5/6/23, 11:04 AM Developing a Process Safety Management Programme

Saturday, 26 February 2011 17:23

Developing a Process Safety Management Programme

Written By: Kraus, Richard S.

Whenever there are processes that use temperature and pressure to change the molecular structure or create
new products from chemicals, the possibility exists for fires, explosions or releases of flammable or toxic liquids,
vapours, gases or process chemicals. The control of these undesired events requires a special science called
process safety management. The terms process safety and process safety management are most commonly
used to describe the protection of employees, the public and the environment from the consequences of
undesirable major incidents involving flammable liquids and highly hazardous materials. According to the United
States Chemical Manufacturers’ Association (CMA), “process safety is the control of hazards which are caused
by maloperation or malfunction of the processes used to convert raw materials into finished products, which may
lead to the unplanned release of hazardous material” (CMA 1985).

Industry and labour process safety involvement

Process safety technology has played an important role in the chemical processing industries so that handling
flammable and combustible liquids and gases could proceed without undesirable consequences. During the
1980s, the oil and gas industries, for example, recognized that process safety technology alone, without process
safety management, would not prevent catastrophic incidents. With this in mind, a number of industry
associations, such as, in the United States, the Center for Chemical Process Safety (CCPS), the American
Petroleum Institute (API) and the Chemical Manufacturers' Association (CMA), initiated programmes to develop
and provide process safety management guidelines for use by their members. As stated by the CCPS, "The
evolution of process safety from a purely technical issue to one that demanded management approaches was
essential to continued process safety improvement".

The CCPS was formed in 1985 to promote the improvement of process safety management techniques among
those who store, handle, process and use hazardous chemicals and materials. In 1988, the Chemical
Manufacturer's Association (CMA) initiated its Responsible Care® programme outlining each member company's
commitment to environmental, health and safety responsibility in managing chemicals.

In 1990, the API initiated an industry-wide programme entitled, STEP-Strategies for Today's Environmental
Partnership, with the intention of improving the oil and gas industry's environmental, health and safety
performance. One of the seven strategic elements of the STEP programme covers petroleum operating and
process safety. The following documents are examples of some of the materials developed as a result of the
STEP programme which provide guidance to the oil and gas industry to help prevent the occurrence or minimize
the consequences of catastrophic releases of flammable liquids and vapours or hazardous process materials:

Management of Process Hazards (RP 750)

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RP 750 covers the management of hydrocarbon process hazards in design, construction, start-up, operations,
inspection, maintenance and facility modifications. It applies specifically to refineries, petro-chemical plants and
major processing facilities that use, produce, process or store flammable liquids and toxic processing chemicals
in quantities above certain hazardous amounts (as defined therein).

Management of Hazards Associated with Location of Process Plant Buildings (RP 752)

RP 752, co-developed by API and CMA, is intended to help identify process plant buildings of concern,
understand the potential hazards related to their location within the process facility and manage the risk of fire,
explosion and toxic releases.

Management Practices, Self-assessment Process, and Resource Materials (RP 9000)

RP 9000 provides resource materials and self assessment methodology to measure progress in implementing
process safety management elements.

Examples of other organizations which have developed materials and programmes providing guidance covering
chemical process safety management include, but are not limited to, the following:

Organizations Resource Counselors' (ORC) report, Process Hazards Management of Substances with
Catastrophic Potential
National Petroleum Refiners Association (NPRA), BEST (Building Environmental Stewardship Tools)
programme
International Labour Organization (ILO), Code of Practice on the Prevention of Major Accident Hazards
International Chamber of Commerce (ICC), Charter for Sustainable Development.cmp01ce.doc

The process design and technology, changes in the process, materials and changes in materials, operations and
maintenance practices and procedures, training, emergency preparedness and other elements affecting the
process must all be considered in the systematic identification and evaluation of hazards so as to determine
whether or not they have the potential to lead to a catastrophe in the workplace and surrounding community.

Beginning in the early 1980s, a number of serious major incidents occurred in the petroleum and chemical
industries involving highly hazardous materials, which resulted in considerable numbers of fatalities and injuries
and significant property losses. These incidents provided the impetus for government agencies, labour
organizations and industry associations throughout the world to develop and implement codes, regulations,
procedures and safe work practices directed toward the elimination or mitigation of these undesirable events,
through the application of the principles of process safety management. They are discussed more fully in the
Disasters, natural and technological chapter and elsewhere in this Encyclopaedia.

