Customizing an OSHA-compliant PSM system for non-PSM facilities

Process safety insights

• Process safety management (PSM) systems is about continually monitoring and measuring and applying key performance indicators (KPIs) and aggregated safety performance indicators (SPIs).
• Non-PSM facilities can benefit from having one because they reduce company risk and downtime and increase employee health, morale and promote operational excellence.

Large process safety management (PSM)-compliant facilities use the system based on the 14 elements in OSHA’s PSM standard to drive down risk by implementing and maintaining a centralized system.

A methodical and well-planned PSM system detects and eliminates hazards embedded in critical systems, infrastructure, equipment, operating procedures or human error before they turn into catastrophic events.

PSM is about continually monitoring and measuring leading and lagging indicators and applying key performance indicators (KPIs) and aggregated safety performance indicators (SPIs) to ensure the health and quality of the PSM system, especially when modifying or upgrading systems or updating processes and documentation.¹

With a robust PSM system in place, automated processing units are regularly monitored and documented for operational issues to prevent an incident from becoming a major event.

Smaller, non-PSM facilities; however, are not regulated by the same industry codes and standards as larger, PSM facilities due to the degree of risk associated with threshold amounts of highly hazardous chemicals. Smaller facilities also may not have the same level of capital, capacity, technologies, processes, systems and organizational structure to build their own PSM system.

Benefits of a PSM system

There are many benefits a PSM can provide to a facility. These include:

• Power of shared knowledge in a centralized repository (easy access to integrated safety information).

• Reduced company risk/hazards, liability, insurance and equipment replacement costs.

• Reduced employee downtime.

• Decreased employee expenses for worker’s compensation.

• Increased employee health, safety, security and morale.

• Increased productivity, profits, quality and operational and equipment reliability.

• Meets OSHA compliance, which helps reduces scrutiny by government regulators.

• Protects the environment, employee health, safety and security and surrounding communities.

• Promotes operational excellence – maintains company reputation, ESG score, investor confidence and stock price.

• Minimizes risks and liability by identifying layer of protection gaps.

• Instills a proactive approach to process safety management.

• Is a cost effective and efficient methodology for identifying non-regulated facility needs.

A process safety management (PSM) system has 14 elements to help ensure a facility is compliant and safe. Courtesy: Anvil Corporation

Often, these smaller, non-PSM facilities lack industry-specific guidance documents, proper employee safety skills and training, and operating procedures on identifying hazards embedded in systems, infrastructure and equipment. As a result, these smaller non-PSM facilities reach out to industry experts with the technical expertise and knowledge of process safety management systems to help them define, identify the likelihood of, and mitigate their safety risks.

PSM consultants first investigate and identify safety gaps in non-PSM facilities before conducting multiple safety studies and engineering analyses to determine the correct course of action, such as:

• Process hazard (PHA) safety studies (e.g., hazard identification (HAZID) and hazard and operability (HAZOP))

• Risk analysis to identify and prioritize all risk and safety issues and to determine the problem, root causes and consequences. This includes gathering PSIs to identify process nodes and recent facility changes to determine if the changes followed proper management of change (MOC) procedures.

A risk waterfall matrix determines the severity and likelihood of each risk relating to HAZOP and layers of protection analysis (LOPA). A good matrix defines each level as an order of magnitude different than the previous level. For example, a recordable injury is 10 times worse than a first aid incident. In addition, HAZOP and LOPA likelihood results are different in that HAZOP uses subjective terms (i.e., remote) while LOPA results are more quantitative (i.e., once every 1,000 to 10,000 years).

Risk Matrix Levels and Definitions

After developing a corrective course of action that works with their client’s existing safety system and management processes, PSM consultants then work with their clients to document, audit, implement best practices and standardize PSM across their facilities and sites.

PSM plan case study

Demonstrating a PSM plan in action, a team of process safety engineers, including a pipe designer, with recent and applicable OSHA and PSM experience, discover a gathering refinery unit was experiencing piping and pump equipment failure every other month, resulting in additional costs and risking exposing personnel to a hazardous material and possible fatalities.

