RISK MANAGEMENT ADOPTING PROCESS SAFETY MANAGEMENT SYSTEM.

INTRODUCTION:

INDUSTRIAL SCENARIO:
In less than half a century, rapid strides have been in Our Country (India) to progress from an
Agro-based economy to the current stage of World Class Information Technology Leader and an
emerging Economic powerhouse by collective efforts of all Stakeholders.

Diverse types of Industries such as Exploration & Production, Oil & Gas Processing, Refining,
Petrochemical, Bulk Drugs and Pharmaceuticals, Shipbuilding, Major Port Operations like large
Container Terminals, Mega Steel Plants, Mineral Processing, Heavy Equipment Manufacturing,
Automotive Sector, with related Small Scale and Other Industries form a vast canvas.

Current Status:
However the focus remains on Major Accident Hazard Category Industries such as
Refining, Fertilisers, Chemical and Petro-chemical units. The reasons for this focus are obvious.
They form the bedrock in manufacture of many popular items of common use including
agricultural expansion so to say “Crude to Food”. Hence the concerns of SHE tend to get
magnified here and rightly so.

Modern Industries are Big and Complex. Giant Machinery and intricate Processes (sometimes
with patented technology) coupled with nature of Operations involving High Pressures,
Temperatures and handling of Corrosive, Flammable, Toxic and Explosive substances justifies
the concerns. But the reality is SHE aspects start very much at the Conceptual & Design Stage.
Whether in a Major Hazard Process Industry or otherwise.

In such Process units Process Safety Management System starts with Design integration of
Loss prevention as a Proactive approach rather than Reactive damage control activity.

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Scenario in the era of Globalisation and Economic interdependence
(Only Illustrative and not specific to any region or entity)
--Intense pressure on profitability. Yet Safety is not universally a condition of employment.
--Compliance to safety not negotiable – no compromise (Cardinality not widespread).
--Criteria / weightage in personnel appraisals for Safe Manufacturing is still selectively adopted
--Safety beyond compliance – not just to meet minimum statutory requirements.
Philosophy to gain momentum.
--But Very high standards co-exist due to involvement of Government Regulators/Professional
Auditors, Some societal monitors, MNC, WB, IMF, EU, partnership, Indo-JV, and such.
--Technology / skills a subject of cost interface decision in preference to Upfront Safeguards.
--Responsible care (Good Corporate Citizen Image). Signatory numbers limited.
--Reflection of SHE in Company Mission Statements not widespread.
--Public interest litigation / public liability compensation, driving Reactive remedies instead of
Self-Regulating Proactive approach
--Safety a way of life more remains a slogan unless Off-the-job Risks and Safety is
viewed equally important
-- Safety not equaled as important function of Management as Manufacturing, Finance etc.
-- “Safety is everybody’s responsibility”--observed more to share issues than to identify
prevention remedies.

MANAGEMENT SYSTEM:
Management can be broadly defined as prudent deployment of resources like
Men (not gender specific), Material, Machinery, to generate Wealth, Knowledge & Economic
Value additions from Human and Capital assets, to all stake holders.

Human and Capital Asset:

The human element is inherent as Planner, Designer, Constructor, Occupier and Operator
including Contractors and others such as Regulators, Statutory agencies, Institutions such as the
Underwriters, Funding, Medical and Safety institutions, individuals like Consultants, Auditors.
In short, translating a Design to Destination Safety has a partnership role in Safety.
Conceptualisation:
A Facility is conceived on paper as a Layout. Engineering Design, Layout Planning,
Construction, Trial Runs, Stabilisation, Perfecting and Innovating translate this concept into
reality.

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Process Safety Management (Prelude):
PSM is a systematic approach to Process plant Safety. PSM is part of the
Code of Federal Regulations under Part 1910-119. It is a codification of the general and
permanent rules by the Executive departments and agencies of the Federal Government in USA.
Appendix C to this part contains compliance guidelines and recommendations for PSM.

Elements of PSMS:
1. Process Safety Information 2.Process Hazard Analysis 3.Standard Operating Procedures
4. Training 5.Contractor control 6.Pre-start up safety review 7.Mechanical Integrity
8. Non-routine work authorisations 9.Management of Change 10.Investigation of incidents
11. Emergency Preparedness 12.Compliance audit 13.Employee participation

1.Process Safety Information:

This should include Referenced Design codes and Standards including Relief and Ventilation
design, Materials of Construction, Line flow diagrams, P & IDs,
Process descriptions, Hazard material inventory, MSDS information including incompatibility
data, Equipment particulars, Operating parameters,
Hazardous area classification, Alarms, trips, Interlocks and Programme logic protocols.

