In the CSB’s final report on a refinery incident, the agency calls on OSHA to:
Develop guidance documents for performing process hazard analysis on operating procedures to address transient operation hazards in facilities with Process Safety Management (PSM) covered processes.
A PHA is a critical element of the process safety management system; unfortunately, we see more poorly performed PHAs than well-performed PHAs. The top causes of this is…
- attempting to do a PHA without a complete set of process safety information
- facilitator not trained on the methodology being used
- wrong team make-up
- lack of focus on how the HHC/EHS can get out of the process containment and how the HHC/EHS can cause problems within the process containment
Not many PHAs go to the extent of actually analyzing the SOPs. Still, ALL PHA’s should analyze the SOP when it is put forth as an administrative control for the PREVENTION or PROTECTION of an event. It is common to find “SOP/Training” listed as a safeguard for a specific scenario, and when pushed, the facility us unable to link the SOP to the process deviation being analyzed in the PHA.
We should NOT be reducing the risk calculation based on some pages of paper that provide NO guidance on managing a process deviation. Instead, we should create a corrective action plan to revise (or create) the SOP to cover the process deviation.
But to get to what the CSB recommends is a new path for many facilities. The CSB defines “transient operations” as:
Transient operations are a grouping of operating modes, such as shutdowns, startups, standby, and emergencies, where a process is changing over and is not in its normal operation mode. Transient operations can pose unique hazards that may not occur during normal process operations.
These transient operations are a severe concern in “continuous processes” (vs. batch processes), and there is a strong reliance on SOPs to manage the risks associated with these types of operations. So it makes sense to perform a detailed analysis of those SOPs (e.g., safeguards). As we do in batch operations, we like to use the What-If methodology as we work through the steps in the batch sheets/tickets. When the batch sheets say “mix the batch at 200°F for 30 minutes” we will look at all the potential deviaitons from that few words:
- What-if we are not mixing at that temp
- What-if we are mixing too much/too fast
- What-if we don’t reach 200°F
- What-if we exceed 200°F
- What-if we don’t mix for 30 minutes before next step
- What-if we mix longer than 30-minutes
Another key step that facilities fail to analyze is the means in which “chemical additions” are performed. I have written extensively about non-conductive flammable liquids and how we control their static generation rate. This should all be addressed in the PSI/Process Design; however, it must also be covered in the SOPs.