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Table of Contents
Process Safety Begins In the Board Room 4
Senior management should take six important steps

Is Your Process Safety Documentation Adequate? 11


Don’t wait for a safety audit or OSHA inspection to find out

Product Releases
Rupture Disk Handles Corrosive Media 8

Weighing Terminal Suits Hazardous Areas 14

Ad Index
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Summit Training Source 10


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Continental Disc 15
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Process Safety Begins In the Board Room
Senior management should take six important steps

By Graeme Ellis, ABB Consulting

Major accidents such as those at Texas City • developing world-class safety management
and Buncefield and in the Gulf of Mexico have high- systems; and
lighted the critical role played by senior managers in • identifying weaknesses in these systems using
the process industries. Effective leadership is essen- targeted performance indicators.
tial to develop a positive safety culture that remains
constantly vigilant toward process safety risks. (For LEARNING FROM RECENT EVENTS
details on how DuPont and Dow executives have Major accidents with multiple fatalities continue to
established a strong safety culture in their companies, occur worldwide in the process industries, causing
see “Orchestrate An Effective Safety Culture,” www. distress to those involved and massive costs to compa-
ChemicalProcessing.com/articles/2012/orchestrate- nies. Accidents at Flixborough, U.K., Seveso, Italy,
an-effective-safety-culture/ and “Make Safety Second Bhopal India, and Pasadena, Texas, in the 1970s
Nature,” www.ChemicalProcessing.com/articles/2011/ and 1980s led to tighter regulation of the process
make-safety-second-nature/.) The U.K. Health and industries and raised awareness of the key risk control
Safety Executive (HSE) has made process safety lead- systems needed to prevent such accidents. Recent
ership a key priority for high hazard industries. accidents have increased recognition of the key role
This article will explore the leadership failings of senior managers in ensuring these systems are ef-
that contributed to recent major accidents and essen- fectively implemented and remain robust throughout
tial leadership principles, including: the life of a facility.
• ensuring senior management actively supports Investigation of the 2005 explosion at BP’s Texas
process safety through its investment strategy City, Texas, refinery revealed a series of failings in
and focus on the safety culture of the organiza- process safety management (PSM). This prompted a
tion; fundamental and independent review of the BP cor-
• reinforcing the importance of safety by personal porate safety culture across its refining operations in
example; the U.S. [1]. As the so-called Baker Panel emphasized,
• thoroughly understanding major accident haz- many of the deficiencies it found are not limited to
ards and key risk control systems; BP. So, other processors certainly should ponder the
• investigating process safety incidents and near following noteworthy comments in the report:
misses to find the underlying causes; • Companies should regularly and thoroughly

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evaluate their safety culture and performance of • The culture BETWEEN
COMPARISON made keeping the process
PERSONAL operating
AND PROCESS SAFETY
their PSM systems.
Consequences
• Preventing process accidents demands vigilance. Process Safety
People can forget to be afraid.
• BP has not provided effective process safety Major
Consequence
leadership and has not adequately established Offsite
process safety as a core value.
• BP mistakenly interpreted improvement in per- Personal Safety
Very Serious
sonal injury rates as an indication of acceptable Onsite
process safety performance. Incident
• Process safety leadership appeared to have
suffered as a result of high turnover of refinery Slips,
plant managers. Trips,
Falls
• A good process safety culture requires a posi- Frequency
tive, trusting and open environment.
• BP does not have a designated high-ranking
leader for process safety. Figure 1. Personal safety metrics don’t provide an accurate indication of process safety.
• The company did not always ensure that ad-
equate resources were appropriately allocated to the primary focus; process safety did not get the
support or sustain a high level of process safety required attention, resources or priority.
performance. • The operation lacked clear and positive process
• BP has not demonstrated that it has effectively safety leadership with board-level involvement
held executive management accountable for that should be at the core of managing a major
process safety performance. hazard business.
• The panel found instances of lack of operating • W hat was set out in the safety report and the
discipline, toleration of significant deviations safety management systems did not reflect what
from safe operating practices, and apparent actually went on at the site.
complacency toward serious process safety risks. • The management board did not effectively
In 2005, a massive explosion and fire at a fuel supervise major hazards; it apparently focused
storage terminal in Buncefield, U.K., caused extensive primarily on finances.
damage. Several layers of protection failed, allowing a
gasoline tank to overfill and ultimately resulting in a LEADERSHIP PRINCIPLES
vapor cloud explosion. The HSE and a cross-industry The Baker report highlighted the strong link between
group carried out a thorough investigation and high- leadership and culture. Edgar Schein [3] puts this
lighted leadership failings as a major contributor [2]: succinctly: “Leaders create cultures by what they
• Management systems relating to tank filling systematically pay attention to.”
were both deficient and not properly followed, The U.K.’s Chemical Industries Association has
despite having been independently audited. summarized the behaviors expected for effective
• A lack of engineering support from head office process safety leadership [4]:
worsened the pressure on staff. • board champion for process safety, ensuring

