Process Safety - controlled by Leadership, HR and Finance!

Having investigated numerous process incidents over my 30 year career, I have come to some mundane conclusions which I am sure everybody knows...
1. No amount of management systems can prevent an incident unless the top management (leadership) send the correct signals!
2. Process safety is understood by the operations and maintenance departments but not understood by the Human Resources (HR) department!The HR department should play an important role in understanding competencies, skills and training required for Process Safety. But in many organisations, the HR department does not really understand the requirements of process safety. However, in one organization, I did see a very responsive HR department - its head was an ex-operations man!
3. Last, but not the least, Money makes the World go around! Without allocating adequate resources, audit findings, HAZOP reports recommendations, LOPA recommendations, incident investigation recommendations - all of them are meaningless and remain on paper till a catastrophic incident happens.
The BP oil spill has instilled great fear among Oil and Gas companies who fear that the regulations will be tightened very much and they need to spend a lot of resources.
Meanwhile, new management systems keep on coming, companies keep getting certified and accidents continue to occur......
Stay tuned!
PS: I am not a Pessimist!

Understand the hazards of chemicals!

Two students in the USA were reported to be in critical condition early Wednesday after being burned by a chemical explosion.Investigators with the Atlanta Fire Department confirm the students were mixing chemicals for "recreation" and not as part of a legitimate class project. They describe the explosion was an accident.In your lab, are your personnel aware of the hazards of all the chemicals they use? I heard of an incident where a lab technician in a plant (the Lab was located in the control room building) was taking a bottle of solvent and using the lift (elevator) when he accidentally dropped the bottle. The solvent went down the elevators floor and collected in the well. A spark ignited the solvent and the person had to be rescued from the elevator.
Read the article about the students in this link

Transportation emergencies and GIS

I know in India, that the Andhra Pradesh Government is using the Geographical Information System (GIS) for disaster management. I read a paper on "Assessment on the Consequences of LPG Release Accident in the Road Transportation via GIS Approaches". The authors have suggested integrating the results from consequence analysis to GIS tools, to get an accurate picture for disaster management. The advantage of this method is that the point of accident can be moved to any location using the GIS and a new result will be displayed for the LPG accident at the new location.
Read the full article in this link

Emergency Response in the BP oil rig fire - Shades of Piper Alpha?

A detailed article in the Wall Street Journal about the lack of command and control system after the BP oil rig fire eerily brings back memories of the lack of emergency response after Piper Alpha disaster in 1988. In the BP oil rig fire emergency response, the article mentions the following points:
"The chain of command broke down at times during the crisis, according to many crew members. They report that there was disarray on the bridge and pandemonium in the lifeboat area, where some people jumped overboard and others called for boats to be launched only partially filled.
The vessel's written safety procedures appear to have made it difficult to respond swiftly to a disaster that escalated at the speed of the events on April 20. For example, the guidelines require that a rig worker attempting to contain a gas emergency had to call two senior rig officials before deciding what to do. One of them was in the shower during the critical minutes, according to several crew members.
The written procedures required multiple people to jointly make decisions about how to respond to "dangerous" levels of gas—a term that wasn't precisely defined—and some members of the crew were unclear about who had authority to initiate an emergency shutdown of the well".
We seem to not learn from previous disasters like Piper Alpha where similar confusion existed after the fire!
Read the full article in this link.

Fire in Chemical Factory

This youtube video shows a fire in a chemical plant in Andhra Pradesh. The official says that the plant was not in operation since 2006 and did not have permission to operate. But when you see the fire it appears that large quantities of flammable chemicals were stored in vessels that were very close to each other. See the video in this link.

PVC pipes fire

A fire occurred in a place in Netaji Nagar, Thirumullaivoyal, Chennai,where PVC pipes were stored in the open. The photo in the paper indicates voluminous clouds of smoke from the fire.Dioxins are produced during a PVC fire and I am not sure if the public and the firefighters were aware about its hazards.
Another article mentions the following about the hazards of a PVC fire:
During 9-12 July, 1997, at least 400 tonnes of PVC were burned in a fire at Plastimet Inc, Hamilton , Ontario ( Canada ). The facility was storing bales of "jet trimmings" from a manufacturer of automobile interiors. Analysis of soot and ash samples after the PVC fire at the plant, revealed levels of dioxin 66 times higher than permitted even for industrial land. This one fire increased the annual dioxin emissions for the whole of Canada by 4 percent in 1997. Residents were advised not to eat local garden produce or allow their children to play on the grass.
Read the article of the fire in this link
Read the article about hazards of dioxins in this link

Cell phones - an ignition source?