In response to public concern over the potential hazards of chemicals, governments and regulatory agencies
throughout the world initiated programmes which required manufacturers and users to identify hazardous
materials in the workplace and inform employees and consumers of the hazards presented by their manufacture,
use, storage and handling. These programmes, which covered emergency preparedness and response, hazard
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recognition, product knowledge, control of hazardous chemicals and reporting of toxic releases, included
hydrocarbon processing.

Process Safety Management Requirements

Process safety management is an integral part of the overall chemical processing facility safety programme. An
effective process safety management programme requires the leadership, support and involvement of top
management, facility management, supervisors, employees, contractors and contractor employees.

Components to be considered when developing a process safety management programme include:

Interdependent continuity of operations, systems and organization

Management of information. The process safety management programme relies upon providing availability
and access to good records and documentation.
Control of process quality, deviations and exceptions and alternate methods
Management and supervisory accessibility and communications. Because process safety management is the
basis for all safety efforts within the facility, managerial, supervisory and employee responsibility and
accountability should be clearly delineated, communicated and understood in order for the programme to
work.
Goals and objectives, compliance audits and performance measurement. Prior to implementation, it is
important to establish both long-term and short-term goals and objectives for each of the elements of the
process safety management programme.

Elements of the Process Safety Management Programme

All chemical facility process safety management programmes cover the same basic requirements, although the
number of programme elements may vary depending on the criteria used. Regardless which government,
company or association source document is used as a guide, there are a number of basic requirements which
should be included in every chemical process safety management programme:

process safety information

employee involvement
process hazard analysis
management of change
operating procedures
safe work practices and permits
employee information and training
contractor personnel
pre-startup safety reviews
design quality assurance
maintenance and mechanical integrity

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emergency response
periodic safety audits
process incident investigation
standards and regulations
trade secrets.

Process safety information

Process safety information is used by the process industry to define critical processes, materials and equipment.
Process safety information includes all available written information concerning process technology, process
equipment, raw materials and products and chemical hazards before conducting a process hazard analysis.
Other critical process safety information is documentation relating to capital project reviews and design basis
criteria.

Chemical information includes not only the chemical and physical properties, reactivity and corrosive data and
thermal and chemical stability of chemicals such as hydrocarbons and highly hazardous materials in the process,
but also the hazardous effects of inadvertently mixing different incompatible materials. Chemical information also
includes that which may be needed to conduct environmental hazard assessments of toxic and flammable
releases and permissible exposure limits.

Process technology information includes block flow diagrams and/ or simple process flow diagrams as well as
descriptions of the chemistry of each specific process with the safe upper and lower limits for temperatures,
pressures, flows, compositions and, where available, process design material and energy balances. The
consequences of deviations in the process and materials, including their effect on employee safety and health,
are also determined. Whenever processes or materials are changed, the information is updated and re-evaluated
in accordance with the facility’s management of change system.

Process equipment and mechanical design information includes documentation covering the design codes
employed and whether or not equipment complies with recognized engineering practices. A determination is
made as to whether existing equipment which was designed and constructed in accordance with codes,
standards and practices no longer in general use is maintained, operated, inspected and tested to assure
continued safe operation. Information on materials of construction, piping and instrument diagrams, relief system
design, electrical classification, ventilation design and safety systems is updated and re-evaluated when changes
occur.

Employee involvement

Process safety management programmes should include employee participation in the development and conduct
of process safety analyses and other elements of the programme. Access to process safety information, incident
investigation reports and process hazard analyses is usually provided to all employees and contractor

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employees working in the area. Most industrialized nations require that workers be systematically instructed in
the identification, nature and safe-handling of all chemicals to which they may be exposed.

Process hazard analysis

After the process safety information is compiled, a thorough and systematic multi-disciplinary process hazard
analysis, appropriate to the complexity of the process, is conducted in order to identify, evaluate and control the
hazards of the process. Persons performing the process hazard analysis should be knowledgeable and
experienced in relevant chemistry, engineering and process operations. Each analysis team normally includes at
least one person who is thoroughly familiar with the process being analysed and one person who is competent in
the hazard analysis methodology being used.

The priority order used to determine where within the facility to begin conducting process hazard analyses is
based on the following criteria:

extent and nature of the process hazards

number of potentially affected workers
operating and incident history of the process
age of the process.

A number of methods for conducting process safety analyses are used in the chemical industry.

The “what if?” method asks a series of questions to review potential hazard scenarios and possible
consequences and is most often used when examining proposed modifications or changes to the process,
materials, equipment or facility.

