A Process Safety Management Company

Tag: Operations

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 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.

PHA, Webinar

The Importance of Operating Procedures & How to Use Them Effectively

Could your facility be under-utilizing your operating procedures? Find out how to use them beyond day-to-day operations.

This 60-minute sponsored webinar starts off by looking at why operating procedures are essential to your safety and efficiency, OSHA requirements related to their content and generation and common mistakes made in the process. You’ll then go on to consider the ways operating procedures can be used beyond the day to day. Learn how operating procedures are a vital part of your PHAs and closely linked to PSI. In addition, discover effective methods for maintaining, storing and accessing operating procedures. By the end of the webinar, you’ll have a better understanding of operating procedures and how to use them more effectively in your facility.

Learn more about our PHA Services


Justin Phillips, P.E.

Justin Phillips has over eight years of onshore and offshore oil & gas process engineering and project execution experience. His technical experience includes process design with specialty in flare and relief systems.

Justin is the Relief Systems Line of Service Manager at Provenance Consulting, LLC. He holds a B.S. in Chemical Engineering from Texas A&M University in College Station, Texas and is a Licensed Professional Engineer in the State of Texas.