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In the last twenty years considerable progress has been made in process safety, particularly in regard to regulatory compliance. Many companies are now looking to go beyond mere compliance; they are expanding their process safety management (PSM) programs to improve performance not just in safety, but also in environmental compliance, quaility control and overall profitability. Techniques and principles are illustrated with numerous examples from chemical plants, refineries, transportation, pipelines and offshore oil and gas.
This book helps executives, managers and technical professionals achieve not only their current PSM goals, but also to make the transition to a broader operational integrity strategy. The book focuses on the energy and process industries- from refineries, to pipelines, chemical plants, transportation, alternative energy and offshore facilities. The techniques described in the book can also be applied to a wide range of non-process industries.
The book is both thorough and practical. It discusses theoretical principles in a wide variety of areas such as management of change, risk analysis and incident investigation, and then goes on to show how these principles work in practice, either in the design office or in an opperating facility.
Introduction 1 Operational Integrity/Excellence 2 Process Safety Management 3 Major Events 6 Examples 7 Fundamentals of PSM 11 Health, Safety and Environmental Programs 23 Quality Management 25 Risk 26 Acceptable Risk 38 Risk Matrices 42
The first edition of this book was published in the year 1997 with the title Process Safety Management (PSM) (Sutton, 1997). At that time process safety regulations in the United States had been in force for just a few years so companies in the process industries were developing and implementing the programs needed to address the new regulations. The need for process safety regulations had arisen as a result of a number of very serious process plant incidents that occurred in the 1970s and early 1980s. (Some of these incidents are listed in Table 1.4.) In the United States process safety legislation was included in the amendments to the Clean Air Act of 1992. This legislation directed the Occupational Safety & Health Administration (OSHA) and the Environmental Protection Agency (EPA) to develop, implement, and enforce process safety standards in order to protect both workers and the public. Some states also introduced their own process safety regulations.
Similar programs were introduced in the same general time frame in many other nations and industries. For example, regulations covering the offshore industry in the North Sea were introduced following the Piper Alpha disaster of 1986. In addition, industry organizations such as the American Petroleum Institute (API) and the American Chemistry Council (through the Responsible Care® program) developed their own process safety standards.
Considerable progress to do with process safety has been made in the 15 years since the early 1990s—particularly with respect to regulatory compliance. For example, prior to the early 1990s few companies had a formal Management of Change Program; now such programs are part of the furniture in almost all process facilities. This is not to say that further improvements cannot be made. Indeed, in the words of one facility manager, "There is always news about safety, and some of that news will be bad". Moreover it is likely that, over the course of the last 20 years, there have been greater improvements in occupational safety than in process safety (Whipple, 2008). (The different types of safety are discussed on page 18.) In addition, new concerns—such as the increased shortage of experienced employees—have come to the fore as being a potential source of decline in process safety performance. Nevertheless, the process industries (including the regulators) can take a great deal of credit for having made substantial strides in process safety during the course of the last two decades.
Many companies are now looking to go beyond mere regulatory compliance to expand their PSM programs, to increase performance not just in safety, but also in environmental compliance, quality control, and profitability. In other words, they are moving into the broader topics of Process Risk and Reliability Management—the title of this book. Another term that describes the same transition is Operational Integrity Management (OIM)—the title of this chapter.
This book was written to assist those managers and technical professionals who are seeking to make this transition from PSM to the management of risk and reliability. (However, in recognition of the fact that regulatory compliance is always an issue, Chapter 15—Process Safety Management Compliance—discusses what needs to be done to abide by the PSM rules and regulations.)
Operational integrity management is rooted not just in process safety management, but also in the many other technical initiatives that companies have been pursuing during the last two decades in order to improve safety, environmental performance, and profitability. A partial list of such initiatives includes the following:
* RAM (reliability, availability and maintainability) programs that focus on achieving maximum profitability; * HSE programs covering the broad spectrum of Health, Safety and Environmental work; * Statistical Process Control; * Quality standards such as ISO 9000; and * Occupational and behavior-based safety programs that help improve the actions and behaviors of individuals.
Each of these topics—along with many others not listed above—can be thought of as contributing toward the overall discipline of operational integrity, as illustratedin Figure 1.1. A facility which has a high level of operational integrity is one that performs as expected in an atmosphere of "no surprises". The facility exhibits integrity in all aspects of its operation.
