Over the past several years I have written many articles on the “safeguards” that get listed in Process Hazards Analysis. In this article I want to focus our attention on the flaws that so many facilities are making in their PHAs. Some facilities are really doing themselves an injustice by listing safeguards that have little to no impact on PREVENTING, PROTECTING or MITIGATING the consequences being analyzed. Please note that in this article I will be offering ideas that may not be a regulatory compliance requirement, keeping in mind that the PSM and RMP requirements are the bare minimum we must meet. Our process safety efforts should be focused on improving our process safety, not making OSHA or EPA happy!
Over the past several years I have written many articles on the “safeguards” that get listed in Process Hazards Analysis. In this article I want to focus our attention on the flaws that so many facilities are making in their PHAs. Some facilities are really doing themselves an injustice by listing safeguards that have little to no impact on PREVENTING, PROTECTING or MITIGATING the consequences being analyzed. Please note that in this article I will be offering ideas that may not be a regulatory compliance requirement, keeping in mind that the PSM and RMP requirements are the bare minimum we must meet. Our process safety efforts should be focused on improving our process safety, not making OSHA or EPA happy!
With that said, we do need to establish the OSHA/EPA minimum for our PHA(s). OSHA’s Process Safety Management (PSM) Standard (29 CFR 1910.119) and EPA’s Risk Management Plan (Part 68) state the following about the conduct of a PHA for a process that is covered by OSHA and/or EPA…
1910.119(e)(1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process…
1910.119(e)(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed.
1910.119(e)(2)(i) What-If;
1910.119(e)(2)(ii) Checklist;
1910.119(e)(2)(iii) What-If/Checklist;
1910.119(e)(2)(iv) Hazard and Operability Study (HAZOP);
1910.119(e)(2)(v) Failure Mode and Effects Analysis (FMEA);
1910.119(e)(2)(vi) Fault Tree Analysis; or
1910.119(e)(2)(vii) An appropriate equivalent methodology.
1910.119(e)(3) The process hazard analysis shall address:
1910.119(e)(3)(i) The hazards of the process;
1910.119(e)(3)(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace;
1910.119(e)(3)(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.);
1910.119(e)(3)(iv) Consequences of failure of engineering and administrative controls;
1910.119(e)(3)(v) Facility siting;
1910.119(e)(3)(vi) Human factors; and
1910.119(e)(3)(vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.
§ 68.50 Hazard review.
(a) The owner or operator shall conduct a review of the hazards associated with the regulated substances, process, and procedures. The review shall identify the following:
(1) The hazards associated with the process and regulated substances;
(2) Opportunities for equipment malfunctions or human errors that could cause an accidental release;
(3) The safeguards used or needed to control the hazards or prevent equipment malfunction or human error; and
(4) Any steps used or needed to detect or monitor releases
(b) The owner or operator may use checklists developed by persons or organizations knowledgeable about the process and equipment as a guide to conducting the review. For processes designed to meet industry standards or Federal or state design rules, the hazard review shall, by inspecting all equipment, determine whether the process is designed, fabricated, and operated in accordance with the applicable standards or rules.
(c) The owner or operator shall document the results of the review and ensure that problems identified are resolved in a timely manner.
(d) The review shall be updated at least once every five years. The owner or operator shall also conduct reviews whenever a major change in the process occurs; all issues identified in the review shall be resolved before startup of the changed process.
So with the regulatory minimums established, let’s take a look at “process safety” and our approach to PHAs from the 30,000 feet level…
First and foremost our process safety efforts should be focused on trying to PREVENT an event from even being initiated. So safeguards that will PREVENT the chain of events from occurring should receive the most attention and “credit” in our PHAs.
Second, we want to PROTECT our asset(s) should the consequence occur. We view these PROTECTION safeguards as our layer of protection once the consequence has occurred.
Third, we need to put measures in place that will MITIGATE the consequences to a lesser degree.
NOTE: Please refer to my previous article, Tips when performing PHA’s and how Chemical Process Safety should be viewed for more discussion and suggestions on the PREVENT, PROTECT, and MITIGATE methodology.
So what will this PREVENT, PROTECT, and MITIGATE methodology look like in a PHA? For purposes to demonstrate this, let’s look at over flowing a process vessel. In PHA terms, LEVEL is our process parameter and TOO MUCH is our deviation. We ask the PHA team what would happen if we overflowed this tank (i.e. consequences). As a matter of fact: 1) the material in this tank is a volatile, toxic, flammable, liquid; 2) the tank is located 50’ from the property line, 3) the tank is an atmospheric tank, and 4) the tank is located inside a dike.
Can our tank overflow – what can cause this occur? There are several common failures in tank over flow events and we should be certain to analyze each one as it relates to our specific situation. At SAFTENG.net LLC we like to do our PHA’s by listing EACH CAUSE and then reviewing the safe guards in place to address EACH CAUSE. Some facilitators may lump all the causes together, especially if the consequence will be the same for each cause; however, by breaking out and reviewing each cause, it allows the PHA team to more closely examine each cause of each potential scenario. But in these economic times, many businesses do not want to invest the time and resources for such a detailed study; so in reality, few studies are conducted in this manner.
