Reframing PSM in the Context of Operational Risk Management and ESG Sustainability

The regulatory climate changed considerably following the highly publicized incidents at BP Texas City in 2005, Tesoro Anacortes in 2010, Chevron Richmond in 2012, and ExxonMobil Torrance in 2015. Each happened not due to a failure of equipment, instrumentation, facility siting, operator, procedure, communication, supervision, or training, but rather a failure of all those things together, i.e., a management system failure. In addition to tens of millions of dollars in enforcement actions, legal consequences are now getting personal as was the case for plant management in the aftermath of the 2011 Chevron Pembroke incident. Systemic failures were cited in a May 2019 sentencing hearing at Swansea Crown Court with the plant declared "fundamentally unsafe" due to a series of errors and failings that contributed to a multi-fatality incident.

Companies are now increasingly being asked by investors and external stakeholders to engage in a broader Environmental, Social, Governance (ESG) landscape relative to environmental, health, and safety (EHS) performance, and risk reduction in the context of asset integrity and process safety human factors (the “organizational incident”) is at the core of that expectation. To that end, companies are currently seeking to ensure holistic, enterprise-wide visibility and accountability for dynamic ESG programmatic efforts, materiality assessments, and sustainability solutions.

To date, no data management system or tool exists which effectively converges the highly interlinked EHS, compliance, and enterprise risk platforms with an asset integrity (and performance) predictive analytic framework. To get there, industry must reframe PSM and EHS management systems in the context of “operational risk management (ORM),” i.e., a broader risk reduction management system which more effectively integrates equipment with worker and production process data to better identify, analyze, and control risks at the physical asset level.

As for today’s EHS platforms, they aggregate only a limited amount of data from process safety and environmental workflows - incident reporting, near miss data, safety processes, environmental spills and releases - as necessary to satisfy regulatory compliance reporting requirements. Their inability to effectively integrate asset integrity and equipment-specific RAGAGEP, e.g., risk-based inspection (API 581 RBI), integrity operating windows (API 584 IOWs), fitness for service (API 579 FFS), corrosion control data (API 571 damage mechanisms), equipment specific inspection data, etc., is an impediment to satisfying the full complement of ORM and ESG sustainability expectations. There is clearly a need to move towards a consolidated enterprise information management platform architecture which consists of risk reduction solutions and decision support functionality by “giving voice to equipment.”

Process plants are built around a myriad of machine and equipment assets like pumps, compressors, heat exchangers, piping, vessels, control valves and instrumentation, with the integrity of those assets being key to properly managing plant reliability and process safety risk. Given the demands of PSM program elements like mechanical integrity, hazard assessment, procedures, change management, incident investigation, and information management, it can be difficult for plant personnel to keep up. Today’s digital transformation movement coupled with analytic tools holds the promise to help.

The convergence of information technology (IT) and operations technology (OT) data has been greatly facilitated by the proliferation of low-cost sensors and internet-protocol-enabled devices. Connecting people, processes, and equipment is the next wave of the industrial revolution which has been called the Industrial IoT (IIoT), or Industry 4.0. It is here, and it will be the early adopters who gain the competitive advantage in this new frontier.

So, I propose a reframing of PSM and EHS management systems in the context of Operational Risk Management (ORM) and ESG sustainability. At a minimum, I would establish a common framework for assessing asset integrity and process safety management system (SMS) effectiveness and maturity with the following requirements:

• Analytics and KPI benchmarking specific to asset integrity, performance, and process safety
• System for categorizing, prioritizing, and risk ranking by economic impact/lost profit opportunity
• Enabling problem solving teams to resolve high value deep-dive systemic problems
• Failure modes decision support functionality
• IIoT data-driven predictive modeling capability
• KPI reporting, alerts/notifications, and action planning

With predictive analytics at the core of an asset integrity and process safety management framework, this paper discusses methods, metrics, performance analyses, KPIs and benchmarking techniques for driving ORM and ESG sustainability as they relate to the ultimate concern of any PSM program, i.e., loss of primary containment and associated impacts to production, profitability, and process safety.