In addition to the incorporation of a wide range of management techniques that are shown in Figure 1.1, operational integrity can be applied to a much wider variety of industries than was the case with traditional process safety management. OIM can be used not only in chemical facilities and refineries, but also in transportation, pipelines, and offshore oil and gas.
Many companies are also developing operational excellence programs. The manner in which these can relate to operational integrity is shown in Figure 1.2. Operational integrity is made up of technical initiatives; operational excellence incorporates nontechnical management systems that can affect safety and operability. These include distribution, inventory management, outsourcing, supply chain management, and procurement.
PROCESS SAFETY MANAGEMENT
Figure 1.1 shows that process safety management is an integral component of operational integrity management. Therefore, it is useful to review the elements of PSM because they are so foundational to risk and reliability management work. Different companies and regulatory agencies have different approaches to the topic, but the standard promulgated by OSHA (the United States Occupational Safety & Health Administration) is widely used (OSHA, 1992). The development of the standard involved considerable input from the leading operating companies of the time, and has often been applied, regardless of whether a facility fell under OSHA's jurisdiction. OSHA divided process safety into the 14 elements listed in Table 1.1.
The topics listed in Table 1.1 were not new. Companies have always carried out activities such as the writing of procedures, planning for emergencies, training of operators, and the investigation of incidents. However, the regulation did have the following effects.
* It forced companies to complete their process safety work. Prior to the regulation there was a tendency to put off tasks such as the writing of operating procedures "until we have time". OSHA required that most of the elements be implemented immediately. The standard put management's feet to the fire. * Companies were required to initiate work on elements such as Management of Change and Process Hazards Analysis that they may not have performed previously. * PSM activities were increasingly seen as an integrated whole in which the elements all interacted with one another.
As companies have gained more experience with the implementation of PSM they have found that the list in Table 1.1 has some limitations. A modified list published by the Center for Chemical Process Safety (CCPS, 2007a) is shown in Table 1.2.
Some of the elements in Table 1.2, such as Management of Change, are identical to those in Table 1.1. Others are modified—for example, Prestartup Safety Review becomes Operational Readiness. But some of the elements listed in Table 1.2, such as Measurements and Metrics, are completely new. One of the topics in the original OSHA list—Trade Secrets—has been removed.
In addition to the structures put forward by OSHA and the CCPS many organizations, such as the American Petroleum Institute (API) and the American Chemistry Council, have offered their own methods for organizing PSM programs. Many larger companies also have their own systems, which typically are similar to what is shown in Tables 1.1 and 1.2.
The organization of the chapters of this book, which is shown in Table 1.3, is based on Table 1.2.
Major steps in the development of process safety management (and hence of operational integrity management) have often taken place following the occurrence of serious accidents. Some of the more significant of these are listed in Table 1.4.
Further information to do with major events is provided by various agencies and companies, including the following, as listed by Balasubramanian and Louvar (2004):
* National Response Center (NRC); * Major Accident Reporting System (MARS); * Accidental Release Information Program (ARIP); * Bureau of Labor Statistics (BLS); * Census of Fatal Occupational Injuries (CFOI); and * Marsh & McLennan Summaries.
Throughout this book the examples shown below are used to illustrate the concepts and ideas that are presented. They are referenced at the appropriate points of succeeding chapters.
Example 1—facility design
A process consisting of four operating units and a utilities section. A schematic of the system is shown in Figure 1.3.
Example 2—process flow
Figure 1.4 shows part of Unit 100 from Figure 1.3. Liquid flows into an Atmospheric Tank, T-100. The liquid, which is both flammable and toxic, is called Raw Material Number 12—abbreviated to RM-12. From T-100, RM-12 is pumped to Pressure Vessel, V101, using Pump P-101A or P-101B, either of which can handle the full flow (A is normally in service, with B being on standby). The pumps are driven by a steam turbine and an electric motor, respectively.
The flow of liquid both into and out of T-100 is continuous. The incoming flow varies according to upstream conditions and is outside the control of the operators responsible for the equipment shown. The flow rate from T-100 to V-101 is controlled by FRC-101, whose set point is cascaded from LRC-101, which measures the level in T-100. The level in T-100 can also be measured with the sight glass, LI-100.
V-101 is protected against overpressure by safety instrumentation (not shown) that shuts down both P-101 A/B, and by the relief valve, PSV-101.
