A process safety coordinator could provide the expertise and coordinate all the activities — but isn't an absolute necessity. When a permanent position isn't viable, a plant still can fulfill the needs of a process safety program on a continuous basis. Let's look at how to accomplish this for key aspects:
Mechanical integrity. Many plants are adept at the maintenance component of MI but less so at the inspections component, which requires expertise and continuous application. There are firms that provide this service and also take care of the documentation to satisfy regulatory requirements. For example, use of risk-based inspection can help reduce the resources necessary to maintain a good inspection program. Adding maintenance and testing data to an asset database assists in complying with the required frequency of maintenance, decreases the risk of failure, and can help maintain the integrity of instrumentation vital to safety instrumented systems (SIS).
Management of change. This must be well executed to avoid creating or increasing risk to the facility. An effective MOC program requires few resources if implemented correctly and the proper tools are used. These tools should automatically manage the mechanics of the system, including documenting all actions and storing all information, and provide immediate easy-to-understand feedback (such as via graphics), thus allowing site management to concentrate on the quality of the system. It's important to track the number of open and past-due MOCs because they increase the risk to the facility . You can download a demo of a database that fulfills these requirements .
Process hazards analyses. If a company doesn't have the expertise to perform a PHA, it can hire a facilitator. However, if the PHA is to succeed, the site must ensure an experienced engineer and a veteran operator are given the time to fully participate. Moreover, the plant must immediately address recommendations coming out of the PHA and implement any accepted changes in its work order system. Lingering action items can only increase risk to the facility. This is an area in which, if in-house resources don't suffice, contracting out may be justified. The facility should use the PHA report as a learning tool and check it when doing an MOC to avoid negating a PHA recommendation.
Process safety information. The PSI should build on the maintenance files and existing process and instrumentation drawings (P&IDs). To ease keeping the system current long term, the plant should require good documentation as part of each contracted activity. Updating P&IDs and equipment files usually demands the largest effort to maintain the PSI. The plant also could contract this out if a large number of changes aren't likely. For a site with many changes and limited resources, a document management system could provide the answer [4, 5] — such systems now are within the means of small companies.
Safety culture. Establishing a good safety culture should reduce the effort of managing process safety because everybody will have a responsibility for safety . Integrating process safety into operations and having line management accountable for everyday and long-term safety shows that management is "walking the walk" and not just "talking the talk." In addition, a plant should consider expanding occupational safety programs and activities such as "toolbox" meetings to include the topic of process safety.
Regulations. A plant should run the PSM system not just to comply with regulations but also to enhance safety in the short and long terms. Implementing a good PSM system will lead to satisfying the regulations but the opposite isn't true. Just complying with regulations may not result in a safe plant. A site should judiciously apply recognized and regularly applied good engineering practices (RAGAGEP); their complexity may thwart safety in the absence of sufficient knowledge or resources.
Finally, a plant also must address other, less frequently occurring process safety aspects such as emergency planning, audits and incident investigation. However, they take much less continuing effort (and, if PSM is successful, there should be no incidents to investigate). The plant also can contract out these parts, eliminating the need for local expertise. Of course, personnel will have to be well trained on the emergency plan and participate in the drills.
Lack of resources shouldn't keep a company from implementing an effective PSM system. The guidelines detailed in this article can lead to a well-functioning process safety system that uses fewer resources.
JACK CHOSNEK, PhD, PE, is president and principal of KnowledgeOne, Houston. E-mail him at firstname.lastname@example.org.
1. Mannan, M.S., "Advantages and Pitfalls of Mechanical Integrity Programs," Meridium APM Advisor, Aug. 2011 (online at www.apmadvisor.com).
2. Chosnek, J., "Managing Management of Change," Process Safety Progress, p. 384, Dec. 2010.
3. "The Great MOC Solution," www.knowledge1.net/psm/Downloads.html.
4. Chosnek, J., "Maintaining the Corporate Memory," J. of Loss Prevention in the Process Industries, p. 796, Vol. 23 (2010). Also in Proceedings, Mary Kay O'Connor Process Safety Center Intl. Symp., Oct. 2009.
5. Chosnek, J., "Organizing Knowledge for Improved Process Safety," Proceedings, Mary Kay O'Connor Process Safety Center Intl. Symp., Oct. 2008.
6. Gambrell, M.R., "Make Safety Second Nature," Chemical Processing, p. 29, Oct. 2011.