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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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How to Protect Your Ship from Process Safety Hazards

In Star Trek, the ship is protected by a force field called a “shield”.  When under attack, the tactical officer will call out the status of the shield’s integrity, e.g. “shields at 70%, Captain.”  When shields are down to 10%, you know that a breach is imminent unless they retreat or find a way to defeat their attacker.

In a refinery or chemical plant, there is no one calling out the integrity of our protection systems and procedures every few minutes.

But OSHA has specified three specific process safety elements that are critical to Protect Against the Hazards (one of the Five PSM Mindets™) – Pre-Startup Safety Reviews, Mechanical Integrity, and Hot Work Permits.

Taking Action to Prevent Disaster

Once we’ve identified the hazards, it’s time to do something about it. We’ve seen where danger may strike, so we go to the possible sources. We anticipate what could go wrong and prepare for it.

  • We put procedures in place to create consistency and avoid mistakes. But are the procedures being followed? 
  • We add alarms and limits to alert us to known unsafe conditions. Will the appropriate alarms overwhelm the operator in the event of an emergency? 
  • We install systems such as relief valves and automatic shutdowns to react as quickly as physically possible if a dangerous limit is exceeded. Are the safety relief devices and shutdown systems being maintained according to industry standards?  What about the mechanical integrity of the pipes, pumps, or vessels? 

In a process hazard analysis (PHA), safeguards and layers of protection are identified and counted on.  And in our industry, there is a great deal of focus on mechanical integrity and maintaining safety instrumented systems.

The Shield Doesn’t Replace the Crew

In a successful process safety culture, the success or failure of the facility is the responsibility of everyone together – like the crew on Star Trek.

If you are going to help ensure the shields are at maximum strength, here are a few places to start:

  • First, know your enemy – become familiar with the hazards that have been identified and communicated to you.
  • Get to know what the protection layers are for the areas you work in.
  • When there are safe work practices and procedures in place, follow them closely. When you know the “why” behind the procedure, you can be on the lookout for any gaps or concerns.

The safety of a star ship isn’t just dependent on its shield. It depends upon each crew member doing their part and working as a team.

The safety of a facility isn’t just based on the safeguards put in place, but upon each person inside the gate doing their part.

You are more than helping maintain the “shield” – YOU are an integral part of the shield preventing catastrophe so that we may all “live long and prosper”.

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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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.

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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.

More Company Posts

Blog
May 2019 Newsletter [ProvPSM Perspectives]
Spring 2019 has been nonstop for Provenance Consulting. We exhibited at three major industry conferences, volunteered at a number of community events in multiple cities, learned more about deepening our...
Read more
Blog
How Better Access to PHA Data Can Inform Your MOC Process
Read more