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discussion at all board meetings to review per- PROCESS SAFETY PYRAMID
formance and set future priorities;
• communication of process safety policy, stress- Lagging Tier: Loss of containment
with serious consequences
ing the importance set by the board and the
role of people at all levels in protecting against
major hazards; Tier 2: Loss of containment
• visibility of board-level management, e.g., visit- with minor consequences

ing control rooms, making presentations on


major hazard risks; Tier 3: Demands on
• use of effective leading and lagging process safety critical elements
safety performance indicators (PSPIs) to allow
board-level monitoring; Tier 4: Management
System Indicators
• board-endorsed formalized process safety im- Leading
provements plan in place for ensuring continu-
ous improvement; and
• outward-looking company and board with Figure 2. Addressing lower-tier incidents is crucial for controlling higher-tier events.
cross-industry approach to learning and sharing
the lessons from incidents. causes are varied and involve both immediate failings
and underlying systems’ shortcomings. Improving
PRACTICAL APPROACH FOR IMPROVEMENT process safety performance requires an effective
A senior manager recognizing a poor process safety organization to maintain risk control systems and
culture in the organization should take six steps, respond to any weaknesses identified.
which are gleaned from experience gained across Step 2. Implement best practice PSM systems.
high-hazard industries: The key elements of effective PSM systems are
Step 1. Understand the approach needed for process well defined in several publications and generally
safety. have converged between the U.S. and U.K. These
Many senior managers believe “safety” to be elements have been identified following serious
under control based on falling injury rates, only to be accidents in the process industries. For example,
surprised by a serious fire, explosion or toxic release. the explosion at Flixborough, U.K., in 1974, which
Figure 1 can be used to explain to all staff the differ- stemmed from failure of a temporary pipe connec-
ence between personal safety and process safety. tion between two reactors, led to “management of
Personal safety is related to relatively frequent change” being a key PSM element, with the require-
low-severity events generally associated with the ment to carry out an assessment of the potential
behaviors of individuals. This has been successfully implications of any change.
managed in many companies by improved manage- The Energy Institute’s PSM framework [5] has 20
ment focus and behavioral safety initiatives. elements. Five relate to process safety leadership:
Process safety relates to serious events involving • leadership commitment and responsibility, includ-
a loss of containment of hazardous chemicals or a ing process safety policy and performance targets,
release of energy. These events are rare and usually plus structure and resources to achieve them;
occur when several layers of protection have failed • identification and compliance with regulatory
to prevent the escalation of an initial event. The and industry standards, to ensure the require-

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ments of applicable legislation are identified, RELATED CONTENT ON
understood and satisfied; CHEMICALPROCESSING.COM
• employee selection, placement, competency and “Orchestrate an Effective Safety Culture,”
health assurance, to make certain that current www.ChemicalProcessing.com/articles/2012/
and new personnel can adequately handle their orchestrate-an-effective-safety-culture/
job responsibilities and are fit for work; “Make Safety Second Nature,” www.Chemi-
• workforce involvement, to align, involve and calProcessing.com/articles/2011/make-safety-
empower all staff in recognizing and managing second-nature/
process safety hazards; and “Achieve Continuous Safety Improvement,”
• communication with stakeholders, including www.ChemicalProcessing.com/articles/2007/063/
identifying key stakeholders plus understanding
and addressing their issues and concerns.
An effective PSM system should follow good initiating events such as failure of hardware or control
practice requirements but must be tailored to reflect systems, or errors by operating or maintenance staff.
the organization and specific process safety hazards. Usually, plants rely on several layers of protection to
A large manufacturing site that produces and dis- prevent, control and mitigate these scenarios from
tributes chlorine will have different procedures than escalating into a major accident, ensuring the risk has
a small facility storing flammable liquids. Senior been reduced to an acceptable level.
managers should implement an independent review Senior managers must thoroughly understand the
of the PSM system to identify and prioritize gaps and main risk scenarios of facilities they manage and remain
departures from relevant good practice. constantly vigilant to complacency toward the risk con-
Step 3. Understand process safety risks. trol systems. The scenarios should be available in safety
Facilities in the process industries face a number reports or similar documents such as hazard and oper-
of specific major accident hazard scenarios depending ability reports. If this information is not available or is
upon the nature of the substances they handle and out of date, executives should initiate a thorough review
their processing activities. These are caused by known of process safety hazards using competent specialists.

