12.2 Process safety management

Process safety management is crucial for preventing catastrophic chemical releases in industrial settings. It involves systematic approaches to identify, evaluate, and control hazards throughout a process's lifecycle, from design to decommissioning.

Effective PSM systems include key elements like hazard analysis, operating procedures, and training. Stakeholders at all levels play vital roles in implementing PSM, while metrics and audits help evaluate its effectiveness and drive continuous improvement.

Process Safety Management Systems

Key Elements of Effective PSM

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• Process safety management (PSM) systematically prevents and mitigates consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals
• Effective PSM systems include process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup safety review, emergency planning and response, compliance audits, and incident investigation
• Process safety information contains detailed data on hazards of chemicals used, process technology, and equipment
• Process hazard analysis systematically identifies, evaluates, and controls process hazards using techniques like hazard and operability studies (HAZOP) and failure modes and effects analysis (FMEA)
• Operating procedures provide clear instructions for safely conducting activities in each covered process, including steps for each operating phase, operating limits, and safety and health considerations

Training and Documentation in PSM

• Training ensures employees and contractors are trained in process overview, operating procedures, specific safety and health hazards, emergency operations, and safe work practices
• Mechanical integrity focuses on maintaining equipment to prevent failures and ensure safe operation
• Management of change addresses potential safety impacts of process, equipment, or personnel changes
• Pre-startup safety review confirms construction and equipment are in accordance with design specifications before introducing highly hazardous chemicals
• Emergency planning and response procedures prepare for and respond to potential emergencies
• Compliance audits evaluate PSM system conformance with requirements at least every three years
• Incident investigation identifies root causes and implements corrective actions for incidents that resulted in or could have resulted in catastrophic releases

Stakeholder Roles in Process Safety

Management Responsibilities

• Implementing PSM requires involvement and commitment from various stakeholders, including top management, process safety professionals, operators, maintenance personnel, and contractors
• Top management establishes overall PSM policy, provides resources and support, and ensures accountability for PSM performance
• Process safety professionals (process safety engineers, risk managers) develop and maintain PSM system, conduct process hazard analyses, and provide technical expertise

Employee and Contractor Duties

• Operators follow operating procedures, report process safety concerns, and participate in training and drills
• Maintenance personnel ensure mechanical integrity of process equipment, perform preventive maintenance, and respond to equipment failures
• Contractors comply with PSM requirements, ensure competency of their employees, and coordinate activities with the host employer

Applying Process Safety Principles

Inherent Safety in Design

• PSM principles should be applied throughout a chemical process lifecycle (design to decommissioning) to ensure inherent safety
• In the design phase, inherent safety principles (minimization, substitution, moderation, simplification) eliminate or reduce hazards at the source
• For example, using a less hazardous solvent or reducing the quantity of hazardous materials in the process can inherently reduce risk

Safe Operations and Maintenance

• In the operation phase, operating procedures, training, and management of change are critical for safe and reliable process operation
• Operators must be properly trained on procedures and hazards, and any changes to the process must be carefully evaluated and managed
• In the maintenance phase, mechanical integrity and quality assurance prevent equipment failures and ensure continued safe operation
• This includes regular inspections, testing, and preventive maintenance of critical equipment (pressure vessels, piping, relief devices, controls)
• Process safety considerations should be integrated into management of change to prevent new hazards or increased risks when making changes to the process, equipment, or personnel

Evaluating Process Safety Effectiveness

Metrics and Indicators

• PSM system effectiveness should be regularly evaluated using metrics and auditing for continuous improvement and regulatory compliance
• Leading indicators (near-miss reporting, process safety training, management of change) provide early warning of potential issues and enable proactive measures
• For example, tracking the number and quality of process hazard analyses or the percentage of employees trained on operating procedures
• Lagging indicators (process safety incidents, equipment failures, regulatory citations) measure overall PSM performance and identify areas for improvement
• An example would be the number of loss of containment events greater than a certain threshold quantity

Auditing Approaches

• Compliance audits, by internal or external auditors, assess PSM system conformance with regulations (OSHA PSM, EPA RMP) and industry standards
• Management system audits, like those based on the CCPS Risk Based Process Safety (RBPS) framework, evaluate PSM effectiveness in managing risks and driving continuous improvement
• These audits go beyond just regulatory compliance to assess the maturity and robustness of the overall PSM system and culture
• Audit findings and recommendations are used to develop and track corrective actions to address gaps and improve the PSM system over time