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Risk Based Process Safety Management (PSM)

PSM eCourse – Background

Extracted from my 3 Day  Process Safety Management (PSM) Training Course (which includes workshops, role playing and examples), this Free eCourse covers the requirements of the Risk Based Process Safety (RBPS) framework developed by the Center for Chemical Process Safety (CCPS) for Process Safety Management (PSM).

Let’s get started:

  1. START HERE:  eCourse overview
  2. THEN: Introduction to PSM video
  3. FOLLOWED BY: Video modules covering the 20 Pillars (or elements) organised into 4 Foundation Blocks as follows:

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    01: Process Safety Management (PSM) eCourse Overview

    The Center for Chemical Process Safety (CCPS)  describes Process Safety Management (PSM) as:

    “The application of management principles and systems to the identification, understanding and control of process hazards in order to prevent process related injuries and accidents”.

    In this short video, we provide an overview on this FreeLearn Process Safety Management (PSM) eCourse structure based on the Risk Based Process Safety (RBPS) framework.

    02: Risk Based Process Safety (RBPS) – Introduction and eCourse Overview

    In this video, we cover the following key aspects:

    • Terminology
    • Global Trends
    • Process safety – vs – Occupational Safety
    • Evolution of process safety strategies
    • PSM Development
    • PSM Models
    • PSM Drivers
    • OSHA PSM Overview
    • PSM Model Comparisons
    • PSM Benefits
    • The “House” picture...What’s that??

    03: Pillar 1: Process Safety Culture

    Process safety culture has been defined as, “the combination of group values and behaviours that determine the manner in which Process Safety is managed“.  

    More succinct definitions include, How we do things around here,” “What we expect here,” and “How we behave when no one is watching”.

    Efforts to nurture and sustain a sound Process Safety culture must occur everywhere, from the boardroom to the production floor.  

    The leadership of an organisation has the primary responsibility for identifying the need for, and fostering, cultural change and for sustaining a sound culture once it is established.

    04: Pillar 2: Compliance with Standards

    Standards is a system to identify, develop, acquire, evaluate, disseminate, and provide access to applicable standards, codes, regulations, and laws that affect Process Safety. 

    The standards system addresses both internal and external standards; national and international codes and standards; and local/state regulations and laws. 

    The system makes this information easily and quickly accessible to potential users. 

    The standards system interacts in some fashion with every RBPS management system element.  Knowledge of and conformance to standards helps a company:

    1. Operate and maintain a safe facility;
    2. Consistently implement Process Safety practices; and
    3. Minimise legal liability.

    The standards system also forms the basis of an audit programme to determine management system conformance.

    05: Pillar 3: Process Safety Competency

    The definition of the individual competence needs is the core of any PSM.

    It forms the basis of the training and assessment programme for the person as well as defining the required level of supervision.  

    Developing and maintaining Process Safety competency encompasses three interrelated actions: 

    1. Continuously improving knowledge and competency;
    2. Ensuring that appropriate information is available to people who need it; and
    3. Consistently applying what has been learned.

    06: Pillar 4: Workforce Involvement

    Workers, at all levels and in all positions in an organisation, should have roles and responsibilities for enhancing and ensuring the safety of the organisation’s operations. 

    However, some workers may not be aware of all of their opportunities to contribute. 

    Some organisations may not effectively tap into the full expertise of their workers or, worse, may even discourage workers who seek to contribute through what the organisation views as a non-traditional role.

    Workforce involvement provides a system for enabling the active participation of company and contractor workers in the design, development, implementation, and continuous improvement of the RBPS management system.

    07: Pillar 5: Stakeholders Outreach

    Stakeholders outreach is a process for:

    • Seeking out individuals or organisations that can be or believe they can be affected by company operations and engaging them in a dialogue about Process Safety;
    • Establishing a relationship with community organisations, other companies and professional groups, and local/state authorities; and
    • Providing accurate information about the company and facility’s products, processes, plans, hazards, and risks.

    This process ensures that management makes relevant Process Safety information available to a variety of organisations. 

    This element also encourages the sharing of relevant information and lessons learned with similar facilities within the company and with other companies in the industry group. 

    Finally, the outreach element promotes involvement of the facility in the local community and facilitates communication of information and facility activities that could affect the community.

    08: Pillar 6: Process Knowledge Management

    The knowledge element primarily focuses on information that can easily be recorded in documents, such as:

    • Written technical documents and specifications;
    • Engineering drawings and calculations;
    • Specifications for design, fabrication, and installation of process equipment; and
    • Other written documents such as material safety data sheets (MSDSs).

    The term process knowledge is used to refer to this collection of information.