Today, at a meeting of like minded people, we had an interesting discussion on how the use of a cell phone may be dangerous in a classified area.One of the participants opined that is is static electricity when using a cell phone that develops the spark that could prove to be an ignition source. Whatever the methodology, it is prudent not to use cell phones in a classified area. An incident in a platform in the Gulf of Mexico in 2002 is quoted below:
"A contract panel specialist was working on an open platform master control panel that used supply gas for the instrumentation. The contractor stated he was carrying a cellular phone that was turned on and rang while he was working on the panel. The employee claimed that when he flipped the bottom piece of the cellular phone to answer the call, a flash fire occurred causing second degree burns on his forearms and “sunburn” on his nose and cheeks. At the time National Safety Alert No. 5 was issued, it was believed that the cellular phone may have ignited the flammable gases or vapors in the area of the open platform master control panel when the phone had been flipped open to receive the incoming call.As part of the investigation of this fire, they sent the hand held cellular phone involved in the flash fire to an independent third party testing laboratory.
Although the cellular phones’ battery provided sufficient energy to ignite the test gases during the testing it did not. As a result, it was the opinion of the independent third party testing laboratory that it is unlikely that the cellular phone would have ignited a flammable mixture of methane or propane under actual field conditions and that the cause of the flash fire was something other than the cell phone.
Based on this information and investigation, we were unable to conclusively identify the ignition source of the fire. However, we have not ruled out the possibility that the fire could have been ignited by static electricity, a spark from the metal master control panel door coming into contact with a metal handrail, or a wrench striking metal inside the control panel".
Read more of the article in this link
Read a brochure by Shell in this link

Safeguards and Regulators

The BP oil spill incident has thrown up an interesting fact. While regulators in two major oil-producing countries, Norway and Brazil require acoustic switches to activate an underwater valve that shuts down the well even if the oil rig itself is damaged or evacuated, the US regulators do not require them. Norway has had acoustic triggers on almost every offshore rig since 1993. How do regulators decide what is necessary? I suspect this again has to do with study of safety integrity levels and the perception of risk. Read the full article in this link

Decisions and Disasters

An article titled "BP Decisions Set Stage for Disaster" alleges the following about the BP oil spill:
A Wall Street Journal investigation provides the most complete account so far of the fateful decisions that preceded the blast. BP made choices over the course of the project that rendered this well more vulnerable to the blowout, which unleashed a spew of crude oil that engineers are struggling to stanch.
BP, for instance, cut short a procedure involving drilling fluid that is designed to detect gas in the well and remove it before it becomes a problem, according to documents belonging to BP and to the drilling rig's owner and operator, Transocean Ltd.
BP also skipped a quality test of the cement around the pipe—another buffer against gas—despite what BP now says were signs of problems with the cement job and despite a warning from cement contractor Halliburton Co.
Once gas was rising, the design and procedures BP had chosen for the well likely gave this perilous gas an easier path up and out, say well-control experts. There was little keeping the gas from rushing up to the surface after workers, pushing to finish the job, removed a critical safeguard, the heavy drilling fluid known as "mud." BP has admitted a possible "fundamental mistake" in concluding that it was safe to proceed with mud removal, according to a memo from two Congressmen released Tuesday night.
Finally, a BP manager overseeing final well tests apparently had scant experience in deep-water drilling. He told investigators he was on the rig to "learn about deep water".
The last point mentioned scant experience. I am seeing a trend in many Indian Companies that indicates a steep decline in competency of personnel working in chemical industries. The lack of competency is acute at the manager level where decisions are taken during an emergency situation. With the advent of the software industry, many engineers prefer a "soft" job with them rather than sweat it out in a chemical industry! Is the stage set for another Bhopal??
Read more of the article in this link

BP oil spill

An article in the Telegraph mentions that "Tony Hayward, whose leadership during the catastrophe has come under fire, insisted that his success at shaving $4bn off BP's costs last year had not contributed to lower safety standards.
"We have let people down in our defence of the shore, and we are going to redouble our efforts," he said, adding that cuts did "not have anything to do" with the accident". Read more in this link

Process Safety – Reacting after an incident?

