UNDER Investigation: Wanted, Missing Rbps Elements

When the 20 elements of CCPS Risk Based Process Safety (RBPS) were published in 2007, they represented a major improvement in risk management over the 14 elements of the OSHA Process Safety Management (PSM) regulation. Not only were several additional elements added, but the scope of many of those elements common with OSHA PSM were broadened. The author has successfully applied RBPS to facilities in countries that do not have process safety regulations, and to industries in the USA that are not covered by OSHA PSM. The author has also previously presented a paper on additional elements that could broaden the scope of RBPS further to promote and drive greater risk reduction where appropriate.

World-wide facility incident investigation audits have frequently identified that symptoms and events were stated as the root cause(s). This failure to identify the true underlying root causes often resulted in recommendations that were unlikely to prevent recurrence of the subject incident. To assist companies in correctly identifying the underlying root causes, the author has developed a root cause analysis (RCA) technique that not only systematically drives the RCA to the fundamental underlying management system weaknesses, but also covers occupational safety, health, and environment (SHE); the 20 elements of RBPS, plus some of the additional elements from the author’s previous paper, such as human factors, and engineering project phases. This paper describes the issues and solutions in detail with examples illustrated from the RCA technique.