 14 serious violations after an investigation conducted in a variety of industries including manufacturing, water treatment and oil and gas that violated OSHA's Process Safety Management (PSM) standard. One of the violations is related to the 29 CFR 1910.119(c)(2) which is employers did not consult with employees and their representatives on the conduct and development of the OSHA’s PSM elements which are process safety information (PSI), process hazard analyses (PHA), training (TNG), mechanical integrity (MI), management of change (MOC), pre-start up safety review (PSSR), contractors (CON), incident investigations (II), emergency planning and response (EPR), compliance audit (CA) and trade secret (TS). 29 CFR1910.119(c)(2) is one of the requirements in the OSHA’s PSM employee participation element. However, companies are still struggling to comply with this regulation due to unclear coverage and the implementation method for achieving compliance. Thus, this paper presents a framework and work-aid tool developed based on OSHA’s PSM 29 CFR 1910.119(c) which are helpful to the industries as they provide structured technique to plan and implement an employee's participation management system to achieve compliance in implementing the OSHA PSM employee participation element.

Interrelations between process safety management elements

OSHA PSM standard has been established with 14 elements that define the management principles to control process hazards and protect the workplace. One of the key factors to the success of Process Safety Management (PSM) implementation is that each element comes as a component in an integrated PSM program. Although various kind of integrated safety management systems have been introduced, direct integration system between PSM elements was not extensively studied due to vague concept on interrelation between PSM elements. This also hampers efforts in designing and developing integrated system for PSM. In this study, the interrelation of critical PSM elements was analyzed based on objectives and information functional of the elements stipulated in OSHA PSM regulations. From the conducted analysis, all the critical elements are interrelated at least with other seven PSM elements. Among the elements, Process Hazard Analysis and Mechanical Integrity were identified to have the highest interrelations comprising of 12 interrelated PSM elements. The developed PSM matrix has systematically showed the interrelation of critical PSM elements that useful for the development of Integrated PSM system. © 2016 American Institute of Chemical Engineers Process Saf Prog 36: 74–80, 2017

Compliance Audit Model for Managing Process Safety in Process Industries

Compliance audit for process safety management (PSM) is a technique to verify that the implementation of the PSM program is in compliance with OSHA standards and to identify potential deficiencies in the PSM program used. However, unavailability of an easy audit techniques hinders the compliances to PSM standards in industries. An audit model is introduced based on OSHA PSM standard to provide a standardize format that utilizes the Piping and Instrumentation Diagram (P&ID) as a basis. A case study based on the training element of OSHA PSM is performed to verify the effectiveness and to ensure the PSM standard compliances. The model is based on Microsoft Access which enables the user to input data, manage and track information. The model is useful to the employee as the weaknesses in the PSM program can be identified and rectified to prevent any major accidents.

Managing process chemicals, technology and equipment information for pilot plant based on Process Safety Management standard

Injuries, accidents or even fatalities while working in pilot plant are reported worldwide. The OSHA Laboratory Standard and Hazard Communication Standard have been used as a guideline to manage safety of laboratories and pilot plant. In spite of the implementation of these standards, incidents which result in injuries and property loss are continuously occurring. The implementation of OSHA Process Safety Management (PSM) Standard in pilot plant is expected to further reduce the risks of accidents. This paper presents a new system for managing process chemicals, technology and equipment information in pilot plant and the concept is developed based on Process Safety Information (PSI) element of PSM 29 CFR 1910.119(d). It provides organized strategies to manage documentations, communicate information, and written program for maintaining, revising and updating related information. Process and Instrumentation Diagram (P&ID) is used as a foundation for data management. Implementation of this system at the CO2 Hydrocarbon Absorption System pilot plant as a case study is examined and discussed.

Managing Process Hazards in Lab-Scale Pilot Plant for Safe Operation

In spite of the OSHA Laboratory and Hazards Communication Standards, incidents which result in injuries and property loss continue to occur in the research and teaching locations. Application of Process Hazard Analysis (PHA) of OSHA Process Safety Management (PSM) to laboratory pilot plant operations has the potential to further reduce risk associated with this location. However, a major challenge is unavailability of the easy and effective system to comply with PHA requirements. This study presents a system to manage the implementation of PHA in pilot plant namely Process Hazards Management for Lab Scale Pilot Plant (PHM-LabPP). It provides organized strategies to manage and track information, documents, recommendations and corrective actions related to the process hazards. Application of PHM-LabPP at High Gravitational Natural Gas pilot plant as a case study is examined and discussed. The implementation of this system could help end users to overcome inadequate of managing and controlling process hazards in pilot plant that had contributed to numbers of accidents.

Has process safety management missed the boat?

