Improve Safety Despite Limited Resources

Even small plants can run an effective process safety program.

By Jack Chosnek, KnowledgeOne

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During tough economic times many companies reduce their head count either by layoffs or by not replacing personnel who have retired or quit. One of the most affected areas is process safety management (PSM) because lots of firms don't consider the function of the PSM manager or coordinator as critical. Instead, they only view it as a way to incrementally improve process safety performance, mainly to decrease the probability of a regulatory mishap or provide a better corporate image rather than to actually reduce the chances of a serious incident.

Although day-to-day application of process safety principles is line management's responsibility, such managers often lack the essential specialized knowledge of the "why" and "how" of some intermittent activities, e.g., process hazard analysis (PHA), safety analysis in management of change (MOC) and incident investigation. A process safety professional who can tie all these elements together is really needed.

Large and medium-sized companies often can afford such a professional, especially if the person serves as PSM coordinator for many sites. However, small and some medium-sized firms can't justify such a position. They treat PSM as a part-time job to be handled by the environmental, health and safety (EHS) coordinator or a process engineer with some knowledge of process safety.

Many small companies downplay PSM because they view it as non-essential to their business. So, they only dedicate enough resources to PSM to meet regulatory burdens. Some very small companies don't even attempt to address PSM but just try to stay under the U.S. Occupational Safety and Health Administration's radar. This stems from a lack of understanding of the potential impact of not following a process safety program and a fear of the expenses involved in such a program

So, not surprisingly, significant safety incidents continue to occur at plants, and many sites still pose a high potential for catastrophic events.

PREVALENT PROBLEMS
The most common deficiencies in process safety affecting small companies (and many others as well) are:

• Deficient or non-existent MOC. This leads to perfunctory safety analyses, overextended temporary changes, etc.
• Inadequate PHAs. Risk identification and evaluation, etc., are poor.
• No refresher training. Although procedures may exist, personnel don't periodically review them.
• Poor process safety information (PSI). Essential details can't be found or are incorrect or out of date.

Another area where all companies seem to be deficient to a certain degree is mechanical integrity (MI) [1], which remains a common underlying cause of many incidents.

Although all aspects of PSM deserve attention, these areas should get priority and constant review. The challenge is doing this effectively when a company lacks adequate expertise and only can provide modest if not meager resources.

COPING WITH LIMITED RESOURCES
Ensuring smooth operation of a process facility on a daily basis requires at a minimum:

• Operating procedures. The plant can't run unless operators know what to do.
• Trained operators. Operating procedures provide the basis for training.
• Good maintenance. This minimizes outages and maximizes production.
• Safety practices. Preventing incidents and injuries during regular work demands lockout/tagout, hot work permits and other practices.
• Contractor selection. It's important to use only well-trained and safety-conscious contractors.

A good manager will put resources into these areas without question. Other process-safety-related areas may receive less or no attention because they don't seem necessary to the daily running of the plant. So, how do we maximize process safety with minimum resources when a manager is reluctant to hire people to perform the needed activities?

The way to do it is by integrating process safety into operations by making it a line responsibility of the operations manager. The manager will have to become knowledgeable in what's needed to avoid incidents that could injure people or damage the facility. This doesn't mean the manager will have all the technical details on how to implement the process safety program.

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