THE 14 ELEMENTS OF PROCESS SAFETY MANAGEMENT – 2020 MUSINGS
1. EMPLOYEE PARTICIPATION
Process Safety Management (PSM) is not a project that can be finished. It has no end, and it requires that everyone be involved, especially the men and women in the middle of the hazard. PSM affects everyone; especially them!
2. PROCESS SAFETY INFORMATION (PSI)
Know the design and design intent of the facility (technology and equipment) and make sure you know what flammables and chemicals (hazards) you are dealing with. Until you know what you are dealing with, you can’t manage it. Making sure all this process safety information is right, accessible, understood and kept evergreen is very difficult. Having a great MOC process makes this achievable, but not easy.
3. PROCESS HAZARD ANALYSIS (PHA)
What are my hazards, what can go wrong, what are my controls/safeguards and how safe am I? HAZOPS, Checklists and What-Ifs? are the techniques most used, but it’s not the method of analysis that makes it work, it’s the experienced, multi-discipline team.
4. OPERATING PROCEDURES
There must be a “right way” to operate the plant/facility/platform. That “right way” needs to be documented and validated so that there is a basis for training… It’s that simple! If your procedures are too detailed, no one will use them. If you make them to high level, they will not be useful…
Use the operating procedures to train and refresh the knowledge of the staff. Training is for everyone, not just operators and mechanics. Engineers and managers need training too.
Treat them like family. Whether they are in operations or maintenance, they will help determine the success of your PSM program. Their performance or non-performance can be determinant.
7. PRE-STARTUP SAFETY REVIEW
It’s a quality/safety review of changes (MOCs) before they are used. PSSR is meant to be a tool for operations to ensure the “project” or change was completed in a satisfactory manner before permission is given to startup. It is the operations hammer!
8. MECHANICAL INTEGRITY
Keep the genie in the bottle. If you can’t assume that all the equipment is fit for service and in good working order, your process hazard analysis and your Process Safety Information is a lie! Inspect, repair and protect.
9. HOT WORK PERMIT – Safe Work Permits Actually
When you open process equipment, de-energize an electrical circuit or enter a confined space you are deviating from design intent. These special operations require special procedures, analysis, controls and permits. This element was never intended to be about “hot work” only. It covers all special operations including excavation, cold work, lock out, tag out, line break, demolition, confined space, etc. Maintenance can be a dangerous business as you can be creating a hazard or removing hazard controls with these operations.
10. MANAGEMENT OF CHANGE
Continuous improvement requires change. There are two kinds of change: in-kind (simple, well understood change) and not in-kind (MOC or complex change). All change requires management. Without an effective MOC system, your investment in PSI, training, procedures and PHAs will soon be lost and you will have to start over again…Very Expensive!
11. INCIDENT INVESTIGATION
This is not a reporting requirement. It is a requirement to pay attention and learn as you go. Most companies use the same process for EHSQ and security. Incident management process is the same no matter what event you are trying to learn from. What happened (documentation), what have we learned (analysis) and what will we do differently (change).
12. EMERGENCY PLANNING AND RESPONSE
When the foreseeable happens, what do you do? Create an emergency response plan. This will be based on your PHAs and PSI. Once you have a plan. You will need procedures to practice so that responding to an emergency is efficient and effective. Practicing emergency response and critiquing those responses is what this element requires. Critiques lead to recommendations for getting better. These recommendations for change can require MOC. If your PSI or PHAs change, they might affect this element…
13. COMPLIANCE AUDITS
This element is about measuring how well, not whether, you are executing these elements on a 3-year basis. There will always be holes/gaps and you will always have recommendations for getting better or you are not paying attention. The audit element is not a box checking exercise, it’s for learning and getting better, like incident management.
14. TRADE SECRETS
You can’t keep secrets from the PHA team, or they cannot judge the degree to which your hazards are understood and controlled.