A Process Safety Management Company

Process Safety Management

Data Management, Mechanical Integrity, Process Safety Management, Webinar

What are “Good Faith Efforts”? PSM/RMP Compliance Discretion and COVID-19 [Webinar]

In response to the health and safety concern presented by the coronavirus in essential industries, OSHA and the EPA have both published enforcement discretion notices that are meant to add some breathing room for facilities juggling regulatory compliance with personal safety. However, the stipulations put in place for facilities to lean on these temporary enforcement policies, especially with regard to the OSHA PSM and EPA RMP standards, are vague as to what facilities must do to qualify for leniency in compliance.

Facilities must demonstrate “good faith efforts”, but what does that really mean with regard to PSM/RPM program elements?Read more

Data Management, PHA, Process Safety Management, Relief Systems, Webinar

Crisis Operations: Is Your PSM Program at Risk? [Webinar]

The COVID-19 pandemic crisis forced rapid-fire decision making nearly overnight for most businesses, including refineries and chemical manufacturers. The balance between protecting employees and managing processes safely was struck in most facilities through focusing on two things – staffing changes (reduced onsite presence) and spending changes (delayed/canceled projects, budget cuts). Now that we have found a new rhythm, it’s time to assess the unintended consequences of those forced decisions.

Specifically, have these deviations in day-to-day operations created more risks to your PSM program?Read more

Blog, Process Safety Management

How Telling Stories Creates Hazard Transparency

Most people enjoy a good mystery.

Writers like Agatha Christie are successful in bringing us into the intrigue by giving just enough clues for us to come up with our own hypothesis of “whodunit”, while withholding enough insight so that at the end, the master detective solves the case and uncovers the unexpected villain.

We are excited by the challenge of looking for clues, reading between the lines, searching for the truth.

For me as an engineer, that love of investigating a mystery contributes to the thrill of problem solving.

Dangers of “Whodunit” in Process Safety

When it comes to understanding process hazards in a facility, knowing the “whodunit” of process hazards goes beyond elementary entertainment.

OSHA designated the elements of Compliance Audits and Trade Secrets to make sure that everyone at the facility knows the whole story, not just a few clues.  Nothing is meant to be hidden from the employee, and no one wants a “surprise ending.”

These two elements also make up the fifth PSM Mindset™, Transparency.

Audits and sharing trade secrets allows everyone who needs it to see the real story of the process:  What are the risks, the protections, the gaps, and the strengths of the processes and procedures in place?

We Don’t Need Sherlocks – We Need Storytellers

As a mindset, it is also about each person on-site being willing to be transparent.

Are you willing to share your stories – what worked and, even more important, what hasn’t worked and why?

We all learn more from stories than from a list of facts.  We can put ourselves into the story, and our minds remember stories especially when the story invokes an emotion – This makes the memory more “sticky.”

If you have years of experience in the petrochemical industry, you have stories to share.  If you are new to the industry, there are lots of stories to hear, so be listening.

Sharing Experiences is Safer and Smarter

I have a vivid memory of a leak detected in the Hydrofluoric Acid Alkylation Unit flare accumulation drum.

Typically the unit would be shut down so the pipe could be replaced.  But that would send all the hazardous materials in the unit right through the leaking pipe.

I remember meetings with operators, engineers, maintenance, mechanical integrity inspectors and others to come up with a plan to safely address the issue.

We came up with a solution and put a temporary Management of Change form in place, formally getting everyone to sign and stack hands on the plan.

The plan worked, the pipe was bypassed and replaced, and I was left with a lesson on the importance of all eyes looking at the potential solution.

I remember the arguments, the concerns, the checking and double checking that was involved.  In the end, it was a success.

The hazard was addressed because everyone was transparent about their ideas and concerns.

What Should We Share?

If you see something that doesn’t align with a procedure or standard, that is a story that needs to be shared.

Is a level gauge not reading accurately? Don’t dismiss it, share that information.

Is a procedure or policy cumbersome and difficult to navigate? The complexity may be necessary but on the other hand, a simpler approach may work instead.

These are also stories that need to be told.  Each story may be part of a bigger picture.

Remember, there is no Sherlock Holmes or master detective on staff, so we all must work as a team to ensure the hidden risks are brought to light and the hazards are exposed.