REFERENCES
1. Baker, J. et al., “The Report of the BP U.S. Refineries Independent Safety Review Panel,” BP, London
(2007).
2. “Buncefield: Why Did It Happen? The Underlying Causes of the Explosion and Fire at the Buncefield Oil
Storage Depot, Hemel Hempstead, Hertfordshire On 11 December 2005,” HSE Books, Sudbury, U.K. (2011).
3. Schein, E. H., “Organizational Culture and Leadership,” 4 ed., John Wiley, Hoboken, N.J. (2010).
4. “Best Practice Guide: Process Safety Leadership in the Chemicals Industry,” Chemical Industries Assn.,
London (2008).
5. “High Level Framework for Process Safety Management,” Energy Institute, London (2010).
6. “Major Incident Investigation Report, BP Grangemouth Scotland, 29th May – 10th June 2000,” HMSO,
Norwich, U.K. (2003).
7. “Process Safety Performance Indicators for the Refining and Petrochemical Industries, Recommended
Practice 754,” American Petroleum Institute, Washington, D.C. (2010).

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Step 4. Investigate process safety incidents. A key conclusion from the Texas City investiga-
Examinations of major accidents often reveal prior tion [1] was “BP primarily used injury rates to measure
similar near misses that were not effectively followed up. process safety performance at its U.S. refineries before
An example of a process safety near miss is operation the Texas City accident.” This reinforced a similar
on demand of the high level trip on a flammable liquid conclusion following incidents at the BP Grangemouth,
storage tank. Although no harm has occurred, the U.K., refinery in 2003 [6] and the need to develop key
potential exists for a serious fire or explosion if the same performance indicators for major hazards.
event happens and the high level trip fails to operate, as These reports have helped spur development of
occurred in the Buncefield accident. PSPIs to allow management of process safety at all
After incidents, senior managers should ensure levels up to the board room. The objective is to have
the correct assessment of the potential for serious appropriate leading (predictive) and lagging (failure)
consequences. They should have a competent special- indicators that are reported and assessed in a manner
ist perform thorough analyses of all process safety similar to injury rates for personal safety.
near misses. These investigations should assess the Figure 2 shows a four-tier process safety pyramid
immediate causes plus any underlying ones involved. based on an American Petroleum Institute recom-
The aim should be to identify PSM system weakness- mended practice [7]. This reflects the principle that
es that contributed to the incident because correcting responding to more frequent and less severe incidents
these deficiencies will prevent similar incidents. toward the base can control rare process safety ac-
Step 5. Monitor process safety performance. cidents at the top of the pyramid.