2. Process Hazard Analysis:

There are many types of this and the analysis should be relevant and appropriate to the
complexity and stage of the Process Unit.
HAZARD EVALUATION TECHNIQUES – APPLICATION (TYPICAL LIST)
Cause – Consequence Analysis , Checklist Analysis, Diagraph Analysis, Event Tree Analysis
Failure Mode & Effects Analysis (FMEA), Fault Tree Analysis, Hazard Analysis
Hazard And Operability Studies (HAZOP), Hazard Warning Structure,
Human Reliability Analysis (HRA), Management Oversight And Risk Tree Analysis (MORT)
Multiple Failure Error Analysis, Preliminary/Process Hazard Analysis (PHA)
Relative Ranking, Safety Reviews, Job Safety Analysis, What – If and What – If Checklist

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Typical Applications
Activity Technique
Design PHA
Detailed Engineering Fault Tree / Event Tree Analysis
Construction / Startup Checklist / Safety Review
Pilot Plant Operation / HAZOP
Routine Operation
Decommissioning What – If , Checklist Analysis
Expansion HAZOP / Relative Ranking
R&D What – If
Incident Investigation What – If / FMEA / HRA
CCPS Book (AIChE) on Process Hazard Evaluation Techniques is an excellent reference for
proper application. (Recommend Buy Book)

Methodology:
The analysis methodology and Team size and composition can vary. Determining the priority of
the system that needs PHA based on the potential severity and likelihood is vital.
Use of Dow and Mond Index should have a thorough understanding of the General Process
Hazards, Special Process Hazards, Process Control factors, Loss control credit factors, Fire
protection system, to derive Base and Actual Maximum Probable Property impact damage

3.Operating procedures:
These should include ranges, limits of Safe Operations, deviation response measures, Normal
Start-up and Planned Shutdown procedures, Upset control procedures, Emergency handling
procedures, PLC security access authorisation, Safety device Bypass and interim hazard
management instructions, and Safety Do’s and Don’ts pertaining to the respective SOP. As a
recommendation, Do’s and Don’ts on Safety can be incorporated in the SOPs as an annex.
SOP review criteria should be established. Typical situations are: change of Process/ chemistry,
change of Operating parameters, Modifications, Equipment changes.

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4.Training:
Training still is mostly emphasised, but causally dealt with subject primarily because of return on
investment on time and effort is only visible in the future. Training process should be structured
with clear Goals and Objectives, based on Task analysis, Skills Gap analysis after objective
personnel evaluation criteria, with a structured calendar, participant profile, venue selection for
ambience, Trainer choice, duration prescribed, with subject topics relevant to the participants.
Levels of Training can be published both for budgetary purposes as well as progress evaluation

It should be treated as an on-going activity preferably with a specified budget and an absentee
profile that would invite serious Management attention. In short it should not be statistic driven.
Identification of trained workers, and a system of recall, refresh and review, reinforcement should
exist. Individual development needs Road Map based on Supervisor/Employee interaction, and
performance appraisal feedback, will ensure attention to specifics.

Video filming of Special works, Mock Drills, Building Evacuation, Training programmes etc can
be cost beneficial with greater impact.

Training Proficiency assessment and quantification is essential to evaluate return on investment.

Identification and grooming of internal Faculty for forming multi-skill Resource Pool of Subject
Matter specialists will serve the Company in Knowledge Management.
Generation of Individual employee training database will track oversights or omissions.

5.Contractor Control:
Safety Orientation and certification should be compulsory before work placement to all
Contractors/Sub-contractors, Temporary and Casual workers. World class Companies issue
Safety tips card to all visitors. As a minimum, Contractors should submit to the following.
Commitment at Tender and Delivery on an agreed periodicity of work assignment:
Safe work methods statements based on JSA
Worker Training and awareness on Site Safety and Fire prevention regulations
Tools certification
Job specific safety PEP-TALKS
Inspection checklists and site audit schedules
Implementation of measures for violation control