Read More from the Five PSM Mindsets™ Series:

This series is based on the concept of the Five PSM Mindsets™ – a unique way to apply OSHA’s 14 PSM elements to your PSM program. Watch this on-demand webinar from Sarah McDuffee for a better understanding of the Five PSM Mindsets™ and how adopting them can create a better process safety culture in your facility.
Sarah McDuffee
About the Author
Sarah McDuffee
Sarah McDuffee joined Provenance Consulting in 2015 as Training Program Coordinator, creating internal and external training courses for industry clients on various Process Safety Management topics. Her background includes 19 years of experience in the refining/chemical industry. She has a B.S. in Chemical Engineering from Montana State University.  Her 11 years with a major refining company included project design, process unit support and distillation consulting roles.

She completed her Masters in Adult Education and Training with Colorado State University in 2011 while working for Northern Oklahoma College as an engineering instructor for 5 years. During that time, Sarah also served as Program Director for the Process Technology program for four years, partnering with industry on curriculum, recruiting and placement.

Blog, Process Safety Management

How to Use Patterns to Identify Process Safety Hazards

A baby is constantly exploring new things and looking for familiar shapes, colors, and other patterns to help him or her understand the world around them.  They are constantly experiencing brand new objects, which their brains must fit into an ever-expanding repository of categories. Sometimes the categorization starts as “not a circle” until they create a new category of “it’s a square!”

One of the ways that we learn new things is to try to categorize a new idea or image with others that we already know.

Patterns in Process Safety

Patterns and trends – defining something by what it IS and ISN’T – help us identify hazards in the workplace.

And sometimes the way to recognize a hazard is by first categorizing it as “not safe.”

I’ve been told that one way to recognize counterfeit money is to be intimately familiar with real money.  Then any anomaly stands out and is identified as “not real.”

What if we approached process safety the same way?

What if we learn the procedures for our safe work practices so well that when something is different, it stands out as “not a circle?”

And once I recognize the deviation, I also need to know the reasoning behind the procedure well enough to understand possible consequences!

Ripple Effects of Deviations

Let’s take an example from the steps of Management of Change.  Most MOC procedures require a relief systems expert to review each process change. But consider if the change is a simple trim on a control valve which doesn’t seem connected to the relief valve downstream at all.

It might be tempting to skip the relief system review step, but in an emergency, that change would send more material to the relief valve than it can handle. In this case, failing to identify the risk due to a presumption of understanding could have serious consequences.

Owning Your Role in Identifying Hazards

As we said, the best way to identify deviations and hazards, is to be intimately familiar with the processes and procedures so that when something is “off”, you notice it.

You can’t notice when something isn’t right if you don’t know what it should be.

If there’s an item in a procedure that doesn’t make sense, find someone to explain it to you.  Bettering your understanding will increase your ownership of the procedure and ensure you don’t miss critical steps because you didn’t realize they were critical.

Looking for deviations is a common way for operating a process unit.

Consider safe operating limits.  Alarms go off when the process variable (temperature, pressure, flow) exceeds or falls below a certain safe range.

When you take the time to study the procedures and standards, it allows for an internal alarm to sound in your brain because something isn’t fitting the pattern. “Wait a minute, this P&ID doesn’t match what is in the field…” or “shouldn’t there be a plug on this bleeder?”

What Does “Safe” Looks Like?

At one company I worked for, we often asked the question “What does good look like?”

I challenge each of us as we go about our work to ask the question, “What does SAFE look like?”

When safe designs, procedures, and standards become the patterns you are most familiar with, you can quickly see the outliers and address the hazards.

Read More from the Five PSM Mindsets™ Series:

This series is based on the concept of the Five PSM Mindsets™ – a unique way to apply OSHA’s 14 PSM elements to your PSM program. Watch this on-demand webinar from Sarah McDuffee for a better understanding of the Five PSM Mindsets™ and how adopting them can create a better process safety culture in your facility.
Sarah McDuffee
About the Author
Sarah McDuffee
Sarah McDuffee joined Provenance Consulting in 2015 as Training Program Coordinator, creating internal and external training courses for industry clients on various Process Safety Management topics. Her background includes 19 years of experience in the refining/chemical industry. She has a B.S. in Chemical Engineering from Montana State University.  Her 11 years with a major refining company included project design, process unit support and distillation consulting roles.

She completed her Masters in Adult Education and Training with Colorado State University in 2011 while working for Northern Oklahoma College as an engineering instructor for 5 years. During that time, Sarah also served as Program Director for the Process Technology program for four years, partnering with industry on curriculum, recruiting and placement.