A Process Safety Management Company

Tag: Management of Change (MOC)

Blog, Data Management, PHA

How Better Access to PHA Data Can Inform Your MOC Process

© Vanderbilt University Center for Teaching

In Bloom’s Taxonomy, “evaluation” is the fifth of six levels. Learners progress from remembering, to understanding, to applying, analyzing and then evaluating and finally creating.

One of the most important “evaluating” exercises in Process Safety Management (PSM) is the Process Hazard Analysis (PHA).

In a PHA, a group of people with expertise in the process (operators, engineers, etc.) gather to look at all the equipment and chemistry and technology involved.

They detail out each possible hazard, cause, consequence and safeguard. They review the risks, make recommendations, and put all of this information into a report.

Re-Evaluating in Process Safety

When you re-evaluate something, it’s typically done with an eye towards any changes or new information.

In PSM, we re-evaluate the hazards when we make a change through the management of change (MOC) process or when there has been an incident and we want to see what went wrong and if we missed something in the first evaluation of the hazard.

When you want to evaluate something again, it would seem natural to look at the original evaluation.

In significant incident investigations, the PHA report is often pulled up to determine if something was missed or a recommendation wasn’t completed.

But during the course of an MOC, it is very rare for the original PHA to be referenced.

Even if the project involves significant change and generates its own PHA, it is not always standard practice to reference the original unit PHA.

One reason for this is the great complexity of the information in a PHA and the challenges in finding a specific area.

In short, the PHA details aren’t always easily accessible.

And as I said, it’s not a standard practice.  Most MOC procedures I’m familiar with do not include a checkbox for looking at the original PHA.

In my many years as a process engineer, I was never advised to look at the PHA for the unit when doing a change. We simply did our own mini-PHA with the group of engineers and operators on hand.

PHA Data Can Be a Valuable Resource

But what about the great level of time and expertise that had already been invested in the most recent PHA? What if something we changed had been counted on for a safeguard? Maybe we caught it in our project group, but what if we didn’t?

There are many advantages to making PHA results and comments more structured and searchable.

One of those is the opportunity for engineers and operators to easily reference nodes and sections of a unit and review the hazards when a change is being proposed and reviewed.

It is one more way we can all have the best information on hand to make wise and safe decisions.


Our Managing Partner Patrick Nonhof presented a webinar on “Can PHA Be Big Data”. He discusses applicable, practical ways to make your PHA data more useful by addressing the barriers to its usability – lack of structure and lack of accessibility. The possibilities for data analysis and continual value-add on your PHA data is an untapped resource at many facilities. Let us help you realize that potential.

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.

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Blog

What to Know to Succeed at Your First ChemE Job

Looking back on my time before joining the professional workforce, I admittedly did not have a realistic understanding of what an “engineer” truly did day-to-day. While studying chemical engineering at the University of Texas at Austin, I imagined a fair amount of my early professional years would be dominated by working technical issues – completing calculations, running simulations, and designing processes.

One of my biggest surprises upon entering the workforce was that unlike my imaginings, a lot of my time was spent determining which information is correct and pertinent and how to best communicate results and issues with others.

While solving problems (a key skill of being an engineer) is an important ability, I found the mark of a great engineer is the ability to communicate difficult ideas, problems, and solutions in such a way that they can be understood easily.

This does not mean “dumbing it down” or speaking down to your coworkers or colleagues; rather, it means latching onto the most important details that your client, colleague or superior needs and explaining it concisely and accurately.

My time here at Provenance Consulting and working with clients in the industry and countless chemical engineers, young and seasoned alike, has helped me hone in on three things that make the difference between a young engineer who “gets it” and one that is stuck in that college classroom. Take a page from my book – it’ll give you a head start on nailing those first few years of your career.

#1: Engineering is WHAT You Do, but in Industry, PSM is HOW You Do It

A common complaint from young chemical engineers, specifically in regulated facilities, is an annoyance with Management of Change (MOC) and other similar programs that ensure Process Safety Management (PSM) compliance. MOCs are seen as a hassle mainly because young engineers don’t understand the value of them or how the facility’s MOCs are implemented. One benefit of a proper, functioning MOC program is that it makes the facility’s Process Safety Information – the P&IDs, H&MBs, line listings – continually accurate. One of the most surprising things to me when I began working with drawings was a common refrain from numerous operators and engineers across a number of companies and facilities:

“You can’t trust the drawings”

This phrase means that the drawings – which are critically important for new projects and general understanding of a facility – are admitted to not be correct. One of the challenges for a young engineer is figuring out which data sources to use to obtain the “correct” data, since that data may exist in four different places. For example, a maximum allowable working pressure (MAWP) might be in inspection software, relief systems design basis, original vessel calculations, on a P&ID, or any number of internal databases.

If these numbers differ, what is the correct value that should be used? At different facilities, the answer is often different.

A functioning MOC program not only ensures the facility is safe and compliant, but it also ensures that your data is correct across a number of different data sources at the facility. This is just one example of the ripple effect these parts of Process Safety have across the facility.

#2: The “Boring” Stuff Matters to Your Boss’s Boss

Ensuring you record and report correct data not only saves you time as you do subsequent work, it also becomes invaluable to the people who will use your work down the road. Large capital projects can go significantly over-budget based on the amount of time needed to verify or correct data that “should” already be correct.

Engineers who understand and ensure that information is correct are an important asset to their company. Your boss (and his boss) will notice whether he can trust your data or if there is a pattern of verification that always needs to happen.

When you are building your professional reputation, it’s these little things that can make the difference between becoming the engineer that managers can rely on, and the engineer who is inconsistent. Trust me – you want to be the former!