AbstractThe US Nuclear Navy has an exceptional record of reactor process safety. In over 50 years of nuclear plant operations with as many as 100 operational reactors, the Nuclear Navy has not had a single loss of life or major environmental accident because of process safety. Compare this to the record of all too frequent serious process safety accidents in industries covered by OSHA's process safety management (PSM) regulation and one may wonder, “What's caused the difference?”Although some may say that comparing a military organization and civilian industrial facilities is impossible, this article compares Rickover's reactor process safety philosophy to the regulations and guidelines applied to industrial PSM to provide readers with potential ideas for improving the implementation of PSM. © 2011 American Institute of Chemical Engineers Process Saf Prog, 2011

How to prevent process accidents

Most professionals agree that the correct application of process safety management (OSHA's Process Safety Management regulation) will prevent major process accidents. Some professionals also agree that the PSM documentation is not enough; a good PSM program must include good communication, delegation, and follow-up. There are also some who emphasize that operational discipline is an essential element of the PSM program. In all cases, however, the teachings do not say how to obtain the desired results. Even when discipline is discussed, the discussions do not specify how this discipline is achieved. Many articles additionally emphasize the importance of having a good safety culture—but they do not say how to achieve it. In general, current articles do not explicitly teach how to develop the necessary PSM program, the discipline, and the culture—to prevent major process accidents. These articles very appropriately stress what needs to be done to prevent major accidents; however, they do not tell you how this is accomplished. This specific article is designed to be a companion article to the cited articles; together they show what is required and how to achieve the desired results to prevent process accidents. © 2011 American Institute of Chemical Engineers Process Saf Prog, 2011.

Complying with OSHA's RNEP, CNEP, and VPP RAGAGEP

The OSHA Refinery National Emphasis Program (RNEP) and OSHA Voluntary Protection Program incorporate specific questions relative to many recognized and generally accepted good engineering practices (RAGAGEP). Many of the same RAGAGEP can be expected to be used in the OSHA Chemicals NEP as well. To comply with OSHA's process safety management (PSM) regulation and improve process safety at their sites, chemical industry personnel should be aware of what RAGAGEP OSHA is recognizing and inspecting against and their key requirements. This article will discuss: (1) OSHA's expectations for compliance with RAGAGEP, including some of the RAGAGEP OSHA references in compliance directives, instructions, and citations, (2) some citations issued by OSHA involving RAGAGEP, and (3) common RAGAGEP compliance issues ABSG Consulting observes when conducting PSM audits and assessments throughout the petrochemical and related industries. © 2011 American Institute of Chemical Engineers Process Saf Prog, 2011

The effectiveness of U.S. OSHA process safety management inspection – A preliminary quantitative evaluation

This study attempted to evaluate the inspection effectiveness of the U.S. OSHA process safety management (PSM) standard using statistical correlation test. A total of 6578 citations of past 1277 OSHA PSM inspections from 1992 to 2006 were quantitatively compared with the findings of the U.S. Chemical Safety and Hazard Investigation Board (CSB) investigations on root and contributing causes of 19 major chemical accidents. Nonparametric Spearman's coefficient of rank correlation tests showed a moderately strong agreement between OSHA PSM inspection citations and CSB findings at p < .01 significant level, and the degree of agreement increased with time. These results suggested that past OSHA PSM inspections had cited the problems that were the accident root causes, and the effectiveness of PSM citations has been improved as more inspections were conducted since the standard promulgation. However, factors such as standard coverage, inspection frequency, inspection resources allocation, and inspection strategy, were critical for effective PSM standard enforcement and implementation. Future studies should include more aspects of PSM citations and CSB accident investigation data for better evaluation of inspection effectiveness. The results may be valuable to the PSM enforcement policy makers.

Management of Change for Laboratories and Pilot Plants

In spite of the U.S. OSHA Laboratory and Hazard Communication Standards, incidents which result in injuries and property loss continue to occur in the research and teaching locations. Application of the Management of Change methods contained in the OSHA Process Safety Standard to laboratory and pilot plant operations has the potential to further reduce the risks associated with these locations. Application of Management of Change from the OSHA Process Safety Management standard to these locations is examined, and the benefits of the approach are discussed.

Improved process safety management and simple metrics

AbstractA Process Safety Management (PSM) system was recently implemented at Gulf Coast Waste Disposal Authority (GCWDA). This approach enabled management of increased process risks. These increased risks were brought about by the introduction of large quantities of oxygen for the processing of chemical waste and the destruction of emissions in Regenerative Thermal Oxidizers. This was a voluntary effort by GCWDA, since they do not fall under the OSHA PSM Standard (29 CFR 1910.119).A tailored PSM system was developed that could comply with the OSHA Standard. This PSM system also included additional elements that are considered improvements on OSHA elements. These additional elements are utilized by some leading U.S. chemical manufacturing companies. These additional elements included Management Commitment, Management Review, Conduct of Operations and Continuous Improvement.Simple metrics were created for selected PSM elements, in order to allow for continuous and proactive management review. These metrics supplemented periodic audits and replaced reliance on the common use of incident statistics.This article will deal with the implementation of the PSM system from both the perspectives of the consultant that assisted in the implementation and the facility management that managed the implementation. The successes and some of the barriers for implementation in a small company will also be discussed, as well as the management success in the year after its implementation. © 2008 American Institute of Chemical Engineers Process Saf Prog, 2008

