Process Safety: Are You Managing Your Hazards or Managing Your Activities?

In process safety, the key protection layers against major accident hazard scenarios are often the small details such as the correct setting on a trip system, being able to recognise and respond to a critical alarm in the face of the other control room distractions, and strictly adhering to the few key process safety related steps in a complex procedure.   Ensuring that these key details are clearly identified, understood and kept intact through the design, installation, and operating phases of the process safety lifecycle can be challenging.

One reason for the difficulty is that process safety management frameworks are often built around delivering specific activities such as process hazard reviews, SIL assessments, incident investigations, training material development, and reviewing and updating operating procedures.  These activities are done by different people in different departments at different times.  The critical details or understanding can easily be lost in the transitions between the activities or the departments responsible for them.  This can result in the whole being less than the sum of the parts, and the all too common management question “why do we keep having these incidents after all the time and resources we put into process safety?”

This paper outlines a framework for focusing on ‘hazard management’ rather than ‘activity management’.  With this approach, the key information on the hazards and the required mitigations becomes the central focus, and all of the supporting activities either feed into developing this information, or use this information as a basis for setting up the maintenance and operating information and systems.  This provides clear links between the related activities and work processes and maintains the integrity of the information, keeping it ‘evergreen’.  The framework can be further strengthened by a process safety auditing protocol (also addressed in the paper) which not only identifies gaps in the protection layers, but also the gaps in linkages between the different activities or in the activities themselves.

Shifting the management framework to emphasize hazards rather than processes should result in fewer incidents through improved operational awareness and maintenance of protection layers.  In addition, the supporting activities will be much better aligned, utilising resources more efficiently by reducing duplication and rework.