Many companies miss significant opportunities to take advantage of process hazard analysis (PHA) beyond the narrow confines in which they currently use the technique. In particular, a PHA can provide crucial inputs for a number of strategic considerations. Here, we’ll look at its potential value for:
• Divestitures and acquisitions;
• Multiplant sites;
• Joint venture projects;
• New technologies;
• Differing risk perceptions;
• Information management;
• Cyber-security concerns; and
• Aging plants and legacy controls.
Divestitures And Acquisitions
Divestitures and acquisitions (D&As) probably have occurred for as long as chemicals have been made. D&As should consider not only business-specific issues but also safety and environmental ones. This involves thorough and thoughtful due diligence. Unfortunately, some companies still make high-level decisions without properly assessing the safety and environmental implications of D&As. Some executives, although financially astute, may lack familiarity or appreciation of potential safety liabilities. Safety professionals can make valuable contributions in such cases. Here are some pointers:
• Corporate executives tend to focus on business risk — e.g., market volatility, industry-specific concerns and legal issues. So, how can safety professionals persuade the executives to appreciate safety risk? They certainly should stress that ensuring the safety of workers and neighbors is both a statutory and moral obligation of an organization. Safety professionals must convince the executives that safety makes business sense before, during and after a divestiture or acquisition. To do this effectively, they should make themselves familiar with “business terminology.”
• Perform a PHA prior to the start of “serious talks” about D&As.
• Soon after completion of an acquisition, harmonize the best safety practices of both organizations.
Such locations present unique risks stemming from the interfaces among the plants. Typically, various operations at the site share or exchange utilities and waste management systems such as flares or incinerators. It is important to carefully consider the safety implications. Common problems are:
• Inadequate protocols to deal with management of change at one or more operations on the site;
• Poorly defined criteria to ensure compliance of environmental systems such as flares or incinerators, particularly that they have adequate capacity to deal with “worst-case scenarios” on a site-wide scale;
• Difficulties in adequately protecting workers from exposure to hazardous materials and safeguarding equipment during “loss of containment” events because of tight spacing between the units; and
• Uncoordinated emergency response systems.
Joint Venture Projects
Typically, joint ventures (JVs) involve large projects; so, the importance of clear communications can’t be overstated. Today’s project management tools are well equipped to deal with massive flows of information and interaction in an efficient manner. However, large projects also present issues that could scuttle a PHA. Project sponsors may have widely divergent perceptions of hazards and risk. They also may use different risk assessment systems. Therefore, prior to the start of the PHA, the PHA facilitator should ensure all sponsors agree on risk assessment, documentation and risk management methodologies.
Companies continually adopt new technology — ranging from entire processes to individual elements such as particular instruments. Introducing a new technology creates risks as well as benefits. Doing so on an ad-hoc basis is a risky move. Use a PHA to delve into a number of critical issues:
• Is there safety infrastructure (e.g., trained staff, tools to maintain technology, waste disposal, permitting and vendor support) to manage the new technology?
• What’s the fallback if the technology doesn’t function as expected? For instance, in the event of a major failure, is it possible to revert to the existing technology or systems without incurring unacceptable level of risk?
• Does the technology pose any new potential hazards? The PHA facilitator should inquire about the number of sites where the technology already is used and problems, if any, encountered. Obviously, a brand new technology requires thorough risk-based scrutiny. Several organizations use standard procedures that address the issue of new technology adoption.
Differing Risk Perceptions
Unfortunately, despite the maturing of the PHA process, widely differing risk perceptions still exist, often even within the same assessment team. This may reflect generational differences. Veteran professionals with operations experience, who have had some accidents at their plants, are much more risk-averse than others. Moreover, it’s not that uncommon even today for some members of the PHA group to regard the PHA as an unnecessary step. In addition, tight schedules and work demands may foster pressures to speed through the PHA. The facilitator must appreciate these issues and take steps to address them.