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The key challenge for an effective PSPI system is • Show me how you manage process safety
to identify appropriate and risk-targeted tier-4 lead- competence.
ing indicators. These should be based on investiga- • How many safety systems have activated recent-
tion of process safety incidents that have highlighted ly? Why and what have you done about this?
weaknesses in risk control systems. They also should • Have you had any process safety incidents that
be “SMART,” i.e.: human intervention prevented from becoming
Sufficient — having enough data to trend changes; worse?
Measurable — allowing efficient collection of data; • W hat process safety experience and expertise do
Accurate — providing data that is accepted as a you have on site?
true reflection;
Reliable — collecting data that the workforce LEADERSHIP MATTERS
values; and Senior managers must remain constantly vigilant to the
Targeted — focusing on high risk systems. risk of a major accident at their facilities. The lack of a
Step 6. Carry out site visits. previous incident is no guarantee that one could not
Senior managers must provide “felt leader- happen tomorrow, so it is essential to monitor process
ship.” As Judith Hackitt, chair of the HSE, stresses: safety performance and respond to warning signals.
“Process safety cannot be managed or led from the Executives should critically review the key leader-
comfort of the boardroom.” It is important that ex- ship principles outlined in this article to check that
ecutives are seen and people believe they are serious they are doing all that can be reasonably expected.
about process safety. Having set policies and declared They should treat this as a matter of urgency, to pre-
the importance of process safety to the organization, empt the soul searching that would follow a serious
senior managers should “walk the talk.” For example, accident at one of their facilities.
leaders should challenge staff at a facility posing Senior managers also should take the six key
major hazards with questions such as: steps cited to improve process safety performance. I
• W hat was the last serious process safety believe that ensuring a strong response to near misses
incident and what has been done to prevent is the most important of these. Leaders should re-
recurrence? quire a thorough investigation of near misses, to find
• W hat safety systems are out of service or over- weaknesses in the overall process safety risk control
ridden? systems and learnings that can be used to implement
• W hat safety-critical equipment inspections or focused improvements.
proof tests are overdue?
• W hat equipment is running outside of design GRAEME ELLIS is principal lead consultant for ABB Consulting,
limits or inspection recommendations? Warrington, UK. E-mail him at graeme.ellis@gb.abb.com.
• W hat is the biggest process safety risk on site?
Can you show me why the process is safe?
• W hat measures can you show me that verify Share this eHandbook!
proper management of process safety?
• W hat independent assessment have you had to
show you’re managing process safety properly?
• Show me how you have learned from a recent
major incident outside of the company.
www.chemicalprocessing.com

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Is Your Process Safety Documentation Adequate?
Don’t wait for a safety audit or OSHA inspection to find out

By Brian J. Kingsley and David E. Kaelin, Sr., Chilworth Global

Process documentation and other process Of course, the challenge is ensuring the information
safety information (PSI) play a key role in process safety you have is adequate and remains that way. So, in this
management (PSM). Nearly every governing author- article we’ll discuss how to assess and address process
ity, including the U.S. Occupational Safety and Health documentation.
Administration (OSHA), and the National Fire Protec- You should start with the fundamentals. Firstly,
tion Association, as well as insurance providers require senior management should prepare a safety mission
process safety documentation. statement and safety policy that commits them to the
While requirements differ slightly among industries, safety of employees and their work environment. Sec-
the key documents common to most include: ondly, form a safety committee to manage the diverse
• process description; aspects of overseeing collection of data and the creation
• process flow diagram; of required documentation. Members should include
• piping and instrumentation drawing (P&ID); representatives from management; health, safety and en-
• electrical area classification drawing; vironmental; engineering; maintenance; manufacturing;
• process hazard analysis (PHA); quality control; and any other departments important
• material safety data sheets (MSDS); to your processes. Thirdly, the safety committee should
• design basis for emergency systems and devices; create a “basis of safety” document as a roadmap for
• startup/shutdown operating procedures; your approach to the design and management of the
• normal operating procedures; safety system, ensuring your operations meet the intent
• emergency procedures; of your company’s safety policy.
• management-of-change procedure; and The best approach for any large undertaking is to
• maintenance records. segment it into manageable pieces. The safety commit-
Supporting documents may include: tee should delegate individual document ownership to
• material and energy balance; appropriate departments. When resources are limited,
• process chemistry; outsourcing the technical drawings to a local engineer-
• materials of construction; ing firm is a common approach. However, you must
• equipment arrangement; start the process internally because no one knows your
• plot plant; operation better than your own people. Prepare a list
• ventilation design; of documents currently available, even if they’re old or
• emergency planning; outdated. Perform a gap analysis to define which docu-
• upper and lower control limits; ments are missing.
• consequence of process deviation; and If the resources for document preparation (in terms
• accident/incident investigation reports. of time or cost) are a factor, select a smaller “boutique”
Additionally, a site should carefully maintain — and engineering firm that can perform the work part time at
periodically update or revalidate — documents pertain- a reduced cost. Alternatively, consider contacting a local
ing to life safety and building structural design. university about participating in a cooperative program