    The knowledge element involves work activities associated with compiling, cataloguing, and making available a specific set of data that is normally recorded in paper or electronic format.  However, knowledge implies understanding, not simply compiling data. 

    In that respect, the competency element complements the knowledge element in that it helps ensure that users can properly interpret and understand the information that is collected as part of this element. 

    09: Pillar 7: Hazard Identification and Risk Analysis (HIRA)

    Hazard Identification and Risk Analysis (HIRA) is a collective term that encompasses all activities involved in identifying hazards and evaluating risk at facilities, throughout their life cycle, to make certain that risks to employees, the public, and/or the environment are consistently controlled within the organisation’s risk tolerance. 

    These studies typically address three main risk questions to a level of detail commensurate with analysis objectives, life cycle stage, available information, and resources. 

    The three main risk questions are:

    Once hazards have been identified and associated risks have been analysed, the acceptability of the risk must be judged. 

    10: Pillar 8: Operating Procedures

    Operating procedures are written instructions (including procedures that are stored electronically and printed on demand) that:

    • List the steps for a given task; and
    • Describe the manner in which the steps are to be performed.

    Procedures are generally divided into three categories. 

    • Operating procedures govern activities that generally involve producing a product.
    • Maintenance procedures, generally involve testing, inspecting, calibrating, maintaining, or repairing equipment.
    • Safe work procedures, which are often supplemented with permits (i.e., a checklist that includes an authorisation step), fill the gap between the other two sets of procedures.

    Good procedures also describe the process, hazards, tools, protective equipment, and controls in sufficient detail that operators understand the hazards, can verify that controls are in place, and can confirm that the process responds in an expected manner. 

    Procedures critical to the safe operation or maintenance of equipment should reference hazard review information (as appropriate) and include consequence of deviation warnings.  Procedures should also provide instructions for troubleshooting when the system does not respond as expected.  Procedures should specify when an emergency shutdown should be executed and should also address special situations, such as temporary operation with a specific equipment item out of service. 

    Operating procedures are normally used to control activities such as transitions between products, periodic cleaning of process equipment, preparing equipment for certain maintenance activities, and other activities routinely performed by operators.

    The scope of this element is limited to those operating procedures that describe the tasks required to safely start up, operate, and shut down processes, including emergency shutdown. Operating procedures complement safe work and asset integrity procedures.

    11: Pillar 9: Safe Work Practices

    Safe work practices help control hazards and manage risk associated with non-routine work (i.e., Non-routine work are jobs and tasks that are performed irregularly or being performed for the first time or are not fully described in an operating procedure. Since these tasks and jobs are not performed regularly, it can be difficult to understand all of the hazards associated with the job).

    E.g., Breaking a connection to remove and calibrate a pressure transmitter would be considered a nonroutine work activity and included in the scope of the safe work practices (safe work) element. 

    Safe work procedures typically control hot work, stored energy (lockout/tagout), opening process vessels or lines, confined space entry, and similar operations.

    Some facilities also include procedures or practices that protect against standard industrial hazards, such as falling, in the scope of this element.

    Safe work practices are often required by regulation, regardless of the magnitude of chemical or other hazards present at a facility. 

    Safe work procedures may be applied to construction work, and should be if the work might affect other operations at a facility.

    Safe work procedures can also help protect equipment from damage resulting from maintenance, construction, or other non-routine activities (e.g., excavation near underground lines, lifting over process equipment).

    12: Pillar 10: Asset Integrity and Reliability

    The asset integrity and reliability element is the systematic implementation of activities, such as inspections and tests necessary to ensure that important equipment will be suitable for its intended application throughout its life. 

    Specifically, work activities related to this element focus on: 

    • Preventing a catastrophic release of a hazardous material or a sudden release of energy; and
    • Ensuring high availability (or dependability) of critical safety or utility systems that prevent or mitigate the effects of these types of events.

    The scope of the asset integrity and reliability element includes the physical equipment that provides containment and safety/utility systems that are designed to prevent or mitigate the effects of loss of containment or a sudden release of energy

    13: Pillar 11: Contractor Management

    Contractor management is a system of controls to ensure that contracted services support both safe facility operations and the company’s Process Safety and personal safety performance goals. 

    This element addresses the selection, acquisition, use, and monitoring of such contracted services.

    14: Pillar 12: Training and Performance Assurance

    Training is practical instruction in job and task requirements and methods.

    It may be provided in a classroom or workplace, and its objective is to enable workers to meet some minimum initial performance standards, to maintain their proficiency, or to qualify them for promotion to a more demanding position. 

    Performance assurance is the means by which workers demonstrate that they have understood the training and can apply it in practical situations. 

