(54bf) Responsibilities of the Line and Support Organization in the Prevention of Catastrophic Process Safety Events

Many of the leading companies in the chemical, petrochemical, and petroleum process industries have experienced significant incidents in the past 10 years involving injuries, property loss, and even loss of life. These companies operate under OSHA and EPA Process Safety Management (PSM) regulations that were put in place over 25 years ago. Most have robust systems in place to meet regulatory requirements, however, in almost every case, it was found that the incident could have been prevented if PSM had been properly and thoroughly implemented. So the question is, why are important elements of PSM not being completed in a manner that would help prevent an incident? This paper will explore the role of leadership and how when they don’t fulfill their responsibilities the PSM process often fails.

Premise:

1. PSM is a robust process that can prevent incidents when fully implemented. It is well understood, documented, and part of US Federal Regulations.
2. It takes people, cost, and capital to implement PSM. The number of people must be sufficient and they must have the necessary skills, including some with institutional knowledge. Cost and capital must be provided to sustain the process and equipment (both direct and ancillary) within design parameters.
3. Each person in the line organization and staff have specific responsibilities to assure that PSM process requirements are met.
4. Most critical to successful implementation is the line function, since there is control of people, costs, and capital.

Many companies operate with line accountability where leaders, managers, and supervisors are responsible for the actions of the line under them. But, this alone does not address the responsibilities for specific actions of individuals in the line.

A successful PSM program must be supplied with sufficient resources to get the work done. This starts with the budget for people, cost, and capital. Budget setting is a complex process to meet shareholder needs, as well as all regulatory requirements and production demands. In most companies the budget is set at a senior level, often well above the site level. Once the budget is in place, the tasks of monitoring performance and assuring that PSM elements are fully implemented fall upon a line leader. Changing conditions and unexpected demands create a challenge to fully implement the PSM process.

A successful PSM program also requires everyone to meet certain job responsibilities. But what are these responsibilities? What must each person in the line organization and support functions do in order to prevent catastrophic events? Below are examples of responsibilities for individuals in the line organization.

Manufacturing companies can be organized for a successful PSM program in a variety of ways. Below are some examples of the responsibilities for a wide range of levels. The responsibilities described are based on a wide range of businesses, both within and external to DuPont, that have solid PSM programs.

Examples of roles that will be expanded upon in the paper:

Business Leader

• Usually in charge of setting the budget. Conducts an annual (or semi-annual) review of PSM metrics including planned and unplanned personnel changes and contingency plans for key persons identified as being critical to the success of the PSM system. Other issues included are identification and replacement plans of major critical equipment, open PHA and incident recommendations, overdue inspections and tests, and other PSM metrics. Identifies areas that are resource deficient or could become resource deficient, and develops plans to correct.

Plant Manager/General Manager

• Meets with all employees annually in groups appropriate to the size of the organization. Covers a broad range of topics including a general business overview, status of major investments, significant initiatives such as a community outreach program, learnings from incident investigations and site audits, and status of the site employee and process safety management programs. Has the participants submit questions in order to answer some in the meeting and promises all questions will be responded to in an appropriate manner.
• Conducts a physical inspection of the facility. The purpose of this inspection is two-fold, it determines if the facility is “ship shape” and provides an opportunity for interaction with employees. Plant managers should emphasize the importance of following the operator’s rules. They should pick a “cardinal” rule and discuss why the rule is in place and make sure the employee supervisor is part of the discussion.

Some examples of other positions in the line and staff organizations that are critical to the success of implementing a PSM system. These will be further developed in the full paper.

• Process Safety Management Leader
• PSM Element Leaders
• First Line Supervisor
• Capital Project Leaders
• HR Leader Specific Technology Leaders