The “checklist” method is similar to the “what if?” method, except that a previously developed checklist is used
which is specific to the operation, materials, process and equipment. This method is useful when conducting pre-
startup reviews upon completion of initial construction or following major turnarounds or additions to the process
unit. A combination of the “what if?” and “checklist” methods is often used when analysing units that are identical
in construction, materials, equipment and process.

The hazard and operability (HAZOP) study method is commonly used in the chemical and petroleum industries.
It involves a multi-disciplinary team, guided by an experienced leader. The team uses specific guide words, such
as “no”, “increase”, “decrease” and “reverse”, which are systematically applied to identify the consequences of
deviations from design intent for the processes, equipment and operations being analysed.

Fault tree/event tree analyses are similar, formal deductive techniques used to estimate the quantitative
likelihood of an event occurring. Fault tree analysis works backward from a defined incident to identify and
display the combination of operational errors and/ or equipment failures which were involved in the incident.
Event tree analysis, which is the reverse of fault tree analysis, works forwards from specific events, or sequences

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of events, in order to pinpoint those that could result in hazards, and thereby calculate the likelihood of an event’s
sequence occurring.

The failure mode and effects analysis method tabulates each process system or unit of equipment with its failure
modes, the effect of each potential failure on the system or unit and how critical each failure could be to the
integrity of the system. The failure modes are then ranked in importance to determine which is most likely to
cause a serious incident.

No matter which method is used, all chemical process hazard analyses consider the following:

process location, siting and hazards of the process

identification of any prior incident or near miss with potential catastrophic consequences
engineering and administrative controls applicable to the hazards
interrelationships of controls and appropriate application of detection methodology to provide early warnings
consequences of human factors, facility siting and failure of the controls
consequences of safety and health effects on workers within areas of potential failure.

Management of change

Chemical process facilities should develop and implement programmes which provide for the revision of process
safety information, procedures and practices as changes occur. Such programmes include a system of
management authorization and written documentation for changes to materials, chemicals, technology,
equipment, procedures, personnel and facilities that affect each process.

Management of change programmes in the chemical industry, for example, include the following areas:

change of hydrocarbon process technology

changes in facility, equipment or materials (e.g., catalysts or additives)
management of change personnel and organizational and personnel changes
temporary changes, variances and permanent changes
enhancement of process safety knowledge, including:

technical basis for proposed change

impact of change on safety, health and environment
modifications to operating procedures and safe work practices
modifications required to other processes
time required for the change
authorization requirements for the proposed change
updating documentation relating to process information, operating procedures and safety practices
required training or education due to change

management of subtle change (anything which is not replacement in kind)

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non-routine changes.

The management of change system includes informing employees involved in the process and maintenance and
contractor personnel whose tasks would be affected by any changes of the changes and providing updated
operating procedures, process safety information, safe work practices and training as needed, prior to the startup
of the process or affected part of the process.

Operating procedures

Chemical processing facilities must develop and provide operating instructions and detailed procedures to
workers. Operating instructions should be regularly reviewed for completeness and accuracy (and updated or
amended as changes occur) and cover the process unit’s operating limits, including the following three areas:

1. consequences of deviation
2. steps to avoid or correct deviation
3. functions of safety systems related to operating limits.

Workers involved in the process have access to operating instructions covering the following areas:

initial startup (startup after turnarounds, emergencies and temporary operations)

normal startup (normal and temporary operations and normal shutdown)
emergency operations and emergency shutdown
conditions under which emergency shutdown is required and assignment of shutdown responsibilities to
qualified operators
non-routine work
operator-process and operator-equipment interface
administrative controls vs. automated controls.

Safe work practices

Chemical process facilities should implement hot-work and safe work permit and work order programmes to
control work conducted in or near process areas. Supervisors, employees and contractor personnel must be
familiar with the requirements of the various permit programmes, including permit issuance and expiration and
appropriate safety, materials handling and fire protection and prevention measures.

The types of work included in typical chemical facility permit programmes include the following:

hot work (welding, hot tapping, internal combustion engines, etc.)

lockout/tagout of electrical, mechanical, pneumatic energy and pressure

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confined-space entry and use of inert gas

venting, opening and cleaning process vessels, tanks, equipment and lines
control of entry into process areas by non-assigned personnel.