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for third- and fourth-year engineering students. Ensure retention is important to the periodic PHA revalidation
the students are well supervised to make the most of process and management of process changes to ensure
their four to six months with you. that new un-assessed hazards aren’t introduced.
Once you’ve got current versions of all the docu- The PHA report must contain a number of
ments needed, store them in a centralized secure loca- elements.
tion where they are accessible to those who need them. Facility siting. OSHA PSM requires PHA reports to
Many companies maintain their documents electroni- include a description of how facility siting was consid-
cally with date stamps and expiration notices to ensure ered, safety-critical findings and recommendations for
only the latest information is utilized. The requirement follow-up activities. Siting checklists such as those of the
for “as built” documentation is time critical not only CCPS are good tools for siting considerations but the
for process troubleshooting but also for process hazard checklists alone may not provide enough detail about
assessment, management of change, and capital project findings. It’s possible that some highly hazardous mate-
implementation. Managers and engineers can spend rials will require additional efforts such as consequence
hours looking for missing documents and, unfortunate- analysis and risk analysis and their results documented
ly, sometimes inadvertently use outdated documents, or referenced in the PHA report; we recommend
leading to lost time and potential rework. The role of a including dedicated paragraphs on these.
document control coordinator is much underappreci- OSHA expects a plant to specifically address
ated and often is critical to minimizing mistakes and hazards associated with the location of buildings and
lost efficiencies. employees as well as the discharge from emergency relief
To illustrate what’s involved in developing appropri- equipment. Regardless of hazard assessment method ap-
ate documentation, let’s look at a PHA. plied, the report must indicate where these hazards exist
and how they are managed.
PHA DOCUMENTATION Human factors. Discussion of these is another
Spreadsheet-like worksheets alone don’t suffice to meet OSHA-PSM-required element; like facility siting,
OSHA PSM requirements for covered processes or human factors often are covered by a specific check-
good engineering practice for noncovered ones, as de- list. In addition, a site should specifically consider
tailed by the American Institute of Chemical Engineers’ human factors in the PHA worksheets for process
Center for Chemical Process Safety (CCPS). safety hazard scenarios regardless of how a scenario is
The PHA is a key part of the overall PSI of a identified. Consistently use phrases such as “human
process. Unfortunately, the OSHA PSM regulation error of omission” or “human error of commission”
doesn’t specify the need for or format of a formal PHA throughout the worksheet (in the “cause” column)
report but does require documentation of the effort. In to demonstrate and document consideration of these
addition, under RAGAGEP (Recognized and Generally human factors for operators, mechanics, engineers,
Accepted Good Engineering Practices) OSHA may in- management and others. Also, consider hazard and
terpret the quality of documentation against the CCPS operability studies (HAZOPs) and job safety analysis
recommendations. to uncover potential hazard scenarios caused by hu-
The OSHA PSM regulation requires a plant to keep man factors. These studies could be follow-up activi-
the PHA and subsequent revalidations for the life of the ties recommended by the initial PHA study.
process. In addition, the site must document all follow-
up activities stemming from PHA recommendations REPORT FORMAT
and retain the documentation. These retention practices Numerous references describe formats that should be
make sense for non-OSHA processes as well. Such used for a technical report. The PHA report should

