Process Safety Programmes – Proactive, Not Reactive Figure 1: Flow Diagram of Proactive Process Safety Programme


Management commitment


Employee participation


Process safety information


OP and SW procedures


Mechanical integrity


Incident data


Management of change


Process hazard analysis


Operator training


Compliance audits


Emergency preparedness


Pre-startup safety


Contractor safety


Management commitment


Benchmarks


Table 1: Notable Process Incidents and Regulations 1974


1976 1984


1988 1989


1994 1998 2000 2001


2005 2009 2010


Flixborough, UK Seveso, Italy


PEMEX LPG, Mexico UCIL (Bhopal), India Piper Alpha, UK Phillips, US


Texaco, UK


Longford, Australia Grangemouth, UK


P36 Platform, Brazil AZF, Toulouse, France BP, US


Buncefield, UK


Caribbean Petro, PR Indian Oil, India


Tesoro Refinery, US Horizon Platform, US


ARAMIS Compliance Audits


ARAMIS = Accident Risk Assessment Methodology for IndustrieS; COMAH = Control Of Major Accident Hazards ; PSM = Process Safety Management; RMP = Risk Management Program.


acknowledging their commitment to process safety while secretly planning their avoidance. These actions continue for a short, well- rehearsed period, then operations stealthily slips back to its ‘normalised deviation’ of reacting to safety issues as they occur.


The above scenario may seem light-hearted or sardonic, but candid process operators will be quick to acknowledge its sad accuracy. Although not intended, many operating companies fall into this scenario due to resource constraints and production pressures.


Requirements for the Proactive Process Safety Programme


Sites that have been immersed into a proactive safety culture do not have operators who become stricken with sudden and mysterious illness relapses when hazard analysis revalidation schedules near. Forward-looking programmes revise analyses as often as necessary to ensure the analysis is consistent with the current process without regard to five-year anniversary dates. The best-in-class proactive process safety programmes will develop expert systems that


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Another example of the proactive intent being morphed into reactive responses is how compliance audits are viewed by some operating companies. Process safety programme audits are required at least every three years in the US under the current process safety standard. Just as with hazard analysis and operating procedures, little thought is given to evaluating the PSM programme performance until the approach of its three-year anniversary date.


The US PSM standard requires employers to evaluate compliance with its programmes to verify that the procedures and practices developed are “adequate and are being followed”.2


Before an evaluation of a


programme’s adequacy can be attempted the programme criteria and benchmarks should be clearly defined. In addition, evaluations of whether a procedure and practice is being followed require significantly more than the characteristic snapshot audit. For example, auditing the PSM programme of a large refining complex would take highly experienced staff several weeks under the best conditions.


Evaluation of numerous audits from several different refineries revealed major flaws in auditing techniques. In many cases, the audits were no more than a futile paperwork exercise lacking any substance or performance assessing capabilities.


HYDROCARBON WORLD – VOLUME 5 ISSUE 2 PSM (Australia)


COMAH Seveso Directive


comprise hazard databases that are continuously populated with operating experience and leading process indicators; essentially making the hazard analysis and its associated process safety information evergreen.


PSM (US) RMP


Process safety programmes require at least an annual certification or evaluation of operating procedures. This can degrade into a mere paperwork exercise and is often postponed for as long as possible. When this occurs, it typically produces negligible procedural improvements. Likewise, a proactive PSM programme will conduct operating procedure evaluations with its operators and technicians as often as necessary to ensure they reflect sound operating practice, clearly explain operational risk and include details on available layers of protection.


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