After the initial meeting with the client, the team of PSM experts conducted a site visit, identified existing PHAs and provided a list of recommendations to include the following:

• Develop a plan to document the existing PHAs and deficiencies.

• Rank the risks.

• Conduct a LOPA gap analysis, identify layers of protection requirements and create a plan to reconcile the gaps.

The resulting studies identified four root causes and six mitigation strategies.

Root causes

1. Outdated maintenance procedures. Maintenance is performed only four times a year when equipment failure is occurring at a rate of 10 times a year.

2. Reliance on institutional knowledge with no formal documentation.

3. Multiple points of failure in the client’s Management of Change (MOC) procedure.

4. Lack of easy access to proper maintenance documentation. Disparate documents are housed in different systems and physical locations.

Mitigation strategy 1: Consistently identify, prioritize and eliminate risks and hazards through engineering controls, administrative controls, and personal protection equipment. Document the PSI for the P&ID’s, pressure safety valve files, SDS’s and design guidelines.

Mitigation strategy 2: Develop a Mechanical Integrity Plan to cover not only the ongoing maintenance of the equipment, but its entire lifecycle including the engineering, construction and spare parts. Mitigation included the following activities:

• Increase inspection frequency from every three months to monthly inspections.

• Capture routine maintenance documentation.

• Plan for obsolescence in the equipment’s lifecycle to prevent failures.

• Correct piping standards and installations.

• Monitor critical equipment.

• Perform leak detection and monitoring.

• Develop equipment checklists and maintenance procedures documentation.

• Train equipment users to understand all modes of the equipment’s operation, whether startup, shutdown or normal operations.

• Maintain operating procedures and instructions with the most current and correct information. Instructions that are outdated, hard to understand, or hard to locate, lead to misinformation which can result in equipment damage, fatalities, schedule slippage, damaged company reputation or litigation.

Mitigation strategy 3: Develop and define the client’s MOC procedure to document all changes to equipment, processes, procedures, chemicals, throughput and training. It is worth noting many larger facilities have MOC software that automatically documents, tracks and stores facility changes and updated process safety information (PSI). The MOC-generated information then becomes the central database for a PSM plan. Understanding smaller facilities often do not have the same resources as larger facilities, safety experts work with clients to build a SharePoint site that becomes the centralized repository for all safety related documents.

Mitigation strategy 4: Gather, consolidate and organize company-wide safety documentation to build a common SharePoint site as a framework to document, audit and update pertinent PSM information, including lessons learned and best practices. The PSM SharePoint site provides the client with company‑wide, easy user access to common and site-specific documentation, including safety protocols, safety training and compliance audits. All clients do is download a PDF for instant access to information.

Mitigation strategy 5: Provide employee education and training on what the PSM system is, how to use it and why it is important. In addition, train process safety gatekeeps on how to maintain the SharePoint site with the latest PSM documents.

Mitigation strategy 6: Follow-up as needed with safety experts to conduct ad hoc compliance audits and/or annual safety refresher training courses to ensure the facilities maintain PSM-compliance by continuing to follow OSHA’s key provisions.

By partnering with PSM consultants, non‑PSM facilities can build and manage a tailored PSM system that:

• Is fully integrated, centralized, customized and auditable.

• Will meet their unique needs and requirements and comply with some, if not all, of OSHA’s PSM elements.

• Will address their technologies, infrastructure, assets, systems and management practices in a companywide PSM culture.

Facilities can then proactively prevent any incidents from occurring by continually monitoring critical systems to ensure they are functioning as intended.

As the first line of defense against catastrophic events, accidents, or life-threatening situations, A well-structured PSM system stands the test of time and is well worth the investment. The ultimate measure of success is when nothing happens because a facility has taken the proper steps to stay ahead of any risk that could threaten plant operations, human safety or the environment and surrounding communities.

References

1. “Processing Safety Management: Going Beyond Functional Safety,” Hydrocarbon Processing, Mar. 2013.

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