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follow this general style because it covers a scientific describes OSHA-approved methods such as checklists,
method used to assess process hazards. what-if, failure mode and effects analysis, and HAZOP.
The key sections of a PHA report include: We recommend including some discussion of why the
General. The report must have a title page, table of method is applicable to this PHA with supporting refer-
contents and pertinent document-control identifiers ences to the PSI. Explain the risk assessment technique
specific to site needs. applied, including pertinent consequence descriptors
Executive summary. This section, which generally is and likelihood levels. Detail the risk rankings as well
limited to one or two pages, provides management with as actions required for each risk ranking, such as action
an overview of the report, including scope, method- time schedule allowances. Also, list the team partici-
ology, significant findings and the most important pants with their experience and titles here.
recommendations. If the PHA uses risk ranking, this Findings and conclusions. Detail all the most
section is used to summarize those discovered scenarios, important team findings. Action items may include
if any, with the highest risk. The executive summary specific follow-up assignments, most commonly for
is where you will find the answers to basic questions of departments, although individuals may be specified.
who, what, where, when and how. In most cases, this Tracking of follow-up activities will be easier if the
section is written last. number of assigned groups or individuals is kept to
Introduction. This begins with a description of what a reasonable number such as three or four. Stress the
the report addresses, including a short process descrip- preliminary nature of findings and that the assigned
tion referencing pertinent detailed PSI such as the activities will lead to a risk management plan for
operating procedures, process flow diagrams, P&IDs, follow-up and closure. Such a plan may include
and MSDS for the process chemicals. It then describes detailed consequence analysis and release model-
the content to follow. ing, layers of protection analysis, or quantitative risk
Scope and objective. Here, detail the process scope analysis. Export tables from the PHA worksheets
and limitations, and the study objectives, such as with the most critical recommendations. Categorize
meeting the requirements of the OSHA PSM regula- findings by major topic, such as process node, unit
tion or corporate or site process safety standards or operation or recommendation area (maintenance,
goals. Note if this study targets multiple issues such operations, engineering, etc.). If risk ranking is used,
as safety, environmental, business and operability or list intolerable level risks with associated action
only safety ones. Describe specific guidelines used items. What is intolerable will vary from company
to specify consequence levels and likelihood ratings. to company and generally is risk-matrix specific.
Explain how safeguard reliability was evaluated. Refer, Appendices. These should include:
as appropriate, to process description documentation in 1. All PHA worksheets edited by the PHA leader
the appendices — but specify scope limitations in this and scribe and approved by the PHA team.
section. Consider including a listing of the modes of op- 2. A complete action-item listing with enough detail
eration covered, such as startup, shutdown, emergency to allow those responsible for closure to understand
shutdown, routine operation and non-routine activities. each issue and make appropriate responses. Follow the
Point out how utilities were considered because they are independent reader (six month) rule: “…include enough
an important source of common fault causes for process detail in each recommendation so that you can grasp
upset scenarios. the issues after a time delay without additional docu-
Methodology. This section most commonly contains mentation study or conversations with team members.”
“boiler-plate” text and covers the method(s) used to 3. PSI references (include date and version), such as:
analyze the process and identify hazards. It typically • equipment files on items within the PHA scope;

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• MSDS for process chemicals and utility materials; work falling off the radar screen. Yet, industrial sites
• process flow diagram and written process handling and processing hazardous materials always
description; must give process safety and, specifically, life safety
• standard operating procedures; top priority. Furthermore, an auditor or a jurisdic-
• standard operating conditions; tional agency relies heavily on a review of available
• P&IDs, if applicable to scope; documentation and records in evaluating the safety
• process material and energy balances; and of your facility.
• list of study “nodes” or other process subdivisions. We can’t sufficiently stress the importance of hav-
In summary, PHA worksheets alone won’t suf- ing your process safety documentation up-to-date and
fice. It’s critical to have a formal PHA report that readily accessible at all times. Even the largest compa-
allows a reader to easily grasp the important hazards nies often find gaps in their data due to a multitude of
associated with your process and understand the reasons from office relocations to staff changes. The
path forward to ensure appropriate risk manage- sooner you evaluate the current status of your documen-
ment. The pointers provided should enable you to tation, the earlier you’ll be able to address any potential
develop a report that stands the test of time, revali- shortcomings.
dation and auditing.
DAVID E. KAELIN, Senior, is a process safety specialist for Chil-
MANAGING THE PROCESS worth Global, Princeton, N.J. BRIAN J. KINGSLEY is manager,
The resources required to consistently update and consulting and training services, at Chilworth Global, Princeton,
effectively manage all the documents and paperwork N.J. E-mail them at dkaelin@chilworthglobal.com and bkingsley@
related to process safety sometimes result in this chilworthglobal.com.

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CONTINENTAL DISC CORPORATION // GROTH CORPORATION //
3160 W. Heartland Drive 13650 N. Promenade Blvd.
Liberty, MO 64068 USA Stafford, TX 77477 USA
Ph (816) 792 1500 | Fax (816) 792 2277 Ph (281) 295-6800 | Fax (281) 295-6999
sales@contdisc.com sales@grothcorp.com

THE NETHERLANDS CHINA INDIA


Energieweg 20 Room 910, Tower B, COFCO Plaza 423/P/11, Mahagujarat Industrial Estate, Moraiya,
2382 NJ Zoeterwoude-Rijndijk No. 8 JianGuoMenNei Avenue Sarkhej-Bavla Road, Ahmedabad (GJ)
The Netherlands Beijing (100005), P.R. China 382213 INDIA
Ph +(31) 71 5412221 | Fax +(31) 71 5414361 Ph +(86) 10 522 4885 | Fax +(86) 10 6522 2885 Ph +(91) 2717 619 333 | Fax +(86) 10 6522 2885
cdcnl@contdisc.com cdcchina@contdisc.com gcmpl@contdisc.com

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