Page 25 - CCPS Monograph - Refletions of Global Process Safety Leaders

identifying what we can reasonably audit remotely and virtually and what audit items need to be
done on site. We are not going to just blanket virtual audit. We do not think that is the right thing
to do. So when we are finished with that exercise, we will document it and that is the good faith
effort on what we can do during this time. With PHAs, we have established that the ‘process safety
during a pandemic’ guideline that complements the CCPS monograph, “Risk Based Process Safety
During Disruptive Times”. With that we have given our sites guidance with what they can do during
the PHAs like checklist hazard identification and what needs to be done with the team, in the same
room, such as complex HAZOP with fault trees and event trees. The key is having good
documentation especially with the PHA and the audits.

Q4: During remote PHAs how do you include the operator into the PHA review?

A4 Sandro: Operators are one of the minimum resources that we require. So, we have minimal
staff from the plants including operators and the inspectors, but not necessarily the field operators.
We need to define which are the inspectors who will be there. Normally, it is specialized operators.
Technical Operation or Shift Operators is the name we use in Braskem. So, the inspector could be
someone who could participate from home.

Q5: Are you experiencing a low incident rate?

A5 David: We have seen a small improvement in our Tier 1 and Tier 2 number of incidents on a
global basis. We had Tier 1 event this year, we have 6 Tier 2. So that is a slight improvement over
the previous time frame in 2019. But when I look at the actual root cause failure analysis I don’t
really see anything, in those incidents that relate to the pandemic. They seem to be more
traditional causes and things in that nature. I will say that we had some sites where the
investigation facilitators are typically manufacturing technical engineers or some other personnel
that might be working from home, and not on site. In some cases, where an incident has occurred,
we have asked them to go to the site and act as essential personnel to facilitate that incident
investigation to make sure that we have full quality in an investigation.

Q6: How are you handling the management presence in the field?

A6 Fred: It is something that we had to add back in, after we made our transitions to reduced
staffing levels. So, what we have done at each of our sites is create a person who is leadership’s
“eyes in the field” and they have these checklists that we develop for each site. They report back to
the leaders on numbers of impairments, number of changes made, any movement in our alarm
numbers. We created a dozen questions that we want this person to collect each day to help
leaders understand that the condition of the facility.

Q7: How do you recommend to update or reassess critical or major risk hazard scenarios that may
have changed, during this period of reduced manning, and without meetings? With regard to
fatigue management and API 755, please show linkage to that as well?

A7 Elena: In relation to that API recommends to limit to the service hours. We have changed from 8
to 12. With the risk management limitations, so more supervision is needed. We also try to
minimize distractions. A lot of communication to be aware of the issues, even personal issues, such

24