Understanding risk and the role of leadership in process safety management
Process safety, by definition, tries to prevent major events, disasters, catastrophes, big fires, explosions and toxic releases. The problem with process safety, however, is that the risk of damage is ever-present. You only have to look at the history of companies that have had process safety disasters to see that there is potential for businesses, of all sizes and in various industries to be wiped out.
Thankfully, catastrophic events occur infrequently, but a lot of effort is needed to ensure this.
Although it’s a difficult task to undertake, process safety management and leadership are core aspects that businesses must focus on, and manage well, to develop a holistic process safety strategy. This complex strategy is a big bag of string that needs untangling and drawing together for it to work.
When you look at the level of risk from your process, especially if you have the potential for major incidents, it should revolve around making informed decisions based upon a level of risk.
To begin correctly implementing and maintaining a process safety management system across an organisation, three essential questions must be answered.
- Do we understand what can go wrong?
This question should probe an understanding of what can happen if control of a process is lost? Will the consequence be a very small fire, or will it be an extremely large dust explosion?
If we don’t understand safety risks, we’re not going to be able to manage the consequences or prevent them from happening again.
So, what are the possible consequences of something going wrong for your business? Once you know what could go wrong, you need to understand the potential outcome of those events happening. This includes everything from minor injuries and equipment failure, all the way up to complete process shutdowns or loss of life.
- What fallbacks are in place in our business to stop potential incidents from occurring?
Are there items of equipment or special processes that can manage various levels of risk? Are there relevant and effective means to use, store and handle flammable liquids or explosive dust? Are there suitable risk management procedures? Are there people and resources in place to identify, monitor and respond to potential incidents? Do all employees have the necessary training and equipment necessary to deal with an incident correctly?
- How do you know these protective measures are effective?
Are protective measures, if called upon, capable of stopping inadvertent events from escalating. Are employees properly trained to use any necessary protective equipment and implement process safety procedures? Are safety measures checked and tested for effectiveness regularly?
These three simple questions form the basic foundation for effective process safety management best practices. They can and should be used when walking around the site and when talking to colleagues, managers and leaders to gauge organisational understanding.
Essentially, do all employees at all levels understand what could go wrong? To maintain a process safety management system across an organisation, all three questions must be answered. Once these risks are understood, you can put in place appropriate protective measures, so inadvertent incidents don’t occur.
Understanding Process Safety Legislation
By delving into process safety legislation from a range of sources including the HSE, Energy Institute (UK), CCPS (Centre for Chemical Process Safety) and OSHA (USA), there are guidelines that aid in understanding and implementing answers to these three core questions.
Whether this is needed to gather relevant process safety information for a business, or if this is what the regulator requires, it is a level of proportionality that is needed to answer the three core PSM questions.
Process safety legislation and guidance aim to provide a holistic understanding of the level of risk and how to understand this risk. Hazard identification is key, because if we fail to understand the hazard, then we won’t be able to put in place measures to enforce the successful management of hazards going forward.
Hazard Identification and HAZOPs
Hazard identification is the first step in the completion of a thorough risk assessment, as it helps to identify potential hazards that may occur during an operation or process. There are lots of techniques to identify hazards, with one of the main techniques being a HAZOP (hazard and operability study), alongside other hazard identification studies i.e. LOPA, HRA, and QRA.
Although companies will rarely decide to not undertake a HAZOP, many are not sufficiently well-executed. A lot of information is needed before a good HAZOP can be achieved. A HAZOP team must understand what it is that they are trying to achieve, what are the basic functionalities and more complex properties of the plant, what hazards could occur throughout a process and how big any problems or incidents could be?
This is termed extent and severity – how big is the problem and how much harm can it do?
There is a lot of work that must be completed before a HAZOP study can start. This is where chemical reaction hazard assessments and other related assessments should be undertaken to really understand potential problems. Although these issues are usually raised in a good HAZOP, without a solid foundation, it may be difficult to actually answer these specificities.
A HAZOP is generally done using 2D representations of processes in terms of processing instrument diagrams (P&ID). Yet many businesses have got into the habit of not keeping their process and instrument diagrams up to date.
Remember if new storage tanks, hazardous chemicals or handling techniques have changed even slightly, they must be documented and discussed. Although plant changes, of any size, may occur for a variety of reasons, the associated drawings must be updated accordingly. If the drawings are not updated, it could have a detrimental effect on the output of the HAZOP.
Practising Inherent Safety
There has recently been more emphasis placed on practising inherent safety. In essence, inherent safety asks how can we operate with something that has a lower inherent hazard to it?
A recent COMAH upper-tier client, supported by Sigma-HSE, carried out processes using a particular reactive chemical, which they have many years of experience in handling safely. However, the material is flammable and toxic and capable of resulting in major accident hazards. A request by a sister company was made to manufacture another new product using the existing technology.
This was easy for the site to achieve quickly only requiring slight modification to the plant and operating at an increased pressure of the raw material – hence greater hazard ranges; so, it made great business sense.
However, when the regulators got involved, they asked questions. Are there any other synthetic routes to this product which may not involve substances capable of major accident hazards? Can we see your written justification within your management of change process that alternative processes were at least considered by you?
As this business wasn’t able to convince the regulator that they’d gone through these risk assessment exercises and because their management of change system didn’t prompt the employees to consider such questions, they eventually got into very deep water with the regulators.
