Speech by Jordan Barab of OSHA on Process Safety Management

At a speech by an OSHA official Jordan Barab,the following have been highlighted by the speaker:
"First: Effective process safety programs and strong workplace health and safety culture are critical for success in preventing catastrophic events.
Second: Industries need to learn from their mistakes. We know the major causes and we know the remedies. Yet lessons learned are not applied and the same problems surface to threaten workers again and again.
Third -- and I'm not telling you anything you don't already know: Numbers don't tell the whole story. Focusing on low DART rates alone won't protect you from disaster. New metrics are needed.
Now, let's explore these ideas a bit more.
Let's look at Concept number one: Effective process safety management systems and workplace safety culture are critical for success in preventing catastrophic events.
In the Baker Panel Report, issued after the BP Texas City explosion, the panel devoted considerable space to the importance of effective process safety systems and the need to build a strong corporate safety culture.
Process safety failures are typically low-frequency but high-consequence events. Our PSM systems have to be strong, and we cannot wait until we have an incident to discover that they were not.
What it comes down to is organizational culture. To paraphrase Professor Andrew Hopkins (whose work I'm sure you are all aware of): Workplace culture is not just an educational program that gets everyone to be more risk-aware and think "safety first." It's deeper and more ingrained than this. Hopkins and the Center for Chemical Process Safety have defined culture as "the way we do things around here."
What I'm talking about is a set of practices that define the organization and influence the individuals who make up the organization. This kind of pervasive, systemic organizational safety culture must come from the top -- and it must be expressed with transformative action, not just simple slogans.
Next: Concept Number Two: Industry must learn from its mistakes.
For three years now, OSHA has had in place a Refinery Process Safety Management National Emphasis Program. We are deeply troubled by the significant lack of compliance we are finding in our inspections, and with the number of serious refinery problems that continue to occur.
Time and again, our inspectors are finding the same violations in multiple refineries, including those with common ownership -- a clear indication that concerns and findings are not being communicated across corporations or throughout the industry or even within different units in the same refinery.
Consistently throughout the course of the Refinery NEP, we have found that over 70 percent of the citations fall into the top four PSM elements:
• Mechanical Integrity
• Process Safety Information
• Operating Procedures
• Process Hazard Analysis
Let's talk about these top four elements:
1. In MECHANICAL INTEGRITY, problems include failure to perform inspections and tests, and failure to correct deficiencies in a timely manner. This is a particular concern given the aging of refineries in the United States.
2. PROCESS SAFETY INFORMATION, including failure to document compliance with Recognized and Generally Accepted Good Engineering Practices to keep process safety information up to date, and to document the design of emergency pressure relief systems.
3. OPERATING PROCEDURES: failure to establish and follow procedures for key operating phases, such as emergency shutdowns, and using inaccurate or out-of-date procedures.
4. PROCESS HAZARDS ANALYSIS, including lack of attention to human factors and facility siting, and failing to address PHA findings and recommendations in a timely manner -- or, all too often, failing to address them at all.
More than a year ago, OSHA sent a letter to every petroleum plant manager in the country, informing them of these frequently cited hazards. Yet, a year after this letter went out, our inspectors continued to find the same problems in many facilities.
And, finally: Concept Number Three: The problem with numbers.
In any business or organization, one of the problems we find when trying to measure performance is determining how and what we measure.
Unfortunately, as we've discovered, having good numbers on your OSHA 300 logs doesn't correlate with having an effective process safety program.
The classic example of this is BP-Texas City, which had very good injury and illness numbers prior to the 2005 explosion that killed 15 workers and injured 170 others. This tragedy, of course, revealed serious process safety and workplace culture problems at the facility despite the good numbers the company had on paper.
It was noted in press reports that many of the workers killed at BP Texas City had just finished a meeting that touted their safety record. More recently, it was noted in the press that BP executives were on the Deepwater Horizon drill in platform in the Gulf of Mexico, celebrating their excellent safety record shortly before the explosion and fire that led to the deaths of 11 workers. In the days following that catastrophe, company officials continued to wave their low injury and fatality rates as a defense while workers widows planned funerals.
There's a message here: Boasting about favorable safety rates while workers are dying doesn't make a company look like a serious employer; and trade organizations that give awards to their members based solely on a lack of slips, trips and falls doesn't make them look like they are seriously addressing serious problems.
Don't misunderstand me: We need to keep reporting and tracking the numbers -- DART rates are useful -- but employers must not let those numbers lull them into a false sense of security. Looking only at these numbers doesn't warn us about pending doom from cutting corners on process safety
To ensure strong PSM systems, we need to do a better job of identifying useful leading indicators. We all recognize the stock market's investment warning that "past performance is no guarantee of future success." This also applied to the low-frequency, high-consequence events that process safety programs guard against.
The chemical and petrochemical industries must continue to develop and track leading indicators to measure the performance and continuously improve process safety management systems".
In my experience, the points that have been highlighted by the speaker are time and again found lacking in many industries.
Read the full speech in this link

Fire in oil tank

A fire that reportedly started in an oil tank in China that was earlier involved in a fire and had remnants of oil left in it has been reported. It is reported that workers were dismantling the affected tank when it caught fire. Do your job hazard analysis well before any hot work. Its these small things that count.Read the article in this link.

