The folks “up north” are miles ahead of OSHA and EPA process safety standards in one simple but HUGE difference… Process Safety Leadership for Senior Management. This standard, not fully embraced by all provinces within Canada, is something that OSHA and EPA should consider adopting in their efforts to revise their compliance standards. This 2022 revision of CSA Z767:17 R2022 even addresses the continuous improvement model (Plan-Do-Check-Act) and Inherent Safety. But it is section 5 – Process Safety Leadership that sets this standard apart from just the basic compliance standards. The “Process Safety Leadership” section is broken down into four (4) subsections:
- Senior Management Accountability
- Regulations, standards, and codes
- Process Safety Culture
- Conduct of Operations — Senior Management Responsibility
Let’s take a look at how they managed to make “senior management” ownership of process safety a cornerstone in their standard.
NOTE: This was so impressive, I have incorporated much of the language in our PS management system documentation.
5 Process Safety Leadership
5.1 Accountability
5.1.1 Senior management shall be accountable for the PSM system.
5.1.2 Senior management shall
a) set expected performance requirements by establishing process safety goals and objectives, and by making resources available to meet the process safety goals;
b) make process safety goals that address worker, public, and environmental risks visible to and understood by relevant stakeholders;
c) provide direction to those responsible for design to consider inherently safer options;
d) require adherence to safe operating conditions (e.g., procedures) through appropriate conduct of operations; and
e) ensure that both PSM and the integrity of the equipment and processes are addressed through completing risk assessment and risk reduction (in accordance with Clause 6.3) throughout the lifecycle of the facility.
5.1.3 An approval process shall be in place and used for maintenance and production decisions. This approval process shall incorporate process-related risks as a key consideration.
5.1.4 Exceptions to the PSM systems shall be managed with appropriate controls, commensurate with the associated risk, in areas including, but not limited to, the following:
a) facility siting, including the location of permanent and temporary occupied structures on facility grounds;
b) engineering designs, including layout;
c) construction, commissioning, and decommissioning of facilities;
d) operating procedures;
e) inspection and testing procedures;
f) safety programs;
g) maintenance practices and procedures;
h) purchasing practices and procedures; and
i) qualified and competent personnel.
5.2 Regulations, standards, and codes
5.2.1 A management system shall be in place to identify, and ensure conformance with, regulations, relevant external standards, and codes. The management system shall guide the development of internal standards and guidelines.
Note: Organizations may seek assistance from industry associations to keep them informed of regulations, standards, and codes that apply to their facilities.
5.2.2 A management system shall be in place to ensure that the various regulations, external standards and codes and internal standards, procedures, and guidelines used are the latest versions, disseminated to appropriate people and departments, and applied throughout the organization.
5.2.3 A management system shall be in place to monitor and respond to changes in the applicable legislative and regulatory framework and applicable standards and codes.
Note: Examples of legislation, regulations, and standards include
a) process safety regulations;
b) environmental regulations;
c) occupational health and safety regulations;
d) planning and zoning regulations or bylaws;
e) chemical labeling and data sheet regulations;
f) transportation regulations;
g) boiler and pressure vessel and piping codes; and
h) electrical, building, and fire codes.
5.2.4 A management system shall be in place to identify when a new or an improvement to an internal standard or procedure is desirable. The system should identify best practices to be used when developing the internal standard or procedure.
Note: Examples of such internal standards include
a) general standards (e.g., maintenance practices, hot work, inspections);
b) reporting procedures (e.g., incident reporting and equipment monitoring data);
c) behaviour in facilities;
d) specific process standards (e.g., chemistry, process design principles, and metallurgy); and
e) mechanical, electrical, civil, and instrumentation design standards
5.3 Process safety culture
5.3.1 Process safety leadership and competency shall be the core values of every manager from the CEO to the front-line supervisors.
Note: Process safety leadership begins with a visible and active commitment from all senior management. It is critical to the successful safe operation of an organization.
5.3.2 Senior management shall ensure that the following requirements are met:
a) Organization policy shall include statements establishing process safety as a measure of successful operations.
b) Senior management shall steward the process safety management system including regular review of key performance indicators.
c) Senior management shall ensure implementation of corrective actions from risk assessments, incident investigations, and audits.
5.3.3 Supervisors shall:
a) demonstrate an understanding of the consequences of a loss of containment event that can affect matters for which they are responsible, such as the workforce, their facility, or the environment; and
b) ensure compliance with safety procedures including conduct of operation, permit to work, and management of change (MOC).
5.3.4 Workers shall
a) adhere to conduct of operation requirements;
b) raise through supervision or representation concerns regarding deficiencies in the process safety system (such as failures in maintenance, failure of permit to work, safety system bypasses, operating outside safe operating limits); and
c) have the responsibility and authority to initiate stoppages of unsafe work or operations.
5.3.5 Open communication shall be ensured as follows:
a) All levels of management shall enable open and effective communication at all levels of the organization related to process safety goals, issues, concerns and incidents, near misses, and performance.
b) All levels of management shall respond in a timely manner to process safety issues, concerns, incidents, and near misses.
c) Workers shall be informed about relevant process safety-related issues in a timely manner.
In addition, relevant stakeholders should be informed about process safety-related issues and incidents that have occurred within the organization or relevant incidents from other organizations or facilities in a timely manner.
5.3.6 Management and workers shall assume responsibility for their role in preventing a process safety incident from occurring. To this end, management and workers shall maintain a sense of vulnerability that a process safety incident can occur. Avoiding complacency may be accomplished through a variety of means, including
a) periodic safety meetings or briefings;
b) refresher training;
c) creation and/or review of safety bulletins; and
d) sharing or discussion of incidents and near misses.
5.4 Conduct of operations — Senior management responsibility
5.4.1 Senior management shall oversee operations and activities by meeting regularly with the facility managers and/or operators. Senior management shall be accountable for the organization’s overall process safety and shall set expectations for
a) maintaining the effectiveness of safety-critical systems and equipment;
b) maintaining fitness for duty of equipment and personnel;
c) ensuring personnel have required competencies and behaviors;
d) formalizing communication between workers, shifts, and work groups;
e) operating processes within safe operating limits; and
f) ensuring personnel incorporates operational disciplines in their daily routines.
5.4.2 Senior management shall commit to fostering a strong process safety culture by
a) remaining knowledgeable and aware of key process safety risks related to their operations;
b) supporting programs and activities to ensure compliance with process safety expectations;
c) regularly asking questions to all levels of the organization to ensure process safety awareness; and
d) showing support for stopping work and/or stopping the process if activities cannot be conducted safely.
Note: Conduct of operations is key to managing risk and can help personnel determine when operational units or the facility should be partially or completely shut down for planned or unplanned maintenance or modifications. Conduct of operations can help personnel make decisions during design processes which support operating safely, such as a system to identify when to segregate parts of a facility so that small sections of the facility can be shut down without shutting down the complete operation. Conduct of operations ensures that buildings are well located, muster points are understood, and process safety critical equipment are protected and perform as required upon demand.