While the occupational safety statistics continue to show improvement, and are extremely low, process safety statistics do not show the same level of improvement and continue to be a concern to both the regulators and the industry. Specific concerns include high incident areas associated with process knowledge, documentation, and process and equipment integrity. It is inevitable that we will continue to have incidents that result in increasing regulatory requirements and burden as we continue to operate complex hazardous facilities in hazardous environments.
Evolution of Process Safety Regulations:
Our regulations and safety techniques have evolved from process safety incidents that have occurred, such as Flixboro (1974), which led to the concepts of Management Of Change (MOC, and the Health and Safety Executive (HSE (UK) Control Of Major Accident Hazards (COMAH) regulation, Pasadena (1984), which led to OSHA’s Process Safety Management (PSM), Macondo (2010) which resulted in a new regulator, the Bureau of Safety and Environment Enforcement (BSEE) and their regulation Safety and Environmental Management System (SEMS), and the San Bruno pipeline explosion, which resulted in the Pipeline and Hazardous Material Safety Administration (PHMSA) issuing their API 1173 regulation.
There are a large number of Federal Regulations that are generated each year, in 2013 there were 70,000 pages and in 2015 it is estimated that 83,000 pages were issues. While these do not all necessarily apply to a specific industry sector, there are is still an endless barrage of new and evolving regulations that organizations have to be able to comply with. So it is crucial for organizations to develop an infrastructure and processes around this dynamic environment.
To manage this environment now and into the future, the following three tactics are recommended:
1. You must track related assets, mitigation strategies, and regulations.
Changes to either your assets, the regulations, or the processes should be linked to inform you of the effect these have on your mitigation strategy. In other words, the impact assessment of changes, or regulation should be flagged for review and appropriate action. This type of granular impact assessment cannot be achieved in a hierarchical document based environment, but in a data-centric environment or combination of both that allows asset, document, and process linkage, so that any change impact assessment can be conducted across all linked, and known Process Safety Information sources (PSI). This combined environment also prevents the gradual information decay that can occur, as all sources of PSI are exposed for examination, review and updating.
2. You need a full impact assessment to inform your Management Of Change (MOC) decision making process.
The combined, and linked document and data environment enables a complete impact assessment to be conducted across the large numbers of information associations that exist. In a document environment, the complexity and associations of the information is extremely difficult to intuitively track, so the information needed to inform change, such as the MOC process is generally incomplete and not always understood, and therefore associated information is not always updated.
I experienced this failure of an MOC system at a refinery where a fatality occurred by electrocution. An individual was hand excavating, and hit a power cable, unfortunately the associated circuit breaker did not clear resulting in his death. The investigation showed that an earlier Management Of Change (MOC) had been conducted correctly to change our brand X for brand Y circuit breakers, but that the impact assessment was lacking, and had not identified the need to change the exiting grease for the new brand of circuit break. The maintenance procedure had not been updated, and the old type of circuit breaker grease was used which change the new circuit breaker fault characteristic.
3. You must know where the gaps are in your current system.
For this purpose, North Highland can use its maturity models to conduct an assessment, and provide benchmarking to compare your organization against your peers. This information allows you to plan a phased strategy for filling-the-gaps, and will also reveal areas for improvement. As part of the process leading, and lagging KPIs can also be developed to identify improvements, and to monitor your overall performance against plan for continuous improvement.
These three tactics with the appropriate infrastructure, and processes will provide you with a safety system that is flexible, durable to sustain compliance, and meet any future regulatory requirements.