#3: Undocumented Institutional Knowledge is a Major Asset: USE IT

Often, a new engineer feels overwhelmed by the new responsibilities and tasks at a facility. It can feel like you are barely treading water. One of the best sources of information and help in any facility is the know-how that exists among the engineers and operators who have been at the plant for a while: the “institutional knowledge” of the facility.

Visit the field, ask questions and – more importantly – listen to the answers that they provide; most experienced personnel enjoy sharing their knowledge if you take an interest.

Oftentimes the most confusing parts of a plant or process make sense if you take the time to look at them in the field and learn the nuances of the facility. Additionally, speaking with more senior personnel allows you to develop personal relationships with them, which builds trust with your colleagues and allows for a mutual respect and better ability to work through issues as they arise.

Just because someone doesn’t have an engineering degree doesn’t mean you know more than they.

Some of these men (and women) at your facility have worked with the equipment since before you were born. The design specs may say it should work a certain way, but those operators and seasoned personnel are a wealth of practical information. Listening to them could save you significant time (and money). You’ve got to work with the entire team to be successful – you can’t just stick with engineers if you want to advance. Learn to work with everyone and understand the value they bring to the company.

Be Great, not Just Good

Being successful at engineering in the real world includes doing things that seem “boring” or “extra” and it means working with people who have a different skill set and experience than yours. A good engineer recognizes that and does what they have to. A GREAT engineer sees the ripple effect of those “small” tasks, the importance of process safety in all that we do, and that the people in our organizations with experience on the ground can be some of our greatest resources.

About the Author – James Topp

James Topp is a PSM Consultant with Provenance Consulting. A graduate from the University of Texas BS Chemical Engineering Class of 2016, he’s been with Provenance since 2015. His roles have included a Co-op position, intern and full time engineer.

During his tenure with Provenance, James has focused on many areas of Process Safety. Mainly, he has worked in Relief Systems engineering for multiple clients and plants including chemical plants, midstream facilities, and refineries across multiple states; completed a maximum intended inventory for a large midstream facility; facilitated MOC coordination and auditing for refineries; and utilized ProvPSM’s ARTS software for PSI reconciliation – among many other projects.

In his personal life, James enjoys reading, travel, skiing, and telling people how the 2008 Longhorns were robbed of winning the Big XII Championship and competing for a national title, despite the fact that they had the same record as and had beaten the eventual Big XII champion, OU, on a neutral site.

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PHA, Webinar

Realizing the Benefits of a Truly Integrated PHA Process

This webinar highlights and discusses the benefits and importance of integrating the Process Hazard Analysis (PHA) process with your Management of Change (MOC) process, conducting a PHA on Capital and Plant Projects, and ensuring the adequacy of the PHA team membership. Apart from the obvious benefit of identifying hazards and mitigating them before the process is built, PHAs can also be used to identify issues with the design, screen out potential surprises and costly system modifications, and help with budgeting and revenue allocation for the project life cycle.

In order to accomplish successful integration and realize the inherent benefits, it is imperative to obtain buy-in from the management team and the appropriate subject matter experts that should be part of the Process Hazard Analysis team.

By the end of this presentation, you should be able to present your organization with specific examples to support these types of discussions and open the door for approaching leadership to implement some or all of the suggested practices and approaches.

Presenter

Nestor Paraliticci

Nestor Paraliticci is a former Senior PHA Facilitator at Provenance Consulting. He has over 10 years of experience in the Oil and Gas Industry along with over 10 years in the Safety and Health Industry. With a focus in PHA/LOPA facilitation and training, he also provides process safety management services including process safety compliance, incident investigation, and project management.

Nestor holds a B.S. in Mechanical Engineering from the University of Detroit in Detroit, Michigan.

Embrace Change by Establishing Comprehensive Management of Change (MOC) Processes.

This webinar addresses the importance of effectively managing change by establishing comprehensive Management of Change (MOC) processes. The components of a comprehensive process will be examined through real-world examples of managing change and methods for assessing and improving change management effectiveness will be provided.

Change is inevitable, and without an effective MOC program, even perceived minor changes can result in major disruptions from both safety and business perspectives.

An effective MOC program starts with consistent recognition of change.  Once a change is recognized:

  • A basis for the change is established;
  • Impacts of the change are evaluated via consistent, approved methods
  • The change is implemented;
  • Reviews are conducted to ensure that the implemented change is in accordance with the intent of the design;
  • Actions are assigned as needed and tracked to completion;
  • Affected personnel are notified and/or trained to ensure safe “operation” of the change;
  • Applicable documentation is updated; and
  • Information is archived as necessary to properly record the change.

An organization can assess the effectiveness of its MOC program by defining parameters of a change and examining historical records to determine if changes have been managed appropriately. For instance, do the data management systems reflect the current data and documentation for existing systems? Have employees been made aware of or trained in recent changes to systems or processes? Have changes been implemented without the appropriate level of review and approval?

 

 

Link to Download Presentation 

 

 

Presenter(s):

kindy

Scott Kindy

Scott Kindy is a Process Safety Management (PSM) Consultant and Project Manager at Provenance Consulting. He has over six (6) years of experience in PSM related project execution in the Oil and Gas Industry, and he has managed multiple projects related specifically to Management of Change (MOC). He has expertise in project execution related to additional elements of PSM including Process Safety Information (PSI) data management, Incident Investigation, Facility Siting, Process Hazard Analysis (PHA), and compliance auditing. He also has experience with the EPA Risk Management Plan (RMP) Rule and the associated elements.