Why do organizations react only after incidents occur? Are they missing the signals coming loud and clear before a major incident happens? My understanding of the situation is that as long as nothing happens, process safety is assumed to be working. If anything does happen and there is major incident, all hell breaks loose and quick fix solutions – like becoming World Class in Safety are immediately thought of. What top management in many organizations are missing out is that there are enough warnings in the form of external and internal audit reports, incident reports and near miss reports that sound alarm bells before a major incident occurs. These signals are not picked up by the top management in time. While becoming World Class by adopting a best in class organizations’ practices is good, there is one important difference between copying a system and copying culture. A system can be copied quickly but culture cannot. In Indian conditions, it is very difficult to change culture quickly. It is a 24 by 7 job that has to be done by top management with unwavering support in times of resource crunches also. While a quarter on quarter growth in profits is demanded by the shareholders, why is not a quarter on quarter growth in safety performance also not demanded? I’m perplexed!!!

Confined spaces

Good handbook by MOEF and others in this link. Please share with all your personnel. Big file, be patient!

Blowout Preventer

What is a blowout preventer? In the Deepwater Horizon oil rig disaster, it is suspected that the blowout preventer failed. Please see Wikepedia's explanation given below:
BOPs come in a variety of styles, sizes and pressure ratings, and usually several individual units comprise a BOP stack. Blind rams are designed to close an open wellbore. Pipe rams seal around tubular components in the well (drill pipe, casing, tubing, or coiled tubing). Shear-seal BOPs are fitted with hardened steel shearing surfaces that can actually cut through drill pipe and tool strings, if all other barriers fail. Since BOPs are important for the safety of the crew, as well as the drilling rig and the wellbore itself, BOPs are regularly inspected, tested and refurbished. Tests vary from daily test of functions of critical wells to monthly or less frequent testing of wells with low likelihood of control problems.Any of these BOPs may be installed underwater, normally with two hydraulic actuators.
Deepwater Horizon blowout
After the Deepwater Horizon drilling rig explosion on April 20, 2010, the blowout preventer should have activated itself automatically to avoid an oil spill in the Gulf of Mexico. Underwater robots were sent to manually activate the mechanism's switch, to no avail. As of May 2010[update] it is unknown why it failed.BP representatives suggested that the preventer could have suffered a hydraulic leak. Gamma-ray imaging of the preventer conducted on May 12 and May 13, 2010 showed that the preventer's internal valves were partially closed and were restricting the flow of oil. Whether the valves closed automatically during the explosion or were shut manually by ROV is unknown.
Please see this link for a pdf version powerpoint presentation of BOP (large file-be patient!).

Organisational culture and Process Safety

I always keep wondering why companies spend so much money on implementing behaviour based safety systems when in real life, what is actually required is the behaviour of top management towards process safety! If top management are able to track and recognize the process safety issues that need attending to, then the organizational culture will be conducive for the success of PSM. A walk around by top management to every nook and corner of their plant once in 6 months is adequate for them to understand the PSM issues!Organizational safety culture must come from the top and it is free to implement!
A recent OSHA report mentions the following:
Since the BP Texas City explosion in 2005, OSHA has counted over 20 serious incidents in refineries across the country.
Last year, OSHA completed an investigation of a naphtha piping failure and release, in which the resulting explosion and fire seriously injured three workers; two other workers, relatively young at 49 and 53 years old, died. One of these two workers was killed in the explosion; the other struggled for 13 days in the hospital before dying from severe burns. Within the unit where this rupture occurred, OSHA discovered multiple pipes that were operating below their retirement wall thickness. In fact, the very line that ruptured had previously ruptured and had to be replaced a decade earlier. As this tragedy makes clear, this type of breakdown maintenance is simply unacceptable. Good mechanical integrity programs are absolutely essential to safe refinery operation.
In 2007, water freezing in liquid propane piping resulted in a jet fire and a rapid evacuation of the entire refinery. Three workers, aged 33, 35, and 42 were seriously burned and hospitalized. Investigators found that a Process Hazard Analysis team had recommended installing remotely operable shut-off valves, yet the recommendation was improperly closed as "complete" by the previous owner. In fact, the valves had not been installed at all. The lack of these shut-off valves impeded workers' ability to control the propane release before it ignited. The refinery learned a hard lesson: It is essential to rigorously follow up on PHA findings to ensure that hazards are adequately controlled. Failure to abate serious hazards can have deadly consequences.
In 2008, at another facility, an explosion in a hydrocracking unit blew the head off a process water filter. The debris struck and killed a foreman; he was 53 and had been with the company for 30 years. OSHA's investigation revealed that an inadequate start-up procedure had allowed hydrogen gas and air to accumulate in the top of the filter where it was likely ignited by pyrophoric deposits. OSHA learned that some operators had recognized the hazard and used an undocumented alternate approach that was actually safer, but the procedure had never been updated to incorporate the safer practice. The result of following the faulty procedure was a violent explosion and the needless death of a refinery worker ? and a reminder that having safe, complete, and accurate operating procedures is essential to safe operations in process units.

