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Prepare Yourself for PSM Modernization
Posted on May 20th, 2016 by Kenneth Bloch in Chemical Manufacturing Excellence
Those of us who are sensitive to developments in the chemical and downstream oil & gas processing industries are well-aware that serious changes are underway. Most notable among these are regulatory changes in process safety management (PSM). PSM changes are already being implemented in the state of California (USA). Based on agency activities observed since 2014, we also know that more widespread changes are in store over the next few years. Eventually, international companies representing the chemical and oil & gas processing industries will adopt these changes or variations of them – we can be sure of that. That is how today’s version of PSM has proliferated.
It is no mystery why the United States Chemical Safety Board has listed “PSM Modernization” as its most wanted safety improvement. The truth is that over the past decade, industry has not earned bragging rights over matters related to process containment. Serious loss of primary containment (LOPC) incidents are a recurring theme throughout the chemical and oil & gas processing industries. Despite PSM’s growth to maturity over the past forty years, fatal industrial accidents worthy of being recorded as a worst case scenario occur more frequently than once every two years. All would agree that this level of performance is not acceptable. Something is wrong. For some reason, PSM still seems very foreign to us. In the face of what will likely amount to substantial changes it appears we are still getting acquainted with the stranger known as PSM.
The truth is that process safety has been a recognized concept since the industrial revolution. But it was not until the Bhopal disaster in December 1984 that it received universal attention. With that particular incident, PSM’s case for action became fully transparent. That incident taught industry that a catastrophic process release could threaten the survival of an entire manufacturing enterprise. No matter how strong and permanent a company’s image might appear to be, it can never afford to develop bad reputation. Therefore, it became a priority within the chemical and oil & gas processing industries to invest deeply in PSM. In doing so it might be possible to preserve a reputation worthy of retaining manufacturing privileges indefinitely.
With regard to maintaining a good reputation, history’s record of Union Carbide, the company whose name is imprinted on the Bhopal disaster, has not been kind. Unanswered questions about decisions and actions involved in the process release left us with the impression of a company that did not deserve manufacturing privileges. Here on the surface was a company that appeared to be compliant in every way. They were the number one chemical manufacturer in the world. Union Carbide’s competitors could only dream about building a track record of similar success. It was a track record reserved for a company that attracted the finest talent. A company recognized for its relentless pursuit of humanitarian goals by inventing products that protected both health and the environment. The company was noted for its consistent introduction of advanced molecular technology that still thrives today. Among these technological advancements was the revolutionary pesticide that replaced DDT upon being exposed as an environmental menace. Ironically, the process used to manufacture this product was the source of the incident involved in the company’s downfall.
Up until recently I remember feeling content knowing that the Bhopal disaster was Union Carbide’s death sentence. That fate seemed deserving of a company guilty of deliberate acts of corporate misconduct. For instance, they recklessly disabled a refrigeration system that might have prevented the Bhopal disaster. To me, this contradiction meant that Union Carbide had been engaged in an act of industrial deception that would make even Volkswagen blush. Hidden beneath their pious exterior were irresponsible decisions that no other company in the history of the chemical processing industry would dare ever make – not in their time nor the time we operate in today. At least that was what I believed until 2011.
In 2011 I was asked to prepare a paper for a process safety conference about the application of basic process hazard analysis (PHA) principles. Having been given the flexibility to select a topic of my choice, I decided to analyze the section of the manufacturing process directly involved in the Bhopal disaster by applying the process safety principles made popular by the incident. The study’s purpose was to assess the effectiveness of modern methods used to prevent similar incidents today. What would history be like if our current implementation of PSM had been in place before the Bhopal disaster? Would we have identified hazards that would need to be addressed before commissioning that process? Or would we be confident that the system, as it was designed, would provide an adequate level of process safety through its useful life – perhaps even into our day?
At the end of the study I had amassed more material than would fit in a paper alone. The complete analysis is documented in Rethinking Bhopal: a definitive guide to investigating, preventing, and learning from industrial disasters, to be published in June 2016. All royalties from that book are for a scholarship made available to science and engineering students that make process safety their priority. Process safety is the key to productivity. That is only one of the major lessons illustrated by the case study. The sooner that students understand this, the safer and more profitable industry will be.
The totality of what I learned was far more than what I bargained for. By analyzing the actions of this once-prolific company I learned something very disturbing about myself. I discovered that the senseless decisions uncovered by the Bhopal disaster are exactly the same ones that I would make today under the same circumstances. In all honesty, I too would have shut down the refrigeration system that was designed to operate nonstop. That decision was driven by safety; not for money. I also came to appreciate how technical principles that still govern the industrial processes we operate today support that decision. In other words, my credibility as an oil & gas industry professional would rightfully be challenged if, under the same circumstances, I had disagreed with that decision. I would not have been acting in accordance with my knowledge about basic industrial safety principles that keep us safe even in our time. I would have gone right along with that decision – as flawed as it was – convinced that I was doing the right thing.
Only by detecting your personal involvement in mistakes like this is it possible to avoid repeating them. It is a very powerful safety lesson for me. It is in front of me every day from the moment I walk into the factory until the time I return home.
To hear more, join me next Thursday, May 26th at a webinar, hosted by Elsevier R&D Solutions, focused on PSM Preparedness. Register now to attend the session live or get access to the recording: https://attendee.gotowebinar.com/register/4098320014991693828
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