The Ten Commandments of risk based process safety

THE TEN COMMANDMENTS OF RISK BASED PROCESS SAFETY—INTRO Instruction of many “Foundations of Risk Based Process Safety (RBPS)” courses has resulted in the realization that the volume of material presented in RBPS training could be overwhelming. The need for a simplified tool to ensure critical points are understood and actions follow upon the “Ten Commandments of Risk Based Process Safety” were developed to leave with the participants to highlight the concepts of the course. It is important to understand the breadth of each “commandment,” for full integration and application. The ultimate intention is that each item will serve as a stimulus for taking action upon returning to your workplace 1, 2.

THE TEN COMMANDMENTS OF RISK BASED PROCESS SAFETY Each commandment is listed below with an explanation of the relative concept.

I. Thou shalt always honor thy container Businesses that are diligent about keeping chemicals and energy in their respective containers in order to eliminate unplanned releases, significantly reduce the likelihood of a process safety incident. In order to create a low likelihood of a process safety incident the following are required; proper operating procedures, a strong mechanical integrity program, appropriate training and routine observations.

It is also very important to include all containers in a process. Many significant incidents occur with finished materials storage tanks, raw material storage tanks, and others. Transportation containers need to also be included in your process safety management activities. A transportation incident can result in a process safety incident which may severely damage not only a company's reputation but can also affect the lives of others, especially those in the surrounding communities. Due diligence is necessary when ensuring that the appropriate containers are used and inspected, and that all transportation rules and guidelines are followed.

II. Thou shalt always maintain a sense of vulnerability Complacency equals incidents. The potential for a process safety incident is always present. This concept needs to be a critical part of the mindset of every employee and every contractor. In order to keep this active in any organization it requires consistency in practice from everyone in the organization. Safety awareness is not the job of just one or two people. It needs to be on the minds of every employee. The thought that it can't happen here, or that it has never happened before need to be dispelled.

III. Thou shalt eliminate normalization of deviation Normalization of deviation is accepting operations which are outside of set limits. One example is when the temperature limits on a reaction is set at 75 degrees C, plus or minus 2 degrees C. Over time the process is allowed to run consistently at 76 degrees C, then 77 degrees C, and then at 78 degrees C. This condition of constantly running at higher than the original set limit has reached a level of acceptability. Over time, it has the potential of further exceeding the original limit if no action is taken. At some point it may reach a temperature where a process safety incident is experienced. Designing a process without strict adherence to design standards is another area where normalization of deviation tends to exist. If a deviation is necessary in any circumstance, steps need to be taken such as management of change, supervisory approval and subsequent documentation to change the previously set limits. Advancements in technology as well as knowledge from experience (either on-site or from field experts) will dictate whether a deviation is acceptable or not. One individual should not determine whether a deviation is allowable. A deviation needs to be researched and based upon sound industry practice.

IV. Thou shalt know thy chemistry It is extremely important to know and understand the chemistry of everything under your control. This knowledge includes: side reactions, operating limits and why these limits are what they are, stability, reactivity, and other properties. This knowledge enables a person to make changes without additional risk. It must be determined if additional testing is required for a process change. This information also provides the “why” answers to those who operate the process and instills upon them commandment II, Thou shalt always maintain a sense of vulnerability.

V. Thou shalt educate, train and drill employees This covers everything from evacuation to regaining control of potential runaway reactions. As changes are made in a process, this thought becomes extremely important. Do not forget there is a big difference between driver education and driver training. The same concept applies to Risk Based Process Safety. After the education and training is complete, the drill is performed to ensure that the education and training was effective. Adjustments to training content or procedures, or retraining, may be required to ensure full demonstration of knowledge by all participants. The use of a pre test and post test method may be beneficial in determining the effectiveness of the training delivered and help in identifying areas of weakness. Annual retraining is another area that should be considered. This may go into more depth than the initial training.

VI. Thou shalt create and nurture a strong risk based process safety culture Without a strong safety culture all other efforts will eventually fade away. A common phrase used when teaching RBPS is “will you act or perform the same, even if no one is watching.” The culture needs to be all encompassing, from the CEO and Board Members throughout all levels of the entire organization. Process safety is a way of life. It factors into every task and assignment. There must be a culture that allows for open and sometimes uncomfortable communication. A strong process safety culture may save a company from its ability to exist or not. Without a strong process safety culture, the whole program may deteriorate to a point of ineffectiveness and result in a process safety incident.

VII. Thou shalt recognize those who exemplify process and occupational safety In the past, and even now, occupational safety goals and objectives are commonplace. Some examples include recordable incidents, lost time incidents, and near miss reports. It is important that I use the term recognize rather than reward. In process safety it is important to recognize the attitude, leadership and performance of individuals. Recognition may take many forms such as a mention at a staff meeting, a verbal thank you for your idea when walking through the plant, or a written note to the individual with a copy in their personnel file. Process safety incidents usually occur much less frequently. An order of magnitude or two less than occupational safety incidents would not be uncommon. Rewards are usually financial in nature and reserved for items such as cost control, production records and improved quality.

VIII. Thou shalt not tolerate omissions in documentation This goes back to culture. Signatures, check marks or other written requirements must be completed. If not, it begs the question of what else is not completed as it should be? One example is the omissions on permits. There are many instances where permit omissions have resulted in significant losses. These omissions are also an indication of a lack of operating discipline. Keep in mind the adage that if it is not documented, it did not occur.

IX. Thou shalt not manage from behind thy desk Visibility of all levels of management is critical to ensure a strong safety culture and reduce risk. Managers need to communicate, demonstrate their commitment and maintain availability for questions. A safety audit once revealed an intolerable situation of free flowing solvent into an open vessel, tank 314. When the plant manager was approached and told of the situation, he replied that he did not believe the situation existed because he had issued an edict that free flowing solvents will not be allowed. When the auditor offered to show him the problem and he replied, “Where is tank 314?”

This example is just one of many where management, at all levels, need to be visible on a daily basis as a minimum.

X. Thou shalt not violate rules There are only two choices that you have with a rule. Follow it or change it. With this mindset in place you have demonstrated a strong safety culture and reduced the likelihood of a process safety incident having a severe effect on your operation. It is a good idea to thoroughly review all rules on a regular basis to ensure their appropriateness. Discipline may have a role when rules are violated.

CONCLUSION The major point to be made is one cannot rest when you are involved with process safety. Bad things can happen to good companies. What needs to be done is to ensure that your company does not experience a process safety incident. Look for the warning signs. Talk to everyone. Establish the culture so that process safety is always considered, whether it is a very trite item or a major revamp of a process.