Facility siting and hazardous chemicals

Greenpeace has sent a blimp over a chemical plant in Delaware, as part of a worldwide campaign to eliminate toxic chemicals. Their focus is on toxic chemicals that could spread in an airborne plume if released suddenly by an accident or terrorist attack. The article mentions that "Federal risk management reports indicate that up to 660,000 people live in potential “downwind” areas at risk in the event of a sudden, complete release from one of the 90-ton chlorine tank cars routinely parked at Edge Moor in east Wilmington.A similar accident at the Chambers Works operation, near the Delaware Memorial Bridge, could endanger 2 million people, by federal estimates".
In India, the problem is more acute.Residential dwellings are allowed to come up in the no man zone surrounding hazardous chemical factories.
Read the full article in this link

Cyclone Laila and Headcount procedures

Today's Times of India carries an article mentioning that cyclone Laila uprooted one of the anchors of the ONGC oil rig Sagar Vijay in the Bay of Bengal, thus destabilising the rig. The article also mentions that ONGC could not give the exact number of people on board at the time of the incident.How robust are your headcount procedures? Test them in surprise tests. During mock drills everything is hunky dory but when an emergency strikes, are your systems telling you the exact number of personnel inside your facility? A proper head count system prevents body counts.
When I worked in the Middle East, I was also a volunteer firefighter for the plant firefighting team. We had an elaborate head count system for firefighters also, to ensure that all firefighters are accounted for. It is better to plan for the worst.It does not cost much but can save lives!

Dust explosions and vacuum cleaners

The CSB has been doing a great service by increasing awareness about dust explosions. Dust explosions can occur in sugar, sawdust, coal, and in fact anything that is combustible including combustible metals. Housekeeping plays a very important part in eliminating dust in the work area. Industrial vacuum cleaners are available to do the job safely. One such cleaner is given in this youtube link. I am not endorsing their product but I thought that the video was a good one!

Hydrogen incidents

Click here for the site. This site is a useful site for incidents connected with hydrogen. For those of you dealing with this dangerous gas, these incidents will help you understand its dangers. Hydrogen is handled in refineries,ammonia plants and chlor alkali industries.

Blowing of natural gas lines

Finally the CSB has released a statement about natural gas blowing of pipelines. A survey has been conducted by CSB. "According to the survey, using natural gas to clean pipes remains the most common single practice in industry, employed by 37% of respondents. The other respondents reported using nitrogen, which is nonflammable, or inherently safer alternatives such as air, steam, or cleaning pigs. On February 25, 2010, eighteen days after the explosion at Kleen Energy, the CSB stated that natural gas blows were “inherently unsafe” and urged industry to seek alternatives".
Even last week, I had warned a natural gas user to prevent the blowing of lines with natural gas itself instead of using nitrogen. Read more of the CSB statement in this link.
Read my earlier post on the topic in this link.

Confined spaces are deadly

Time and again, we realize how deadly a confined space can be but lives continue to be lost. The number of deaths we have read in newspapers involving conservancy workers entering sewers and asphyxiated by hydrogen sulfide are countless. In chemical plants,refineries,food industry, transportation industry, power generation, pulp, paper and other industries, deadly gases can accumulate inside confined spaces. No wonder they are called silent killers. CO, H2S, CO2,CH4, Ammonia, paint,thinners, solvents, nitrogen are all deadly inside a confined space. Reactions that take place inside confined spaces including fermentation can make the confined spaces deadly.
Treat your confined spaces with respect. Have a proper confined space entry permit that is enforced.Read some of the accidents in confined spaces in this link
The CSB video on hazards of nitrogen in confined spaces can be viewed in this link.
Read an interesting article on confined space threats to farmers in this link!