Chemical facilities should develop and implement safe work practices to control potential hazards during process
operations, covering the following areas of concern:

properties and hazards of materials, catalysts and chemicals used in the process
engineering, administrative and personal protection controls to prevent exposures
measures to be taken in event of physical contact or exposure with hazardous chemical
quality control of raw materials, catalysts and inventory control of hazardous chemicals
safety and protection system (interlock, suppression, detection, etc.) functions
special or unique hazards in the workplace.

Employee information and training

Chemical process facilities should use formal process safety training programmes to train and educate
incumbent, reassigned and new supervisors and workers. The training provided for chemical process operating
and maintenance supervisors and workers should cover the following areas:

required skills, knowledge and qualifications of process employees

selection and development of process related training programmes
measuring and documenting employee performance and effectiveness
design of process operating and maintenance procedures
overview of process operations and process hazards
availability and suitability of materials and spare parts for the processes in which they are to be used
process start-up, operating, shut-down and emergency procedures
safety and health hazards related to the process, catalysts and materials
facility and process area safe work practices and procedures.

Contractor personnel

Contractors are often employed in chemical processing facilities. The facilities must institute procedures to
assure that contractor personnel performing maintenance, repair, turnaround, major renovation or specialty work
are fully aware of the hazards, materials, processes, operating and safety procedures and equipment in the area.
Periodic evaluations of performance are made to assure that contractor personnel are trained, qualified, follow all
safety rules and procedures and are informed and aware of the following:

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potential fire, explosion and toxic release hazards related to their work
plant safety procedures and contractor safe work practices
emergency plan and contractor personnel actions
controls for contractor personnel entry, exit and presence in process areas.

Pre-startup safety reviews

Pre-startup process safety reviews are conducted in chemical plants prior to startup of new process facilities and
introduction of new hazardous materials or chemicals into facilities, following a major turnaround and where
facilities have had significant process modifications.

The pre-startup safety reviews assure the following have been accomplished:

construction, materials and equipment are verified as in accordance with design criteria
process systems and hardware, including computer control logic, have been inspected, tested and certified
alarms and instruments are inspected, tested and certified
relief and safety devices and signal systems are inspected, tested and certified
fire protection and prevention systems are inspected, tested and certified
safety, fire prevention and emergency response procedures are developed, reviewed, in place and are
appropriate and adequate
startup procedures are in place and proper actions have been taken
a process hazard analysis has been performed and all recommendations addressed, implemented or
resolved and actions documented
all required initial and/ or refresher operator and maintenance personnel training, including emergency
response, process hazards and health hazards, is completed
all operating procedures (normal and upset), operating manuals, equipment procedures and maintenance
procedures are completed and in place
management of change requirements for new processes and modifications to existing processes have been
met.

Design Quality Assurances

When new processes or major changes to existing processes are undertaken, a series of process safety design
reviews are normally conducted before and during construction (prior to the pre-startup review). The design
control review, conducted just before plans and specifications are issued as “final design drawings”, covers the
following areas:

plot plan, siting, spacing, electrical classification and drainage

hazards analysis and process chemistry design
project management requirements and qualifications
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process equipment and mechanical equipment design and integrity

piping and instrument drawings
reliability engineering, alarms, interlocks, reliefs and safety devices
materials of construction and compatibility.

Another review is normally conducted just prior to the start of construction covering the following:

demolition and excavation procedures

control of raw materials
control of construction personnel and equipment on facility and site
fabrication, construction and installation procedures and inspection.

One or more reviews are usually conducted during the course of construction or modification to assure the
following areas are in accordance with design specifications and facility requirements:

materials of construction provided and used as specified

proper assembly and welding techniques, inspections, verifications and certifications
chemical and occupational health hazards considered during construction
physical, mechanical and operational safety hazards considered during construction and facility permit and
safety practices followed
interim protective and emergency response systems provided and working.

Maintenance and mechanical integrity

Process facilities have programmes to maintain ongoing integrity of process-related equipment, including
periodic inspection, testing, performance maintenance, corrective action and quality assurance. The programmes
are intended to assure that mechanical integrity of equipment and materials is reviewed and certified and
deficiencies corrected prior to startup, or provisions made for appropriate safety measures.

Mechanical integrity programmes cover the following equipment and systems:

pressure vessels and storage tanks

emergency shutdown and fire protection systems
process safeguards such as relief and vent systems and devices, controls, interlocks, sensors and alarms
pumps and piping systems (including components such as valves)
quality assurance, materials of construction and reliability engineering
maintenance and preventive maintenance programmes.