The regulators didn’t stop them from manufacturing their product, but trouble occurred because they had not justified an appropriate way of creating this new process.
Many businesses these days are lean and mean and have a highly responsive attitude towards achieving client satisfaction. Although we might want to be able to satisfy our clients as quickly as possible, completing thorough HAZOPs, implementing holistic PSM practices and putting processes through management of change are not quick actions.
Understanding what can go wrong
How do we know our process safety is robust enough?
Once we understand what can go wrong, we can put in place measures to prevent, control and mitigate inadvertent incidents. These measures generally reduce the likelihood of irregular activities occurring.
Although some measures may reduce hazardous consequences, the primary control should be the reduction of likelihood. Pressure relief valves and cooling systems are examples of critical steps within a procedure that must be correctly managed and work effectively. There should be tight enough control over processes that the safety-critical equipment doesn’t operate, but if they are called upon to operate, they prevent, control or mitigate.
Safety-critical equipment must be properly designed, constructed, installed, operated, inspected and maintained to form part of the process safety lifecycle. This is what process safety management systems are for, they remind us about the importance of looking after assets, permit to work systems and management of change systems.
There is, however, a precursor to this, which isn’t specified under the law, but
is referred to as the ‘golden rule’. Process designs should follow what’s called ‘accepted good practice’ at a minimum.
General minimum standard guidance from the regulators or from standard practices across the process industries should be set and an organisational rule book must be created. The rule book must be updated and changed over time. Even if a HAZOP was recently undertaken if procedures change another hazard identification exercise must be completed. This is normally called the process hazard analysis (PHA).
A PHA is completed to catch the things that were missed when the original HAZOP was completed. Although the HAZOP is a very robust and methodological approach, it’s only as good as the people in the room and how fresh their minds are.
People often say that the PHAs are not of sufficient quality as there is a belief that because the plant’s been running for the past 20 or 30 years, nothing significant has changed. This has led the PHA to become a mere tick-box exercise. What many internal PHA teams tend not to do, which is very important, is to ask themselves one question; if we were building this plant today, how different would it be?
There are many pieces of old accepted good practices for dealing with toxic materials. The bulk storage of these hazardous materials in the open air for quick dispersal in case of a leak is no longer currently considered acceptable good practice. In this particular case, an operation isn’t really satisfying the law in the UK and it’s not really satisfying the continuous improvement processes that should be present within a business.
So, when an organization undertakes a PHA, it is important to ask these questions:
- What are the most significant changes that have taken place since the last HAZOP?
- What is our updated understanding of how this particular process works and what could happen in different situations?
A PHA should be used not just as a safety check but as an input into continuous improvement programmes that should loop into the culture of the entire organisation.
How do we know these protective measures are effective?
So how is process safety performance measured? How is the organisation learning? How is the business learning to improve?
Businesses can look at performance measurement via the following methods:
– Historical trends (looking at how often particular events or problems have occurred)
– Process hazards analysis (documenting all potential accidents and their causes)
– Critical control points checking (tracking the state of specific equipment or processes at defined intervals)
But the most effective performance measurement system that should be implemented in any process industry is leadership responsibility. Process safety requires more than simply following legislative requirements, it requires organisations to continuously improve. This is a key facet of any business; if a business doesn’t continuously improve, it won’t be sustainable.
Process safety management isn’t just engineering, it should be viewed as the optimal point between engineering and management. Both of these elements have one thing in common, they all require human impact.
The way we behave is very critical to doing this correctly, and this is set by the leadership.
For the leadership to be effective, they’ve got to understand what can go wrong. They’ve got to understand what measures are in place. They’ve got to understand what performance monitoring data provides and act accordingly. This is why there’s such a big push for leadership in the process safety industry as leaders must be direct safety practitioners.
If we can have management systems that prompt employees to do things in certain ways, and if the leaders side-track safety systems by focusing on production rate rather than safety, then these standards across the organisation will slip.
Ultimately, there’s very, very little new in process safety. Events happen, investigations occur, and root causes are discovered, but there’s very little that’s new that comes out of it.
However, if the leadership aren’t interested and if there isn’t clear positive leadership attached to process safety, then our behaviours as employees working for those leaders will be affected negatively. There must be a commitment to do things right, and there has to be a level of involvement and contact, to convince all employees that process safety is important.
Do we understand what can go wrong? What have we got within our business to stop these potential incidents? How do know these protective measures are effective?
Answering these three questions are the basic fundamentals for creating and maintaining an effective process safety management program across an organisation. As we create, monitor and update answers to these questions, it will allow organisations to determine whether current process safety strategies are acceptable, whether protective measures are effective and if there are any areas where further improvement (in continual improvement mode) is needed.
Leaders, task teams and individual employees can use monitoring data as a tool for continuous improvement. By looking at the graphs and trends in process safety incidents over time, managers can identify patterns that might indicate when improvements may be necessary on their part.
Leaders must be committed to process safety and risks must be fully understood so appropriate protective measures are put in place, so incidents don’t occur.
Protecting your people, workplaces, business, and the environment depends on the awareness and maintenance of holistic process safety practices and culture across an organisation.
Sigma-HSE offers a comprehensive range of process safety consultancy and training solutions. Our team of engineers, technical experts and process safety leaders are on hand to discuss your requirements and will collaborate with you to provide actionable solutions that are both cost and time effective.