Failure and repair times for the pumps are shown in Table 1.5. Summarizing Table 1.5 in words:
* P-101A (which is the pump that is normally in operation) is expected to fail twice a year. It takes 8 hours to repair. * When P-101A stops working, P-101B is started. It is expected that P-101B will fail to start on demand once in 10 times. If P-101B does not start immediately its anticipated repair time is 3 hours.
Example 3—heat exchanger
Figure 1.5 shows a shell and tube heat exchanger. Hydrocarbon vapors enter the exchanger on the shell side where they are condensed by cooling water which runs through two passes of tubes. The pressure relief valve and the drain and vent valves on the shell side are shown.
Example 4—risk management workflow
The third example is used for discussions of the management of risk. Figure 1.6 illustrates the major steps in the development of a representative risk management program.
The first step in the development of a risk management program is to check for the existence of standards from an external agency—generally either a government regulator or a company's own corporate group. Regulations are broad in scope. Corporate standards are likely to be more specific because they focus on just those operations that the company carries out.
Because external standards do not generally provide enough detail to actually develop and run a risk management program additional nuts-and-bolts guidance is needed. Such guidance can be internally generated or it can be provided by outside experts and consultants.
Risk analysis plan and implement
The next step is to conduct a risk analysis that will help determine what risks exist, how those risks can be mitigated, and how resources should be prioritized. Planning is followed by implementation.
No management program is perfect. Gaps between goals and reality always exist. In order to systematically identify the gaps, audits are needed. If the audit finds deficiencies or gaps, the process recycles to the implementation step. (The word "delta" is sometimes used to describe the difference between plan and performance because it sounds less critical than words such as "deficiency" or "failure".)
Ideally, once the plan is implemented and has been audited, management can declare that they have successfully implemented their risk management program. However, risk can never be low enough; improvements can always be made. Therefore, once the program has been completed, management should start the whole process over again—usually at the risk analysis and planning steps—in order to achieve even higher levels of safety and economic performance.
FUNDAMENTALS OF PSM
The nature of Process Safety Management (PSM) can be understood by examining its component words.
* The first word is Process. PSM is concerned with process issues such as fires and the release of toxic gases, as distinct from occupational safety issues, such as trips and falls. * The second word is Safety. Although an effective PSM program improves all aspects of a facility's operation, the initial driving force for most PSM programs was the need to meet a safety regulation, and to reduce safety incidents related to process upsets and hazardous materials releases. * The third word is Management. In this context, a manager is taken to be anyone who has some degree of control over the process, including operators, engineers, and maintenance workers. Effective control of an operation can only be achieved through the application of good management practices.
Some of the fundamental features of a successful PSM program are discussed below. These fundamentals also form the basis of operational integrity management work.
The safe limits for each process variable must be defined quantitatively. For example, the safe temperature range for a certain reaction may be 125-150°C. If the actual temperature deviates outside of that range, then that reaction is—by definition—out of control and potentially unsafe; action must be taken to bring the temperature back into the correct range. The fact that the process has deviated outside the safe range does not mean that an emergency situation exists—management and the operators may have plenty of time to react. But they must do something because the facility must always be operated within its safe limits. The option of doing nothing is not an option.
Once the safe range has been defined management must determine how to operate their facility so that it stays within that range. In the case of the reaction temperature example, instrument set points must be adjusted and operators trained so as to achieve the 125-150 °C range. All the people involved in running or maintaining the unit must know how to identify an out-of-control situation, what its consequences might be, and how they should respond to it. If it is management's intention to operate outside the prescribed range then the Management of Change program should be implemented in order to ensure that the new conditions are safe, that new limits have been set, or that new safeguards have been installed.
Excerpted from Process Risk and Reliability Management by Ian Sutton Copyright © 2010 by Ian Sutton. Excerpted by permission of William Andrew. All rights reserved. No part of this excerpt may be reproduced or reprinted without permission in writing from the publisher.
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Operational Integrity Management; Culture and Employee Involvement;Hazards Identification; Consequence and Likelihood Analysis;Technical Information and Industry Standards;Asset Integrity;Reliability, Availability and Maintainability (RAM) Analysis; Operations, Maintenance and Safety; Operating Procedures; Training and Competence; Emergency Management;Incident Investigation and Root Cause Analysis; Management of Change;Audits and Assessments; Process Safety Management Compliance;Managing a Risk and Reliability Program