Improving the effectiveness of process safety management in small companies

AbstractMajor accidents are continuing to injure people, and damage facilities and the environment. About 50% of these accidents are in plants that are covered by process safety management (PSM) and 50% are in smaller plants that are not covered. However, the damage is the same. Clearly the OSHA PSM regulation and recommendations by CSB, CCPS, PSP, etc. are not being used as specified. The objective of this paper is to express an enthusiastic support for these major excellent recommendations and to make a few additional recommendations that should enhance those previously listed. This article describes (a) specifically designed methods to improve the implementation of PSM and the above‐mentioned recommendations and (b) additional plant practices for preventing accidents. The methods and practices presented in this article are especially important for smaller plants; most of the larger companies already have good systems to prevent accidents. However, since many of the large accidents are in PSM‐covered plants, some of these larger plants may also benefit from these additional recommendations.One recommendation is that small companies, although not covered by PSM, should practice the intent of the regulation. At a minimum, companies should develop a document that is at least similar to the PSM documentation. However, this article emphasizes that this documentation is not enough because the management of the requirements is extremely difficult. Companies need to have a system that includes the PSM documents, communication, delegation, and follow‐up to insure that the requirements are practiced as intended.Based on the author's experience, the use of additional plant practices such as an effective management system, internal audits, walk‐the‐line, and checklists will enhance the utilization of PSM. These practices are easy to use and will prevent accidents. More of these methods and practices are needed and should be shared between companies. © 2008 American Institute of Chemical Engineers Process Saf Prog, 2008

Predicting and confirming the effectiveness of systems for managing low‐probability chemical process risks

AbstractThis article addresses the role of a facility's process safety management system (PSMS) in preventing low probability–high consequence (LP–HC) accidents. We review the rationale for the hypothesis that a facility's PSMS is the central driver of accident prevention, and we discuss how this rationale has been incorporated implicitly into the OSHA Process Safety Management standard (PSM) in 1992 and explicitly into both the EU Seveso II Directive and the USA EPA Risk Management Program regulation (RMP) in 1996. We then note that the limited process accident incidence data available to date have not resolved the issue of determining or predicting characteristics of a facility's PSMS that are likely to be effective in reducing LP–HC accidents. Based on a variety of considerations, the authors propose retrospective and prospective case‐control studies on facilities with and without RMP reported process accidents using candidate survey instruments to test which survey factors appear to have the greatest predictive power for the likelihood of future LP–HC accidents. © 2006 American Institute of Chemical Engineers Process Saf Prog, 2006

Management system failures identified in incidents investigated by the U.S. Chemical Safety and Hazard Investigation Board

AbstractA key mission of the US Chemical Safety and Hazard Investigation Board (CSB) is to determine the root causes of incidents, report the findings, and issue recommendations to prevent similar incidents from occurring. CSB investigators respond to a variety of events occurring in a wide range of workplaces, from chemical plants and refineries to food‐flavoring factories and steel mills.The details of each investigation are unique and the root causes are pertinent to each specific case. However, a common thread that emerges in CSB investigations is the inadequacy of management systems that might have prevented the incident from occurring. Examples of the systemic issues identified in CSB reports are: Lack of hazard review to predict and prevent incidents Insufficient investigation and follow‐up after previous incidents Inadequate training of staff Failure to implement effective mechanical integrity programs These issues are well recognized as elements of a process safety management (PSM) program, although many incidents investigated by the CSB occurred at facilities that are not regulated by OSHA's process safety management rule.1 Indeed, a number of these incidents occurred at facilities that are well outside society's definition of “chemical plants.”Please note that the opinions and conclusions expressed in this paper are those of the author, and do not necessarily represent the opinions of the Chemical Safety and Hazard Investigation Board. © 2004 American Institute of Chemical Engineers Process Saf Prog, 2004

On the ability of process hazard analysis to identify accidents

AbstractProcess hazard analysis (PHA) has become the standard way of identifying possible accidents in processes. However, despite the large number of studies that have been performed since OSHA's Process Safety Management standard was issued in 1992, accidents still occur. When this happens the effectiveness of PHA and the quality of the studies performed may be questioned. Litigation can arise, and attorneys may try to make the case that someone was negligent because the PHA did not identify the accident that occurred.While it is possible that PHAs may miss accident scenarios owing to the quality of the study performed, there are other reasons why scenarios may not be identified. This paper identifies and describes such reasons.

Benchmarking MOC practices in the process industries

AbstractChemical, oil, and gas plants process many potentially hazardous chemicals. Historically, a variety of measures have been used for hazard reduction and risk management. However, a number of catastrophic chemical incidents can be attributed to incorrect handling of process changes. During the last decade, federal regulations have been promulgated in the United States mandating a well‐defined administrative procedure for “management of change” as a key element of a process safety management system. OSHA's Process Safety Management Program and EPA's Risk Management Program provide the baselines and framework for the development of Management of Change programs. Due to the performance‐based nature of these regulatory requirements, there is wide variation in management of change programs and practices. This paper summarizes the results of a benchmarking exercise aimed at identifying the diversity of implementation practices in industry.