Process Safety Regulations 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.

Review of global process safety regulations: United States, European Union, United Kingdom, China, India

Process safety regulations are an integral part of maintaining the safety of workers, the public, and the environment. Therefore, global regulations were analyzed to compare the extent of process safety regulations in the United States, European Union, United Kingdom, China, and India. The development of regulations is typically instigated by the occurrence of a significant process safety incident. However, the extent of the regulations and the quality of their enforcement varies greatly between countries. In general, the developed countries have better reporting procedures, enforcement of regulations, and emergency plans which increases the number of incidents reported. Developing countries are working to implement regulations, typically influenced by regulations from developed countries, but the regulations aren't currently enforced to the same extent. Overall, improvement in reporting & data collection procedures and increased communication between the government, companies and the public would help increase the effectiveness of process safety regulations.

Investigating Written Procedures in Process Safety: Qualitative Data Analysis of Interviews from High Risk Facilities

Socio-technical systems, such as those in oil and gas, or the petrochemical and energy industries, are escalating in complexity, a consequence of increasingly advanced technologies, organizational constructs, and business functions that interact and depend on one another. These dynamic social and technological elements, coupled with the high risk inherent in these systems, have generated conditions that can bring about catastrophic failure and the tragic loss of human life, such as the disaster in Bhopal, India (1984) or the explosion in the Houston Ship Channel near Pasadena, Texas (1989). Historically, the perception of such complexities and the struggle to minimize catastrophic failures observed within the petrochemical industry have been attributed to the inherent variability in people. Therefore, process safety regulations associated with the Clean Air Act Amendments of 1990 and the Occupational Safety and Health Administration (OSHA) require employers to develop written process safety information or “procedures” which aim for consistency in plant operations and to help workers at the “sharp-end” of the system cope with unexpected events (OSHA, 2000). However, investigation reports since, such as the BP Texas City incident of 2005, suggest “outdated and ineffective procedures” as significant contributing factors to failure. Evidence from other studies suggest that procedures in complex environments are sometimes misunderstood, outdated, or simply not used (Bullemer & Hajdukiewicz, 2004). While there have been studies on procedural deviations and safety violations (Alper & Karsh, 2009; Jamison & Miller, 2000), employers continue to report a high rate of procedural breakdown as root causes for incidents (Bates & Holroyd, 2012). This warrants a contemporary, systems-oriented inquiry into process safety and behavior surrounding the use of the documents at different individual (e.g. cognitive), task, cultural, organizational, and environmental levels. This perspective appreciates the interdependent nature of these interrelated socio-technical elements and should provide insight into the effectiveness of current procedure systems, thereby informing future work in creating and empirically testing mitigation methods to address potential barriers. This research documents one part of a three part, large-scale project that investigates the issues with procedure forms, usage, adoption, and challenges in a wide range of high-risk industries. As such, the method was framed around first understanding the extent to which these challenges could be generalized between various locations. A grounded theory approach in qualitative data analysis, influenced by the Strauss & Corbin and Charmaz approaches (Bryman 2015) and facilitated by the analysis software MAXQDA-12 was used to examine 72 semi-structured interviews with operators of varying roles and experiences across 6 countries and an offshore drilling vessel. Findings reaffirm previous research, suggesting that the effectiveness of written procedures is limited by an abundance of outdated procedures plagued by information overload. New findings suggest that frequency of the task and the experience level of the worker would impact workers’ procedure use, with participants commenting that the perceived importance of these documents decreases significantly after initial training periods. Other unintended consequences associated with written procedural systems range from complications in using the documents around personal protective equipment (PPE) requirements and harsh weather, reactive organizational behavior surrounding changing procedures, and a general disconnect between the users and the writers of these documents. This is only exacerbated as management imposes pressure to use procedures on personnel despite the issues encountered with the documents, inhibiting valuable feedback within their organizations as personnel withhold information for fear of job security and potential punishment (in the form of 20-day suspension programs or termination). Moving forward, research is in-progress to identify the interdependencies between environmental, cultural, organizational, task, and personal factors unique to each location. This will provide insight regarding the extent to which procedures may not be generalized, after which a holistic view of procedure use in the industry will be offered. The resulting insight will point to recommendations for the future redesign of procedures’ role in promoting safe operations within petrochemical systems. Finally, the third part of this research project will demonstrate the efficacy of using visualizations as tools and methods in qualitative research for modeling complexity in socio- technical systems.

Numerical risk tolerance criteria in the United States: A critique of the risk criterion used for the New Jersey Toxic Catastrophe Prevention Act

Numerical risk tolerance criteria are used around the world in the management of process safety, although federal process safety regulations in the United States do not currently employ such criteria. However, increasingly individual companies are employing numerical criteria motivated by industry practices and standards. Often, precedents are sought in setting criteria. One precedent is the first process safety regulation that was enacted in the United States in the state of New Jersey under the Toxic Catastrophe Prevention Act (TCPA). The regulation that implements the TCPA contains a numerical risk criterion. Companies covered by the regulation must demonstrate through analysis that they comply with the criterion. Unfortunately, the criterion and the procedure for using it are seriously flawed and they should not be used as a precedent by companies or other regulators. This paper identifies various problems with the criterion and describes how to overcome them in order to explain how to avoid mistakes in developing criteria.

