On the fateful night of 2nd December 1984, more than 2000 were killed after the release of Methyl Isocyanate in a Union Carbide India Limited plant in Bhopal. Five years later, in 1989, a series of explosions and fires at Phillips 66 Company’s Houston Chemical Complex caused by inadequate safety procedures took the lives of 23 people and injured another 132. Then in the years 1990 and 1991, two more incidents took place in the United States. First, an explosion at the BASF in Cincinnati, Ohio that resulted in 2 deaths and 132 injuries. Then another in May at the IMC Sterlington facility in LA that took 8 lives and injured 128 others. According to the U.S. Chemical Safety and Hazard Investigation Board (CSB), there have been 281 identified incidents between 1980 to 2005 that have taken the lives of 119 workers injured 718 more. Could these incidents have been prevented through better process safety practices? Arguably. Over time, different companies have relied on different process safety practices to prevent disasters like these. Some are based on standards and regulations issued by different entities such as the Occupational Safety and Health Administration (OSHA). But why are accidents still happening?
What is Process Safety Management?
Center For Chemical Process Safety defines it as a system that “is focused on the prevention of, preparedness for, mitigation of, response to, and restoration from catastrophic releases of chemicals or energy from an industrial chemical manufacturing process associated with a facility.”
OSHA’s PSM standard, 29 CFR 1910.119 emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.
One of my favorite descriptions that I learned from a PSM training I had attended once was “keeping the dragon in the pipes”.
Through years of experience and learning from painful incidents, OSHA has outlined 14 elements that encompass the scope of PSM. However, some organizations instead follow the CCPS Risk-Based Process Safety (RBPS) Management System which has a total of 20 elements.
Why is it important?
Disaster can happen at any time. These regulations and standards are put in place because they can prevent heavy losses, including loss of life, property, and reputation. Even though OSHA legally requires your facilities that are considered covered processes to implement a process safety management system, it’s one’s moral and social obligation to not let any harm come to another human being. Most of these plant workers have families and are the sole breadwinners of their families. Even a small accident can change chemical plants’ reputation for the worse. Therefore, it’s in everyone’s best interests that safety is maintained in each corner of the plant. Here’s how you can do it,
Major accidents don’t happen out of anywhere. They are always small missteps, oversights, and issues that lead to bigger problems. This is where the 14 OSHA elements come in. These regulations have been in place for more than two decades and check the organization for any of those missteps or oversights. Think of the OSHA regulations as a checklist, the more boxes you tick, the more likely you are to avoid any major incident.
However, most organizations realize that these elements are not always enough. For instance, ammonium nitrate that caused the explosion in West Texas in April of 2013 that took the lives of 15 people is not listed as a PSM chemical under OSHA (this is about to change). Another example is the sugar dust explosion in the Imperial Sugar Plant in February of 2008 that lead to 14 deaths. There is no mandatory OSHA standard for controlling dust in the general industry. To protect their workers, factories, and the environment, most organizations follow certain guidelines that are not mandated by law. Following are some of them:
- Go above and beyond the 14 elements
As mentioned above, sometimes the OSHA standards are just not enough to cover every aspect of an organization. In these cases, in order to implement a successful PSM program, the organization needs to go above and beyond those 14 elements. For starters, the organization should try to incorporate some of the guidelines outlined by CCPS that are not included in the OSHA standard. As an example, companies should have standards or benchmarks in place and measure current performance with set benchmarks. This will ensure consistency in quality and that some metrics never fall or rise to unacceptable levels.
- Develop a culture for change
Every business organization is a dynamic entity and so is the business environment. That means the factors that govern how one must manage their company is constantly changing. In order to implement such changes in your PSM program, the organization must foster a culture that accepts change. By culture, I mean how things are done in your organization. It includes the behavior of employees, contractors, and users.
For instance, a new regulation or a new scientific discovery could force you to introduce certain changes to your PSM program. However, this can only be done smoothly if the mindset of your workers allows this change. One must understand that any change in the PSM (or any system for that matter) means workers will have to move from a familiar environment to an unfamiliar one. Some of the ways you can introduce changes smoothly are:
- Ensuring employees are aware of the benefits to be gained
- Managers and leaders should motivate employees and teach them ways in which they can help support the change.
- Holding classes, seminars, and meetings to demonstrate the new process or best practices to the employees to remove any confusion.
This is important because if the employees don’t fully embrace the changes in
the PSM program, they are likely to do things their way and not according to
- Integrate PSM with other management systems
Most of the companies that have a PSM program in place also have a dedicated management system(s) to improve operating efficiency, performance, production, and consistency. However, it’s possible that the business management system’s (BMS) functions could overlap with the process safety management system’s (PSM) functions leading wastage of resources, confusion, and even frustration between departments. Your organization could avoid these potential problems by integrating the PSM with your BMS.
Ensuring that your process safety works with your management systems also have certain benefits, like:
- Ensuring no management decision will lead to decreased process safety.
- Higher operating efficiency as fewer resources is wasted.
- Reaching organization goals faster through synergy between different management systems.
- Learning from incidents
There have been incidents in every industry and these incidents lead to investigations, reports, and valuable recommendations for process safety – do not overlook these resources. For instance, the Piper Alpha disaster of 1988 led to a public inquiry which brought about significant improvements in process safety. The recommendations made in the Cullen Report emphasized the importance of communication and maintaining equipment. Accidents like Deepwater Horizon and Milford Haven both lead to thorough investigations and comprehensive reports that have helped make offshore drilling industry and oil refineries much more safer.
The causes that lead to these disasters have been uncovered and by taking a look at those reports and investigations, you’re not only ensuring the safety of your workplace but also that hundreds of workers did not lose their lives in vain.
In fact, I urge you to foster a culture of loss prevention and inquiry in your workplace. If a worker feels something is not right, there should due process and investigation into the problem by a qualified team. And afterward, all employees should be made aware of the findings so one stays in the dark.
Wrapping up, it’s important to know that the success of any organization relies heavily on how it manages its processes. A well-designed and well-implemented process safety management system will ensure that your day-to-day operations run without any hiccups.