We see this often in our PHAs/HFA and audits…
an emergency shutdown procedure would need an Olympic athlete to carry out before the LOPC event begins. And to top it off, the operators we witness as those who would be expected to carry out this ESD SOP are “senior” operators who tend to be out of shape and look as if they are in a ZZ Top cover band! Clearly, “human factors” and “timing” needs have not been considered in this ESD SOP. There is an excellent white paper, Impacts of Process Safety Time on Layer of Protection Analysis that can aid our review/analysis to ensure the ESD SOP can be executed in the time necessary to prevent a LOPC event.
The SOP would require these senior operators who are overweight and out of shape to don an SCBA (but first, they would have to shave their full beards off!), and then one operator has approximately 15 minutes to cover two (2) flights of stairs, each one going to the 5th floor, actuate 9 valves, all in FRC and their SCBA. To top it off, the heat index was 117°F.
I know that “staffing” is not officially part of PSM, nor is the conditioning of the operators, but when we stack the deck against them in this manner, it can increase risks considerably. Remember 1910.119 and Part 68 establish the “floor” of our expectations – not the ceiling!