    Performance assurance is an ongoing process to ensure that workers meet performance standards and to identify where additional training is required.

    15: Pillar 13: Management of Change

    The Management of Change (MOC) element helps ensure that changes to a process do not inadvertently introduce new hazards or unknowingly increase risk of existing hazards. 

    The MOC element includes a review and authorization process for evaluating proposed adjustments to facility design, operations, organisation, or activities prior to implementation to make certain that no unforeseen new hazards are introduced and that the risk of existing hazards to employees, the public, and/or the environment is not unknowingly increased. 

    It also includes steps to help ensure that potentially affected personnel are notified of the change and that pertinent documents, such as procedures, Process Safety knowledge, and other key information, are kept up–to-date.

    16: Pillar 14: Operational Readiness

    The operational readiness element ensures that shut down processes are verified to be in a safe condition for re-start. 

    This element addresses start-ups from all types of shut down conditions and considers the length of time the process was in the shutdown condition. 

    Some processes may be shut down only briefly, while others may have undergone a lengthy maintenance/modification outage, or they may even have been mothballed for an extended period. 

    Other processes may have been shut down for administrative reasons, such as a lack of product demand; for reasons, unrelated to production at all; or as a precautionary measure. 

    In addition to the shutdown duration, this element considers the type of work that may have been conducted on the process (e.g., possibly involving line-breaking) during the shutdown period to help focus the readiness review prior to start up.

    17: Pillar 15: Conduct of Operations

    Conduct of operations (operations) is the execution of operational and management tasks in a deliberate and structured manner.

    It is also sometimes called “operational discipline” or “formality of operations”, and it is closely tied to an organisation’s culture. 

    Conduct of operations institutionalises the pursuit of excellence in the performance of every task and minimizes variations in performance. 

    Workers at every level are expected to perform their duties with alertness, due thought, full knowledge, sound judgment, and a proper sense of pride and accountability.

    18: Pillar 16: Emergency Management

    By definition, emergencies provide little to no warning lead time.  There is little chance or opportunity to develop, update, or revise plans.  Responders are faced with choosing a course of action based on a range of pre-planned response options or derivatives of those options. The response options are typically limited by personnel, their training, equipment, communication protocols, and external support. 

    Emergency management includes:

    • Planning for possible emergencies;
    • Providing resources to execute the plan;
    • Practicing and continuously improving the plan;
    • Training or informing employees, contractors, neighbours, and local authorities on what to do, how they will be notified, and how to report an emergency; and
    • Effectively communicating with stakeholders in the event an incident does occur.

    19: Pillar 17: Incident Investigation and Reporting

    Incident investigation is a process for reporting, tracking, and investigating incidents that includes:

    • A formal process for investigating incidents, including staffing, performing, documenting, and tracking investigations of Process Safety incidents; and
    • The trending of incident and incident investigation data to identify recurring incidents.

    This process also manages the resolution and documentation of recommendations generated by the investigations.

    20: Pillar 18: Measurement and Metrics

    The metrics element establishes performance and efficiency indicators to monitor the near-real-time effectiveness of the RBPS management system and its constituent elements and work activities. 

    This element addresses which indicators to consider, how often to collect data, and what to do with the information to help ensure responsive, effective RBPS management system operation. 

    A combination of leading and lagging indicators is often the best way to provide a complete picture of Process Safety effectiveness. 

    Outcome oriented lagging indicators, such as incident rates, are generally not sensitive enough to be useful for continuous improvement of Process Safety Management systems because incidents occur too infrequently. 

    Measuring Process Safety Management performance requires the use of leading indicators, such as rate of improperly performed line breaking activities.

    21: Pillar 19: Auditing

    The audits element is intended to evaluate whether management systems are performing as intended.

    It complements other RBPS control and monitoring activities in elements such as management review, metrics, and inspection work activities that are part of the asset integrity and conduct of operations elements. 

    The audits element comprises a system for scheduling, staffing, effectively performing, and documenting periodic evaluations of all RBPS elements, as well as providing systems for managing the resolution of findings and corrective actions generated by the audits.

    22: Pillar 20: Management Review and Continuous Improvement

    Management review is the routine evaluation of whether management systems are performing as intended and producing the desired results as efficiently as possible.

    It is the ongoing “due diligence” review by management that fills the gap between day-to-day work activities and periodic formal audits. 

    Management reviews have many of the characteristics of a 1st party audit as described previously.  They require a similar system for scheduling, staffing, and effectively evaluating all RBPS elements, and a system should be in place for implementing any resulting plans for improvement or corrective action and verifying their effectiveness.