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Regulations & EHS&S



Common process safety management gaps

By Janet Persechino and Ryan Welch of Engineering, Planning & Management (EPM), Incorporated - 14th January 2020

Janet Persechino and Ryan Welch of Engineering, Planning & Management (EPM), Incorporated, discuss common process safety management (PSM) gaps based on their review of OSHA’s publicly available violation data.
 
The US Occupational Safety and Health Administration (OSHA) standard Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC) is listed under Title 29 of the US Code of Federal Regulations (CFR) as 1910.119 [1].  This standard outlines methods and programs to decrease the likelihood of chemical releases and reduce the risk to employees, visitors and contractors that work at chemical processing facilities.
 
Facilities are subject to the standard if they process any of the chemicals listed in Appendix A in threshold quantities and on-site in one location. They are also subject to the standard if they process flammable liquids and/or gases in quantities equal to or greater than 10,000 pounds. Exceptions include [2]:
  • Retail facilities and oil/gas well drilling or servicing operations
  • Normally unoccupied remote facilities; the standard defines ‘remote’ as a facility that is operated, maintained or serviced by employees who visit the facility periodically to check its operation, no permanent employees are stationed at the facility, and is geographically remote from all other buildings and persons.
  • Hydrocarbon fuel used solely for workplace consumption as a fuel if such fuels are not part of a process containing another highly hazardous chemical covered by the standard
  • Flammable liquids with a flashpoint below 100°F stored or transferred in atmospheric storage tanks, which are kept below their normal boiling point without benefit of chilling or refrigeration.
Regulatory compliance is not the only goal of adequate PSM programs, nor is it the goal of this review.  The purpose of reviewing the OSHA violation information is not meant to help facilities avoid OSHA citations but to uncover gaps – hopefully leading to more focused solutions.  The information provided in this article reviews some of the violation data over a 10-year period, 2007-2017 [3].
EPM 2020-01 Figure 1.png

The PSM elements are listed in the 1910.119 standard in the following lettered sections:
  • (c) Employee participation
  • (d) Process safety information
  • (e) Process hazard analysis
  • (f) Operating procedures
  • (g) Training
  • (h) Contractors
  • (i)Pre-startup safety review
  • (j) Mechanical integrity
  • (k) Hot work permit
  • (l) Management of change
  • (m) Incident investigation(n) Emergency planning and response
  • (o) Compliance audits
  • (p) Trade secrets.

The data show that there four elements that are cited most frequently in violation cases. From highest to lowest, the most commonly cited elements are: process safety information; mechanical integrity; operating procedures; and process hazard analysis. The most costly violations relate to mechanical Integrity, process safety information, operating procedures and process hazard analysis (Figure 1).

EPM 2020-01 Figure 2.png
It is alarming that process safety information is the most cited element.  Having correct and adequate process safety information is the foundation for implementing, not only all PSM elements correctly, but any and all chemical safety precautions. Mechanical integrity can be difficult to implement, but new software solutions and training programs exist to help with proper execution.  There are products on the market that come with capabilities to capture process safety information, process hazard analysis and operating procedures addressing all of these elements within one product. 
 
In fact, each of these elements have known solutions and corrective actions can be easily implemented given the lessons learned and the current level of expertise that exists in the industry.
 
It can be helpful to utilize PSM experts for implementation and execution of PSM programs, as they are aware of the depth of information that is needed to meet the intent of the standard and for overall safety.  Individuals dedicated to PSM will have access to resources that might not be available to others who are not embedded in the PSM field. 
 
EPM 2020-01 Figure 3.png
The expenditure for bringing in this type of expertise can provide a beneficial return on the investment when we start to look at average cost per violation and average number of violations per OSHA inspection visit (Figures 2 and 3). 
 
The costs of these violations typically exceed the costs of PSM consultancy – had such consultancy been employed in time. However, costs are only one aspect to consider when reviewing the return on investment.  Other benefits that are quickly realised once PSM programs have been established include:
  • Improvement in operating efficiencies (less waste)
  • Increased employee morale
  • Lower turnover rates
  • Safer working conditions
  • Uptime gains
  • Insurance benefits
  • Decreased likelihood of an incident.
It should also be noted that the violation information is public data available to lawyers and insurance companies.

