The most successful companies know not only what (the “what”) needs to be done but also how (the “how”) to do it.  In process safety we mostly know “what” is required to have a good system.  But to be successful we must know “how” to go about doing this.  Every company, regardless of size, has limited resources.  How do we prioritize those resources and to what degree of detail do we implement the “what”  is crucial to the success.  In periodic postings I will try to convey my thoughts on how to comply with all the requirements, prioritizing  them (using risk for starters) and applying efficiencies without compromising quality.  This posting deals with process safety culture and the application of process safety in your facility.

Process Safety Culture- What is It?  Process safety culture refers to the collective values, beliefs, and behaviors of an organization that prioritize safety in the design, operation, and maintenance of processes that handle hazardous substances. It’s about creating an environment where safety is deeply embedded in every aspect of the organization’s operations.  A good safety culture is the cornerstone of a good process safety system.

Creating such an environment is a difficult undertaking that must be initiated by management at the top and permeate and be sustainable throughout the organization.  Management must show a strong and visible commitment to safety.  The typical pronouncements that the company is dedicated to have a strong safety environment and the goal will be to have “zero incidents” won’t work by itself.  The employees must see management commitment in everyday activities.  Some activities that will reinforce that commitment:

• The facility manager will make rounds in randomly selected parts of the facility on a periodic basis (more often than once a month), talk to operators, comment on the observed housekeeping, and listen to concerns about the safety of the operations.  Follow up on the observations through line management.  This takes time – it is necessary.
• Ensure that incidents and near-misses are investigated, and the results are promptly shared with the employees.
• Carefully examine events which led to loss of production or facility damage because of an operator’s action and if that action was taken because of the person’s concern for an impending serious  incident, rather than scold, praise the person for erring on the side of safety.
• On the other hand, show that unsafe behavior is not tolerated.  Unsafe acts should result in a reprimand and, if it continues, may lead to termination.
• And, very importantly, provide resources and prioritize closure of PHA and MOC recommendations.  It is assumed that those studies were risk based, and the open items represent measurable risk to the facility.

Application. Unfortunately, U.S. OSHA, in issuing the PSM Standard (29 CFR 1910.119) exempted parts of a facility from application of the standard based on quantities of hazardous chemicals and some conditions.  This led many companies to implement a much less rigorous process safety system in those areas, many being tank farms.  The continuing occurrence of tank fires across the industry, some with catastrophic results, has shown after analysis that it was a bad decision.  If the thought was that less resources would be needed to manage process safety, it is the wrong assumption.  Having two different management systems for parts of the facility makes it more difficult, and costlier, to manage the facility.  You would have different standards, training, competencies, etc. leading to more errors, and losing the flexibility of a work force that can be moved from one area to another based on need.

If the idea was that if an incident occurs in the exempt areas, you wouldn’t be punished by OSHA with a resulting reputation loss.  But having an incident (that could probably be avoided with a strong safety system), by itself entails a certain loss of reputation.  The dilemma can easily be solved by having a uniform process safety system in place across the company and marking in a plot plan the areas that are not covered by the Standard, together with a document that states that determination.  Thus, you would be safer, and the potential fines and loss of reputation would be eliminated.

The most successful companies know not only what (the “what”) needs to be done but also how (the “how”) to do it.  If you are in a line of business you mostly know what is needed to run the business.  Important for success, though, is how you are going to execute your business plan.  How are you going to use your limited resources and how are you going to allocate them among all the “whats” that need to get done?  Are you going to have permanent, contract employees, or both?  Does the success of your business require competent people?  Do you have plans for unforeseen events?  There are many ways for achieving your objectives and you must have a vision for which ones are best.

All this applies to process safety.  Process safety has evolved significantly in the last 30 years, but we still see too many incidents involving injuries and fatalities, derailments with toxic releases that necessitate evacuations, and large-scale loss of containment with significant environmental impacts.  These are the events that make the national, and sometimes world, news.  Unfortunately, there are many other events where there is “only” one fatality  or a local fire, and they sometimes, but not always, make the local paper.

Why do we continue to have all these incidents if we know what is to be done?  We got guidance on what needs to be done from the U.S. Chemical Manufacturers Association before OSHA came on board, then OSHA promulgated the PSM Standard in 1992 (more than 30 years ago!) containing 14 elements that need to be complied with, later followed by 20 elements provided by CCPS, and down the line directives from the EU (e.g. the Seveso Directives).  Other countries are following through. Large companies, using the economy of scale, can have experts for every element of PSM.  Smaller companies do not have that luxury and must be efficient.  But many procedures become too detailed and cumbersome and sometimes this leads to a “check the box”  performance.

In periodic postings I will try to convey my thoughts on how to comply with all the requirements, prioritizing  them (using risk for starters) and applying efficiencies without compromising quality.  These are not going to be procedures or instructions but rather the essence, informally describing sometimes seemingly unorthodox ways to make process safety work for all sizes of companies with varying resources.  In the next posting I’ll talk about safety culture and the application of PSM beyond compliance with regulations.