Successfully Reduce Process Safety Events — Part 2

Consider three programs that have proven effective at Dow

By John Champion, Sheila Van Geffen and Lynnette Borrousch, The Dow Chemical Co.

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The first article in this series ("Successfully Reduce Process Safety Events — Part 1") introduced Dow’s program for reducing process safety incidents (PSIs) based on the concepts presented by Vaughen and Klein [1]. It illustrated the idea of leadership at all levels and described two programs associated with our operational discipline systems: cardinal rules and training to maintain corporate memory. Here, we cover three more programs that play an important part in our day-to-day success in preventing incidents; these involve using a process safety focal point (PSFP); recording near-misses; and doing root cause investigation (RCI) and sharing of learnings.

Process Safety Focal Point

Dow has found that designating within an organization a specific PSFP role — tasked with raising awareness of process safety at the facility level — provides a focus to the process safety management systems as well as support necessary to ensure process safety requirements are met. In practice, each operating facility assigns an individual to be PSFP. This person — a senior plant engineer, who assumes the role while retaining current duties — is the key resource on technical issues relating to process safety for the particular production, site logistics or environmental unit. The PSFP works closely with the technology experts to provide proper interpretation and guidance on process safety requirements and practices.

Core responsibilities of the PSFP include:

• performing process safety reviews as part of the management-of-change (MOC) procedure at the facility and calling in experts for further review where required;
• facilitating gap assessments against Dow mandatory requirements and local regulatory standards and working with plant leadership to gain resources to close identified gaps;
• participating in and helping to prepare for RCIs, reactive chemical process hazard analyses and other process safety requirements as necessary;
• maintaining the process safety documentation for the facility;
• working with the maintenance group to review mechanical integrity and instrumented-protective-system test and inspection results and following up as needed;
• assisting in developing plant, business and site process safety goals and assessing progress or defining opportunities to achieve performance goals;
• supporting the development and delivery of process safety training in the facility;
• ensuring the reporting and investigating of process safety near-misses (PSNMs) and process safety and containment events; and
• actively engaging in geographic or business PSFP networks and communication meetings to share best practices and “Learning Experience Reports” (LERs).

Dow has a number of process safety networks for sharing knowledge on technology as well as recent learnings. Business and technology networks include technology center representatives and all the PSFPs for the business globally. Site and geographic networks include local representatives and all the PSFPs from that geography.

The objectives of these networks are to:

• sustain a high level of process safety knowledge within Dow manufacturing by sharing best practices and innovative approaches to managing hazards;
• provide interpretation and guidance on process safety requirements and practices;
• share process safety and containment learnings as well as near-misses to minimize the probability of occurrence; and
• enable a structured approach to developing the knowledge of PSFPs and other network members on the technology of process safety.

Process Safety Near-Misses

Major PSIs in chemical manufacturing are infrequent. However, when they do occur, the consequences can be severe. For example, the Deepwater Horizon oil rig explosion and oil spill (Apr. 2010) [2], Imperial Sugar Refinery dust explosion (Oct. 2009) [3] and BP Texas City Refinery vapor cloud explosion (Mar. 2005) [4] significantly impacted human life and the environment and received extensive coverage by the media.

Corporate performance goals often are measured in such a way that a plant could operate for many years without a major process accident while still not meeting an acceptable level of performance. That’s why paying attention to near-misses — i.e., events in which an accident involving a chemical process was narrowly avoided — is important [5, 6]. PSNM reporting is intended to be a more sensitive indicator of actual performance. The value of such reporting is not in the counting of events but rather in the ability to recognize the potential for an accident, the opportunity to identify and implement corrective actions and the prospect to gain knowledge that may prevent future accidents.

In 2009, Dow began to emphasize PSNM reporting globally as a key leading indicator of performance. The general principles that apply to PSNM reporting are:

• The event must directly involve a chemical or chemical process.
• A failure must occur.
• There is a learning value (taking into consideration both the actual and potential severity of the event).

Facilities report and investigate PSNM incidents to discover and eliminate their potential causes. Dow considers a high number of PSNMs reported as a positive indicator — because we believe that investigating and eradicating the sources of near-misses also will remove the underlying causes of potential incidents before they happen.

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