Process Safety Management Plus or Minus 20 Years - What I Wish I'd Known 20 Years Ago and What We Can't Wait Another 20 Years to Learn
Abstract of proposed presentation to the Global Congress on Process Safety: Houston - April, 2012
Presenter: Alan C. (Al) Brackey, Senior Manager PSM Audit - Valero, San Antonio, TX 78249
Brief Bio: B.S. Chemical Engineering, EIT - Iowa State University, 1979. 33 years experience in chemical, petrochemical and refining processes, including 30 years at large manufacturing facilities (21 years with Celanese) and the last 19 years directly involved in all aspects of Process Safety Management (PSM).
My purpose would be to offer, primarily to those who may be relatively new to PSM, a few thoughts and insights on the “essence” of PSM, distilled from my 33 years in the industry, the past 19 of which have been spent solely as a “boots on the ground” PSM practitioner. It would not be to tell a bunch of war stories, however just so it’s clear that I don’t view PSM as some abstract concept, I would note a few incidents which have directly impacted me and/or others with whom I’ve closely worked over the years:
- Small dust explosion/fire in a fiber handling system. No one got hurt and the event ended up not being much more than a minor interruption. However, later on, one of the managers was in a meeting banging his shoe on the table saying such a thing would never happen again, when the plant alarm sounded and the same thing had happened again.
- Explosion in a reactor piping system led to a major hydrocarbon release, formation of a large vapor cloud that found an ignition source, ignited and exploded. Multiple fatalities/many injuries. Catastrophic damage. Multi-year eight-figure rebuild.
- Reactor explosion while a unit was down for maintenance. Multiple fatalities/many injuries. Catastrophic damage. Significant offsite impact. Multi-year eight-figure rebuild.
- Explosion and fire in a compressor train during a unit startup. One serious injury.
- Major fire due to a hydrocarbon release from failed piping. Significant domino effects. Several serious injuries. Entire plant down for several months. Unit rebuild took about a year.
I would start by making an observation that bad things don’t always happen to somebody else. I believe it to be absolutely critical that none of us ever lose a true “sense of our own vulnerability”.
I would note that the practice of PSM can sometimes be very frustrating, and that I believe there are probably several reasons for that frustration, including:
- OSHA 1910.119 is a performance based regulation, not prescriptive. It states what needs to be done, but for the most part, leaves the how to the user. I would note that we’re now 20 years into it and look at some of the questions that we’re still wrestling with.
- PSM is not “sexy”. We’re always trying to keep that last straw off the camel’s back. Truly, the devil is in the details, and the details touch every aspect of the entire operation.
- We can really never prove a negative, in other words prove that something we did (or money we spent) actually caused something bad not to happen. It’s similar to the challenge that the Department of Homeland Security faces every day. They have to be right every time. The bad guys only have to be right once.
I would then offer a few thoughts on how we might deal with current and future PSM challenges, e.g., (1) continue to emphasize a risk based approach to all key activities, (2) ensure that we have in place effective, functional systems that are not any more complicated than they need to be to get the job done, and (3) never be satisfied with anything less than the flawless execution of those systems.
I would emphasize that all the PSM elements are important and must work together to provide the multiple layers of protection that we rely upon. However, over the years I’ve found that certain elements are sometimes viewed as being the “heart and soul” of PSM. I would offer some brief thoughts on the role and importance of these key elements, both now and into the future:
- Process Safety Information (relief system design, defining safe limits, engineering and administrative controls, safety systems)
- Process Hazards Analysis (consistency of results and risk analyses)
- Operating Procedures (good procedures don’t just happen, role of operating limits)
- Management of Change/Pre Startup Safety Review (one size doesn’t fit all situations or applications, PSSR must ensure all bases are covered including all PSI/procedure changes)
- Mechanical Integrity (risk-based inspection schedules for all safety critical equipment, functional understanding of applicable RAGAGEPs, strong deficiency management systems)
- Management Systems/Performance Audits (not just the 3-year compliance audits - strong, effective monthly, quarterly, or annual management system reviews will drive continuous improvement and dramatically reduce findings from those 3-year compliance audits)
Finally, in closing, I would say that over the past 20 years, the chemical, petrochemical and refining industries have made significant progress toward materially improving their process safety performance. I believe we have a far better grasp on knowing and understanding that which we may not have fully known or understood 20 years ago. But we’re not there yet. And the bar will continue to be raised. I believe it will be up to each one of us, and even more importantly, to those who will follow us in the coming years and decades, to commit that we will (1) always maintain a strong sense of our own vulnerability - bad things don’t always happen to somebody else, (2) continue to emphasize appropriate risk-based approaches to our key process safety activities, and then (3) for those key activities, never be satisfied with anything less than flawless execution.
Admittedly we live and work in a world that allows for very little margin of error. It’s not easy. It’s often tough to prove that something we did really made a difference. Failure, of course, is often immediately obvious. I believe that our motivation must come from the satisfaction in knowing that yes, the things we do, do in fact make a difference, and that difference is that lives are saved, livelihoods are preserved, and our licenses to operate are continually renewed.
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