Either way, the team’s focus still needs to be on PREVENTING the event from occurring, then PROTECTING assets once the event occurs, and lastly MITIGATING the consequences to a lesser severity. When looking at each of these three (3) priorities we seek to find safeguards that are classified as ENGINEERING CONTROLS, ADMINISTRATIVE CONTROLS, and PPE being our last line of defense. Keeping in mind that the PHA team must always be thinking “INHERENT SAFETY”; meaning the team should constantly be asking “can we run this process with a lesser hazardous chemical” or “can we run this process with less inventory of the current hazardous chemical”. Remember, the tank in our scenario is only 50’ from our property line, so even a “small overflow of just several gallons” on a hot summer day will cause off-site issues, if nothing more than odor complaints.
We are now ready to begin asking the tough questions regarding our overflow scenario and to analyze how well our process is designed to PREVENT, PROTECT, and MITIGATE the consequences from such an event.
First, we ask, in the following order…
What ENGINEERING CONTROLS do we have in place to PREVENT the overflow event from occurring? Examples would be: Hi-Level Control Alarm, Hi-Hi-Level Control Interlock that shuts down transfer pump and closes all fill valves, Manual Level Float on tank
What ADMINISTRATIVE CONTROLS do we have in place to PREVENT the overflow event from occurring? Examples would be: Operating Procedure(s), Staffing, and Training
NOTE: PPE is not a prevention method, so it does NOT apply in our PREVENTION efforts.
Next we ask, in the following order…
What ENGINEERING CONTROLS do we have in place to PROTECT our assets once the overflow has occurred? Examples would be: Secondary containment, area around the tank and inside the dike is a Class I Div 1 & 2 location, foam system in secondary containment to blanket any spill to act as a vapor suppression, chemical detectors inside the dike that alarm locally and in the control room
What ADMINISTRATIVE CONTROLS do we have in place to PROTECT our assets once the overflow has occurred? Examples would be: Emergency Response Plan, Emergency Action Plan, Facility Emergency Alarm System, HAZMAT Response team, and Fire Brigade
What Personal Protective Equipment do we have in place to PROTECT our assets once the overflow has occurred? Examples would be: Operators wear Flame Retardant Clothing (FRC), Truck driver wears FRC, FRC is always the outer most garment, Two (2) SCBAs are provided at unloading station
Next we ask, in the following order…
What ENGINEERING CONTROLS do we have in place that will MITIGATE the consequences of the overflow event? Examples would be: four (4) fixed monitor nozzles at the tank farm that can be operated remotely, fence line chemical monitors, tank farm foam system, secondary containment
What ADMINISTRATIVE CONTROLS do we have in place to MITIGATE the consequences of the overflow event? Examples would be: Hazardous Materials Attendant within 25’ and line of sight, Emergency Response Plan, Emergency Action Plan, Emergency Alarm System, HAZMAT Response team/Fire Brigade
What Personal Protective Equipment do we have in place to MITIGATE the consequences of the overflow event? Eight (8) HAZMAT LEVEL A ensembles with flashover protection, Twelve (12) HAZMAT LEVEL B or C ensembles, Fire Brigade equipped with NFPA compliant Turnout Gear
This is the manner in which we conduct our HAZOPs and although it is very strict, we feel this is how a PHA is to be conducted! The focus on safeguards is 1st – ENGINEERING CONTROLS, 2nd -ADMINISTRATIVE CONTROLS, and lastly PPE. Bottom line, if any of our scenarios do not have ENGINEERING CONTROLS as the first line of defense to PREVENT the event from occurring, we will need to discuss some recommendations so they can be put in place. Of course there may be scenarios that do not warrant engineering controls due to their lack of severity of consequences, but be VERY CAREFUL when using this rationale when the severity of consequences is HIGH, but the frequency is LOW. As a PHA team we need to study all significant events that have consequences impacting environmental, health and safety, regardless of their frequency or probability of occurrence.
On another note, every safeguard listed in the PHA MUST BE part of a true management system to ensure its availability and reliability when called upon. What I mean by this is that ALL of the ENGINEERING CONTROLS listed in our example MUST be listed in the facility’s Mechanical Integrity Program, with an established inspection/testing frequency that meets or exceeds the OEM’s requirements. There MUST be a written maintenance procedure to accompany the inspection/testing to ensure consistency in this task. And lastly, there MUST be a formal training program that includes initial and refresher training on the procedures and devices used in the inspection/testing, as well as a means to verify personnel fully understood their training. The ADMINISTRATIVE CONTROLS we claim must also be included in a management system to ensure they are reviewed and certified annually. The same applies to our PPE – it must be included in an inspection/testing program and personnel must be trained on its care, use, and limitations.
In closing, focus on PREVENTING the event from occurring, but be prepared to PROTECT assets when the event occurs, and lastly have the means to MITIGATE the consequences to a lesser severity. We also need to ensure that we place priority on ENGINEERING CONTROLS, then ADMINISTRATIVE CONTROLS, and our last line of safeguards will be PPE. Following this methodology will not only ensure we meet OSHA and EPA requirements, it will ensure that our process is designed, operated and maintained properly.