Process safety challenges for SMEs in China

While process safety regulations and standards have been in place in western countries for more than two decades, China has only recently started to officially embrace these issues with the adoption of its Process Safety Management (PSM) regulation AQ/T 3034-2010 (SAWS, 2010). However, compliance with this regulatory framework requires substantial resources and may therefore appear too complex to be efficiently implemented by small and medium sized enterprises (SMEs) in the chemical sector. This is of particular relevance as about 99% of chemical companies in China are SMEs, accounting for more than 80% of all chemical accidents. To address this issue, additional local regulations and planning activities related to process safety have been implemented in China, including the establishment of hundreds of chemical industry parks. Some of the process safety problems faced by chemical industry parks are identified and discussed in this paper. To help solve these problems, UNEP's “Responsible Production approach for Chemical Hazards Management along the Value-Chain” is introduced in this paper and suggested as a simplified PSM approach targeted specifically at SMEs which, regardless of handling hazardous chemicals in their daily operations, may not have the knowledge or capacity to efficiently implement PSM and may not fall in the scope of the PSM regulation AQ/T 3034-2010. By introducing PSM to SMEs in a more manageable way, relevant steps can be progressively implemented by companies towards full compliance with the current regulatory framework, contributing to increased safety in chemical industry parks in China.

History of process safety at OSHA

AbstractOccupational Safety and Health Agency (OSHA)'s first major process safety regulation, 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (PSM) was enacted in 1992. However, OSHA's experience with process safety began in the 1980s when a series of catastrophic chemical incidents occurred. Learnings from investigations of these incidents helped to shape PSM. More than 15 years after PSM, lessons from incidents and inspection experience continue to shape the history of process safety at OSHA. © 2009 American Institute of Chemical Engineers Process Saf Prog, 2009

The Real Cost of Process Safety—A Clear Case for Inherent Safety

This paper takes a deep look at the costs related to process safety. It is not confined to the costs of trips and alarms, compliance with regulations and worker training, but also takes into consideration many aspects considered standard process design practice. In reality, these practices have evolved due to process safety considerations, for example, use of a pressure vessel as a reactor instead of an open vat. The scenario considered is a simple process of making salt solution (sodium chloride dissolved in hydrogen monoxide, H2O). It is carried out in open vats. New tests indicate that hydrogen monoxide is indeed very hazardous, since it is made up of extremely hazardous hydrogen and a very active supporter of fire, oxygen. Hence, the company has to comply with all the applicable process safety regulations and modify the plant accordingly. Factors that affect the cost due to the hazardous nature of operation have been listed. While the exact cost would vary from one plant to another, this cost could, according to our thinking, amount up to one-third to one-half, or even more, of the capital and operating costs of the new plant handling the hazardous operations. The vision of the process industry globally is zero hazards and zero accidents. The costs of running the hazardous process mentioned in this paper would hopefully drive the industry to consider inherently safer systems, green chemistry, process intensification, and the like. Just imagine if process plants, at some later date, cost only one-third to one-half of their current counterparts, and are significantly safer too! How much cheaper would the cost of living become, since we use chemicals in one form or the other, throughout the day? Corporate profits would increase and process-related liabilities would (almost) disappear. The regulations too would be reduced to just a few, as would the number of regulators. Successful application of inherently safer concepts in the process industry will motivate other accident-prone industries such as construction, mining and transport. It may even decrease the frequency of medical errors by encouraging development of inherently safer medical equipment, techniques, and procedures.

The anticipated impact of the EPA's RMP regulation on the ammonia industry

AbstractOver three years ago the Occupational Safety and Health Act (OSHA) process safety management regulation became effective in the United States. Most of us have dealt with the initial shock of that regulation and what it entailed and, hopefully, we have things pretty much under control.Although, one hates to be the bearer of bad news, it is not yet time to relax. The Environmental Protection Agency (EPA) has another process safety regulation in store for the ammonia industry. In fact, in some areas, the EPA's upcoming risk management programs regulation makes the OSHA regulation look like child's play.It is much better to be proactive than reactive when responding to new regulations. A proactive approach allows one to make the correct long‐term decisions without the pressure of a compliance deadline.

Interactive training aims to prevent disaster

Many chemical plant disasters have been precipitated by an unplanned change in process, a change in equipment, or a change in personnel. In the Occupational Safety & Health Administration's process safety regulations, training in management of change is required for plant workers. To assist companies with that training and with changing the attitude of workers toward change, the American Institute of Chemical Engineers' Center for Chemical Process Safety, New York City, has developed an interactive computer-based training module. The approximately three-hour course requires users to read passages, answer multiple-choice questions, and deal with situations such as scheduled maintenance and changes in process or personnel. The program allows plant personnel to sit at their computer workstations to complete the training and—if they aren't careful—blow up a virtual plant. The scenarios, such as replacing a catalyst in a process or making a process decision just before a three-day weekend, are based on real-li...

Direction of plant process safety regulation in the United States

Direction of plant process safety regulation in the United States