Three Simple Things to Improve Process Safety Management

In this Tip of the Month, we look at how to deal with some of the challenges of managing process safety.  This TOTM is an excerpt of a paper presented by JMC Instructor/Consultant, Clyde Young at the 2008 Mary K. O’Connor Process Safety Symposium.  This TOTM continues where the February 2009, TOTM left off.

Processes are designed to run in a “normal” mode.  No process is really stagnant and throughout the life cycle of a process, changes will be made.  When defining “normal”, some tolerance should be built in to allow a range of operating conditions for operators to work within.  When changes to operating parameters, or the equipment in the process are required, these must be evaluated and approved. Any effective process safety management system will contain an element to deal with Management of Change (MOC).  Experience conducting training, audits and process hazard analysis studies indicate that identifying what changes require evaluation using the MOC process can be confusing at times.  Some organizations only evaluate technical changes to the process and equipment and ignore or forget about managing changes to the PSM system or personnel changes within the organization.

Insuring that PHAs are consistent with the process through the revalidation process is less time consuming and more likely to yield effective results if the facility’s MOC program is rigorously followed.  If this cannot be assured, then the only choice may be a complete redo of the PHAs.  This could be very expensive and resource intensive.

To alleviate confusion and especially to insure that all personnel within an organization understand and will follow the MOC program requires practice.  As more MOCs are developed and approved, all personnel become more competent at evaluating change and meeting the requirements of the program.  Ever since the US Occupational Safety and Health Administration (OSHA) implemented the PSM standard in 1992, one of the hottest debate topics witnessed in plant offices is about replacement in kind.  OSHA and CCPS define a replacement in kind as meeting the design specification of the original.  This is a workable definition, but can cause some confusion when personnel are not well versed in PSM and risk management.

The second simple thing which can be done to improve process safety management systems is to do away with the concept of replacement in kind.  Again, this does not have to be and probably can’t be accomplished throughout an organization; this can certainly be implemented at the process and plant level for a specified period of time.  The purpose of this change would be to end the debates and more importantly allow personnel an opportunity to practice and become competent at all the issues associated with performing changes.

A real life example illustrates this:

A Waukesha 7042 engine is scheduled for overhaul.  Three options are considered:

• overhaul in place by company personnel,
• overhaul in place with contract personnel
• removal of engine and ship to contractor for overhaul.

The most economical choice was found to be, swap the engine with another 7042 engine.  The only difference is the serial number.  This was determined to be a replacement in kind, and by definition it is.  However, the older 7042 engine was “grandfathered” under the facility’s air discharge permit from the environmental regulatory body.  As soon as a new engine, with a different serial number was installed, the “grandfathering’ of the older engine was invalid and a new air permit had to be issued.  To meet the requirements of the new permit, air/fuel ratio controllers and catalytic converters were required.  This change cost the company approximately $70,000 above the highest priced option that was analyzed.   This change also increased the workload on maintenance and operations staff, which could affect other areas of operations.

During audits, there have been several instances where plant personnel try to stretch the replacement in kind exemption so that changes to the process are not evaluated with the MOC process.  The most frequent reasoning for this is that the MOC process is too cumbersome and takes too long.  In the end, the MOC process is being bypassed and potential hazards may not be addressed appropriately.

The MOC process to, evaluate personnel changes, is used by some organizations, but generally it occurs for changes at the supervisory level.  But consider that no two people are the same.  Both have different skill sets and it is important to dig a bit deeper into the “design specification of the original” to determine what the real impact of personnel changes might be.  Especially consider the reassignment or replacement of operations and maintenance personnel.  Identifying gaps in their technical competencies should be an important part of the MOC evaluation.  The evaluation can be a powerful tool for performance management and identification of training opportunities for development.

In the end, doing away with the replacement in kind exemption within a facility’s MOC process can increase the process safety competencies of all personnel.  Process safety competency is one of the elements of the CCPS Risk Based Safety Management guidelines.  Increased competency leads to a change in the culture and hopefully a safer process.  Within the world of adult learning, it is recognized that learners must be given the opportunity to apply lessons to the job or the training may be lost.  Considerable time and effort may be spent providing training to personnel on the procedures for managing change, but how often are they given the opportunity to put this training into practice within the working environment?

The final simple thing will be presented in a future tip of the month.  If you would like a copy of the paper that was presented, please contact John M. Campbell & Co. and request a copy.

To learn more about managing process safety systems, we suggest attending our PetroSkills HSE course, HS 45- Risk Based Process Safety Management or schedule a session of our two day Process Safety Case Study for Operations and Maintenance – OT 21, which can be found in our catalog.  To enhance process safety engineering skills we suggest any of the JMC foundation courses and watch for an announcement scheduling sessions of our newly developed,  PS 4 – Process Safety Engineering course.

By: Clyde Young
Instructor/Consultant