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On-site safety performance statistics
6.Pre-start up safety review:
Start-up checks: Typically these include but not limited to the following:
• Reaffirmation that PHA and Punch list items have been closed
• Documented authorisation of Modifications and Changes
• P & ID is validated
• Equipment and work areas cleared
• Internal clean up of equipment and piping using suitable Utilities
• De-greasing, acidising and passivating of specific piping systems and equipment
• Pressure testing of equipment and pipelines
• Check of all panel mounted and field instruments
• Functionality checks of fail-safe Engineered controls—E.g. Relays/Alarms/Trips/Interlocks.
• Rotational checks of machinery
• Lubrication and coolant line checks as required
• Checking of vents, drains, steam traps
• Utility Line and Hose connection checks
• Checking of all PPE, Fire fighting equipment
• Removal of all restrictions and blinds not required for start-up.
• Functional check of all electrical appliances, switchgear, Transformers
• Ensuring good communicating systems using work permits per SOP
• Checking and dry run of start-up sequence activity
• Trial run of equipment to ensure normality
• Actual start-up
It should be borne in mind that Safety of Personnel and Asset protection is of paramount
importance and the competence of the Operating personnel during the training and the experience
gained by hands-on work will impose new requirements from to time.

The success of the start-up depends on teamwork and strict adherence to the Standard Operating
and pre-commissioning procedure and comprehensiveness of checklist developed at the site.

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7.Mechanical Integrity:
The soundness of the system depends on the baseline data and subsequent data base creation.
Equipment can be sorted category-wise and assigned individual history card. This can include
Material of Construction, specification sheets, Materials, time consumed, impact, and costing.

Schedule Annual Preventive Maintenance calendar should be drawn, with work instructions.
Values derived using calibrated instruments are to be compared to Design Specification. A ready
comparison sheet between design and P.M readings can be trend graphed in the form of
Paretto Diagram, Scatter Diagram, Histogram and such.

Agreements on deviations to schedules and any resultant impact should be documented.

A good P.M and Operational database can facilitate to generate Mean Time Between Failure
information for increasing On-time service hours. Beneficial accruals will be, base for
Predictive maintenance, Reliability Engineering data for equipment and components/
Plant Life Extension studies/Remnant Life Analysis, Sparing philosophy, to name a few.

The Focus point for effective testing and inspection programme should include
Engineered controls, Vents, drains, Flare lines, Elbows, Bends, Turbulent Spots, Spring hangers,
Pipe supports, Foundation Settlements, Stack top segments, critical isolation valves and
Non-Return Valves.
Inspection techniques vary. Reference to appropriate Inspection Standards is necessary
Individual Competency, Instrument and Result interpretation familiarity is essential

8.Non-routine work activities:

Verbal instructions are to be avoided when work is to be performed in an Owner operator area by
other Service providers. A system of work permits is to be adopted and most importantly
implementation and adherence verified. The nature and type of work permits and formats should
reflect the changing needs and reviewed based on Operational experience, Lessons learnt,
Best Industry standards.
Generally common permits are Routine Cold Work, Hot Work, Confined Space entry,
Line breaking, Excavation, Electrical Line clearance, Lock out/Tag out , Work at heights,
Bye-pass authorisations

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9. Management of change:
There should be a published procedure for any type of change i.e. Emergency change Temporary
change, and Permanent changes. Levels of approval authority should be part of the procedure
including associated checklist with signature provisions. A multi-disciplinary Change
Management Approval Committee should be formed, defined both for membership and tenure.
Approval request should include:
Change basis, Type of change, PHA/HAZOP, accrued benefit, Mention of Code/Standards
referenced, Material Specification Sheets, Design deviations if any, list of drawings such as
Block diagram, P & ID of relevant section, Proposed date of change, External approvals required,
Resource requirement and estimated payout factor without impact on SHE.
After Implementation Closure (Completion report) should address update of Isometric/P & ID.
Publishing Change Management request and approval flow chart will be useful handy reference.

10. Investigation of incidents:

World class Companies adopt the system of investigating all Incidents including Near Miss
and No Injury and publish for the knowledge of all employees and other site Contractors’
workers as lessons learnt to avoid repeat.
The reporting formats are also suited to the investigation methods, which are based on Root
Cause analysis for implementing not just Corrective action but more importantly Preventive
action. The focus is not on fault- fixing but fact- finding. This enables openness and transparency
at different levels to partner, to intervene and eliminate in time potentially lurking hazards, from
progressing to cause greater harm and impact damage.
The approach is not Company Employee focused. The Statistics are non-exclusive of all types of
Contractors workers and visitors.
Anomalies in reporting are reconciled between Plant records, Health centre records, Absentee
records, and insurance claim records.