An appeal to readers - Share an incident!

I appeal to readers of this blog to share at least one process incident a month for the benefit of all. You need not mention the company's name. I have been receiving contributions regularly only from a few readers. Even if you write a brief few lines of the incident, it would be enough. Thanks in advance!

Do not forget Bhopal!

Tasleen, 26, who was poisoned by the Bhopal gas leak, cares for her disabled daughter. Photograph by Alex Masi
Every day, the people working in the chemical industry must realise that process safety is for the good of people - people inside the plant and people outside the plant. The horrors of the Bhopal Gas Disaster continue even today. We should not forget Bhopal. I think it will be a good practice for every chemical plant to organise a"Don't Forget Bhopal" day on December 2nd or 3rd every year and remind all managers of the things that went wrong at Bhopal and the lessons learnt from Bhopal..
See the human impact of Bhopal in pictures in this link.

Critical utilities are important for process safety

A news article reports that a refinery in the US has been flaring gas after loosing a big transformer which shut down the grid. I have been observing cases of transformer failures causing plants to either run on reduced capacity or shut down. Electrical systems are key for process safety. They are silent and appear docile but when they fail, they can cause a process upset that may lead to a catastrophe. Maintain you key utility systems with the same fervor as you would maintain your plant!
Read the news article in this link.
The EPA has reported an accident in 1999 involving a plant converting bauxite to alumina in a series of steam-heated pressure vessels. A loss of power stopped all pumps including those that circulated process material through heat exchangers for cooling. However, steam injection stayed on causing temperatures and pressures to increase. Pressure relief valves and piping were blocked or choked with solid deposits hindering their ability to relieve the increasing pressure. Several vessels over-pressured and exploded. The force of the explosion and release of highly corrosive caustic material injured 29 employees and extensively damaged the plant.

A third eye for process safety

After the BP oil rig disaster, authorities in the US are now planning to monitor the critical parameters of all oil rigs from land. An article mentions that the system will "put real-time data from offshore wells in front of government-employed petroleum engineers, who could keep a close watch during vital drilling operations or whenever anomalies are detected.Many drilling contractors and oil companies already use high-tech monitoring systems to keep track of what's happening offshore -- even from computer centers hundreds of miles inland".
Now while this is a good idea, it throws up another window regarding security of such networks. Just imagine if someone was able to unauthorizedly break into these networks!
I personally feel that while technology can be an enabler,it cannot solve all problems. Read the full article in this link.

The importance of corrosion monitoring and control in Process safety

What you do not see is most dangerous in Process Safety. Corrosion is a major problem in the chemical process industry and I am observing a disturbing trend. Regular painting and maintaining of metallic structures and equipment is often delayed when budget pressures dominate. Corrosion is insidious. It slowly and surely kills. If you do not have a good corrosion monitoring and control system, you will one day run out of luck, with disastrous consequences. An article by Dr A K Samant of ONGC mentions the following:"Corrosion control is an important consideration. The periodic monitoring techniques and analytical assessment of corrosion severity is very important and critical since it provides the direction to ensure proper utilisation of materials and corrosion control methodologies. Therefore, correct and appropriate condition assessment techniques should be used to avoid premature failure and ensure maximum safety".
Read the full article in this link

A missing word causes an accident!

Mr Yigal Riezel, Process Safety Management Consultant mentions about an explosion in a gas oil tank that was attributed to the use of nylon rope for taking a sample of tank contents.The operator lowered a nylon rope attached to the sampling device through the sampling hatch on top of the tank. This caused a static electricity spark. After the explosion, in which the operator was killed, the investigation determined that the special precautions mentioned in the tank sampling procedure of tank sampling included the following remark: “In order to reduce the potential for static charge, nylon or polyester rope, cords or clothing should be used”. The committee immediately sent the finding to the originators of the standard and got a fast reaction apologizing for a typing mistake by missing the word NOT before “be used”.

Disposal of old ammonia gas cylinders

I am really not sure whether the guys in this video really know what they are doing. They are reportedly disposing old ammonia cylinders.. watch this video and comment....

LPG tanker accidents

Thanks to Abhay Gujar for sending information about these LPG road tanker accident.
You can view them in this Link

The importance of P & ID's in process safety

The Piping and Instrumentation Drawing (P & ID) is the heart of any plant. There is always a debate about whether your P & ID's reflect the current as built status. With newer people joining the organisation, it is important that your P & ID indicates all the relevant information. Jeff Ratush has made a good presentation which I have attached in this link

No Safety, No Moolah!

A news article mentions that safety will be the sole criterion for judging employee performance in the fourth quarter for BP, as per an internal memo from BP CEO.
"The memo, written by new chief executive Bob Dudley, was sent to employees on Monday, the story said.
The sole criterion for judging performance in the 2010 fourth quarter would be "each business's progress in reducing operational risks and achieving excellent safety and compliance standards," said the memo.
The change was designed to ensure an incident such as the "Deepwater Horizon tragedy" never happens again, the story said".
Read the full article in this link. and in this link too