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Changes Are Coming to Process Safety Management Standards
Posted on July 1st, 2016 by Kenneth Bloch in Chemical Manufacturing Excellence
OSHA regulations establish the requirements for industries to follow in managing the hazards associated with processes using highly hazardous materials.
OSHA introduced its PSM regulations in the 1990s in response to the tragic 1984 Bhopal gas-leak disaster and several deadly domestic incidents that followed. Since then, other countries have adopted measures similar to OSHA’s PSM standard. This global growth in PSM standards has resulted in significant progress in protecting workers, businesses, and communities from catastrophic industrial process failures.
The results, however, have not been perfect. For example, a 2005 refinery explosion in Texas City, Texas, killed 15 workers, injured 170, and caused major property damage. And a 2013 explosion at a fertilizer plant in the town of West, Texas, killed 15 people (mostly emergency responders) and injured more than 200.
Several key factors underlie these and similar industrial safety failures. I’ll address three of them here. The first is cultural defect. In simple terms, a cultural defect is a flaw or imperfection in the way groups of people in a company manage hazards or risk. This flaw usually persists until an incident of significant consequence exposes it. But by the time that this incident occurs, it’s too late to correct the behavior that represents the cultural defect. Examples of these behaviors include a tolerance for running the process either outside of operating limits or contrary to operating procedures.
Tribal knowledge is another factor often involved in catastrophic industrial incidents. Tribal knowledge is the knowledge contained within a group that others must know for the team to operate as a cohesive unit. For example, the interim report covering the LaPorte mercaptan release contains information related to tribal knowledge that was involved in that incident.
The final key factor I want to touch on is the lack of a sense of vulnerability. Creating a protective sense of vulnerability makes engineers and employees appreciate how decisions they make in good conscience — and are backed by valid engineering principles — can lead to situations where there’s no safe way out.
Surprisingly, highly reputable and successful companies are more likely to suffer a catastrophic event. These organizations diligently dictate specific requirements and expectations for regulatory/mandatory/external compliance, but they also encourage a creative approach to achieving voluntary/discretionary/internal compliance. That’s because they want to tap into the skills offered by employees to create a comparative advantage. As a result, an image of outstanding compliance develops, but the company’s support systems are actually experimental and weak.
This paradox reinforces the importance of implementing a prescriptive approach to PSM, which includes meeting requirements involving mechanical integrity, management of change, and safeguard protection (independent protection layer) — just to name a few. The goal: A company’s reputation should reflect the strength of its internal PSM support systems, not simply to prove that it’s in regulatory compliance.
The two disastrous events in Texas, along with the factors that contribute to process release incidents, demonstrate the importance of improving PSM practices globally. In the U.S., federal and state regulators have taken note of these incidents and are poised to overhaul their PSM programs. This will mark the first time any regulatory agency has made significant changes to their core PSM programs. Cal-OSHA has already started the process to make changes in California. Federal regulators have often adopted regulatory standards introduced in California and other states, so and OSHA and EPA are likely to follow Cal-OSHA’s lead and adopt more restrictive requirements.
Although the investigation into the explosion in West, Texas, determined that arson was caused the fire that started the explosion, it’s unlikely that finding will have any impact on the speed or content of pending regulatory changes in the U.S. The basis for increased regulatory action exists despite the ignition source. The U.S. Chemical Safety Board’s final report implies that the incident could have been avoided if current PSM regulations for oil & gas and chemical processing industries had been applicable to ammonium nitrate storage facilities.
The bottom line: The forthcoming changes to PSM standards will have a substantial effect on chemical and oil & gas industries, significantly altering the practices they use to prevent catastrophic process release incidents.
Read more in the best-selling Rethinking Bhopal, A Definitive Guide to Investigating, Preventing, and Learning from Industrial Disasters.
All opinions shared in this post are the author’s own.
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