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11. Emergency Preparedness:
While Incident free operation is the basic objective and goal, in reality layout considerations
do factor likelihood of impact in the event of any incident. To control, contain, mitigate and
eliminate the potential impact of harm an Emergency preparedness plan is published.
The Plan contents include Objectives, Emergency definition and Communication, assigned duties
to the Emergency response team, Resource mobilisation, Control and Protection Measures,
Safe Escape routes, Assembly Points, Facilities and equipment at the Emergency Control Centre.

12.Compliance Audit:
The audits are of many types: Routine walkthrough, Internal scheduled based on checklist,
Specialist Audits, Corporate Audits, Systems audits such ISO, EMS, OHSAS, ISRS, PSM,
Statutory audits, Third party audits, just to name a few.
The purpose of the audit should be for timely identification of potential source of hazards, and
identification of preventive measures before harm is caused. Most importantly, implementation of
recommendations based on audit observations is vital to ensure success of the audit efforts.
Audit Process should include Audit scope, Audit objectives, Audit frequency, Audit team,
Audit techniques, Pre-audit preparation, Audit Time-table, Audit actual, Audit reporting,
Post-audit review, Follow-through closure.
Actual audit should include Physical visit, connected document verification,
Personnel interaction, compliance status of prior audits observations and improvement plans.

The auditor/s should have a keen eye, independence, objectivity and possess the required
knowledge and qualification to conduct the audit and present the report summation logically.
Subsequent to the audit, Key focus areas are to be prioritised, action plan and accountability
assigned and closure followed through by verification. Outstanding items should attract senior
Management attention for closure.

13. Employee participation:

Bottom-up, lateral and Top-down involvement and partnership is vital for success of any On-site
Occupational Safety & Health Programmes. These are nurtured in many ways. Employee being
assigned his own area safety audit, implementing Safety suggestions Scheme, Involvement as
members of site safety committee, organising safety promotional activities, structuring

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recognition & reward system with defined criteria, issue Safety newsletters with contributory
inputs from employees, involving employees families in Off-the-Job safety promotion etc
Conclusion:
Focus on integrated Process Safety Management will enable systematic approach and eliminate
Going Unorganised Eliminating Systematic Study (GUESS), the greater Hazard.
Process Safety Management implemented studiously will add to the bottom line by increasing
yield factors, otherwise lost due to reactive approach. It makes the probability of incidents that
much less likely.

This does not mean that reliance on Administrative measures and PPE is neither done away,
nor substituted for Engineered fail-safe controls. But in most cases the erroneous impression is
that since unsafe conditions formed a smaller percentage of contributory cause for incidences, the
focus gets shifted from this key aspect. In other cases, practice of such measure is resorted to
avoid investment on the cost intensive but highly beneficial built-in Engineered Safety Measures.
Cost Benefits:
The cost benefits of PSM System will come into focus sharply only when a crippling incidence
occurs due to any human error. And after all, TO ERR IS HUMAN. But in such cases the
consequences will be unforgettable and not easily forgiven by those impacted.

Good Corporate citizens however reference PSM as a Self-regulatory activity and as a proactive
measure of Safety Management System. By avoiding high risks, Managing medium risks and live
safely with low risks, the objective is to have the freedom from unacceptable risk towards
incident free Business continuity. Small scale and non-process industry and more particularly
ageing Plants can also suitably adapt PSMS.
Reference Credits: -

CFR USA, Centre for Chemical Process Safety (AIChE), Professional Interactions with many in
Chemical Industry, EPC Companies, OEMs.

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 List of Abbreviations

AIChE American Institute of Chemical Engineers

CFR Code of Federal Regulations
CLI Central Labour Institute
EMS Environment Management System
EPC Engineering, Procurement and Construction
EU European Union
IMF International Monetary Fund
ISO International Organisation for Standardisation
ISRS International Safety Rating System
JSA Job Safety Analysis
JV Joint Venture
MAHAC Major Accident Hazard Category
MNC Multi National Corporation
MSDS Material Safety Data Sheets
NSC National Safety Council
OEM Original Equipment Manufacturer
OHSAS Occupational Health and Safety Assessment Series
P & Ids Piping & Instrumentation Diagram
P.M Preventive Maintenance
PLC Programme Logic Controller
POL Petroleum, Oil and Lube
PSM Process Safety Management
SHE Safety, Health and Environment
SOP Standard Operating Procedure
USA United States of America
WB World Bank

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