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Mechanical integrity programmes also cover inspection and testing of maintenance materials, spare parts and
equipment to assure proper installation and adequacy for the process application involved. The acceptance
criteria and frequency of inspections and tests should conform with manufacturers’ recommendations, good
engineering practices, regulatory requirements, industry practices, facility policies or prior experience.

Emergency Response

Emergency preparedness and response programmes are developed to cover an entire process facility and to
provide for hazard identification and assessment of potential process hazards. These programmes include
training and educating employees and contractor employees in emergency notification, response and evacuation
procedures.

A typical process facility emergency preparedness programme complies with applicable company and regulatory
requirements and includes the following:

distinctive employee and/ or community alarm or notification system

preferred method of internal reporting of fires, spills, releases and emergencies
requirements for reporting process-related incidents to appropriate government agencies
emergency shutdown, evacuation, procedures to account for personnel, emergency escape procedures,
vehicle and equipment removal and route assignments
emergency response and rescue procedures, duties and capabilities including employees, public safety,
contractors and mutual aid organizations
procedures for handling small spills or releases of hazardous chemicals
procedures for providing and safeguarding emergency power and utilities
business continuation plans, personnel and equipment sources
document and record preservation, site security, cleanup, salvage and restoration.

Periodic safety audits

Many process facilities use self-evaluation process safety management audits to measure facility performance
and assure compliance with internal and external (regulatory, company and industry) process safety
requirements. The two basic principles of conducting self evaluation audits are: gathering all of the relevant
documentation covering process safety management requirements at a specific facility and determining the
programme’s implementation and effectiveness by following up on their application in one or more selected
processes. A report of the audit findings and recommendations is developed and facility management maintains
documentation which notes how deficiencies had been corrected or mitigated, and if not, reasons why no
corrective action had been taken.

Compliance audit programmes in hydrocarbon process facilities cover the following areas:

establishment of goals, schedule and methods of verification of findings prior to the audit

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determination of the methodology (or format) to be used in conducting the audit, and develop appropriate
checklists or audit report forms
readiness to certify compliance with government, industry and company requirements
assignment of knowledgeable audit teams (internal and/ or external expertise)
prompt responses to all findings and recommendations and documentation of actions taken
maintenance of a copy of at least the most recent compliance audit report on file.

Facility and process unit specific checklists are often developed for use when conducting process safety audits
which cover the following items:

orientation and process safety management programme overview

preliminary walk-around through the refinery or gas processing facility
process facility documentation review
“prior incidents” and near misses (in the process facility or specific unit)
determination and review of selected process units to be audited
process unit construction (initial and subsequent modifications)
process unit chemistry hazards (feedstocks, catalysts, process chemicals, etc.)
process unit operations
process unit controls, reliefs and safety systems
process unit maintenance, repair, testing and inspection
process unit-related training and employee involvement
process facility management of change programme, implementation and effectiveness
process fire protection and emergency notification and response procedures.

Because the objectives and scope of audits can vary, the compliance audit team should include at least one
person knowledgeable in the process being audited, one person with applicable regulatory and standards
expertise and other persons with the skills and qualifications necessary for conducting the audit. Management
may decide to include one or more outside experts on the audit team due to lack of facility personnel or
expertise, or because of regulatory requirements.

Process incident investigation

Process facilities have established programmes to thoroughly investigate and analyse process-related incidents
and near misses, promptly address and resolve findings and recommendations and review the results with
workers and contractors whose jobs are relevant to the incident findings. Incidents (or near misses) are
thoroughly investigated as soon as possible by a team which includes at least one person knowledgeable in the
process operation involved and others with appropriate knowledge and experience.

Standards and Regulations

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Process facilities are subject to two distinct and separate forms of standards and regulations.

1. External codes, standards and regulations applicable to the design, operation and protection of process
facilities and employees typically include government regulations and association and industry standards and
practices.
2. Internal policies, guidelines and procedures, developed or adopted by the company or facility to complement
external requirements and to cover processes which are distinct or unique, are reviewed periodically and
changed when necessary, in accordance with the facility’s management of change system.

Trade Secrets

Process facility management should provide process information, without regard to possible trade secrets or
confidentiality agreements, to persons who are:

responsible for gathering and compiling process safety information

conducting process hazard analyses and compliance audits
developing maintenance, operating and safe work procedures
involved in incident (near miss) investigations
responsible for emergency planning and response.

Facilities typically require that persons to whom process information is made available enter into agreements not
to disclose the information.

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