A deeper dive into the subsections of the most commonly cited elements yielded the results in Figure 4. While process safety information was the most cited element overall, the most frequently cited sub-section was equipment information, which ties into the mechanical integrity portion of PSM.  Based on this, deficiencies in equipment-related information and mechanical integrity rank very high on the list.   

The most cited sub-sections of OSHA’s PSM standard were:
  • Process safety information: Equipment information (section 03 in Figure 4)
  • Mechanical integrity: Written maintenance procedures (section 04);    Inspection and testing (section 02); Correcting equipment deficiencies (section 05)
  • Process hazard analysis:  Inadequate coverage of the hazards of the process (section 03)
  • Operating procedures:   Develop written operating procedures (section 01).
EPM 2020-01 Figure 4.png
While PSI was the most cited element, the most cited sub-section is Equipment Information, which ties into the Mechanical Integrity portion of PSM.  Based on this, deficiencies in equipment related information and mechanical integrity ranks very high on the list.   
 
MI programs are complex and can be difficult to establish, but there are current solutions on the market to help correct these deficiencies, such as economical software solutions that improve compliance by organizing maintenance tasks.  The right solution can alert staff to overdue maintenance and store the maintenance history for each particular piece of equipment.  Some tools can also track inventory of spare parts and keep Management of Change documents related to the process and/or the equipment.  Consultants versed in the regulations and mechanical integrity techniques can help establish appropriate solutions.
 
The development of operating procedures for both process and maintenance activities have a high number of citations in the mechanical integrity and operating procedures elements.  It is essential that these procedures are comprehensive, accessible, updated and easy to interpret.  Mistakes in operating steps, or failure to recognise abnormal conditions, can quickly lead to catastrophic releases.
 
Software tools currently on the market can assist in organizing this critical information.  Also, once authored, it is easier to audit the documents for accuracy and audit the operators using a behavior-based system to determine that procedures are being followed.  Vast benefits can be gained using this approach, and many PSM consultants offer services to help author these documents and provide suggestions for document control, audit and review processes.
 
In conclusion, our research objective was to highlight some common gaps in implementing PSM. The OSHA violation picture is only one piece of the gap analysis puzzle, but it is one place that collects enough data to increase awareness of PSM weaknesses, regardless of the type of operation. 
 
Despite the intent for OSHA PSM to decrease the likelihood and severity of accidents, PSM gaps still exist.  These gaps present an unacceptable risk.  This is evidenced by the accidents that continue to occur. The various incident investigations performed by the US Chemical Safety and Hazard Investigation Board often attribute inadequate PSM programs as the root cause. 
 
Solutions to the deficiencies revealed by this data are well-known and PSM experts are aware of the solutions that exist.  Return on investment is usually realized soon after the solutions are put in place.  Many PSM consulting firms focus on compliance and help embed PSM concepts into the plant’s overall safety culture.  Bringing in these third parties is worth the cost because they can bring along expertise from other industries, the latest information and years of experience.
 
The list of resources (consultants, software, trade organizations) are readily available, even for the smallest of plants, and they are much more prevalent than they were 10 years ago.  PSM implementation is a continuous improvement journey with new lessons learned, new technologies and new resources being created every year.  Using the plethora of tools available can help close the deficiency gap.
 
References
1. U.S Department of Labor OSHA 3132 Publication Process Safety Management 2000 (https://www.osha.gov/Publications/osha3132.pdf).
2. U.S Department of Labor OSHA 3133 Publication Process Safety Management Guidelines for Compliance, 1994 (https://www.osha.gov/Publications/osha3133.html).
3. OSHA Violation Data 2007-2017 downloaded from OSHA database.


Authors:
Janet Persechino and Ryan Welch of Engineering, Planning & Management (EPM), Inc, 959 Concord Street, Framingham, MA 01701, USA
T: +1 508 875 2121
www.epm-inc.com

For more information, contact Janet Persechino at jap@epm-inc.com