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EXTERNAL AUDITORS

Agenda

Part 1 Review PSM & Auditing

Part 2 Employee Participation
Part 3 Operating Procedure
Part 4 Training

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RULES OF MY CONFERENCE

Relax and Learn

Participate in Discussions
Share Experiences
Share Best Practices
Ask Questions
Enjoy Yourself

Part 1 Review PSM & Auditing

What is PSM
Why PSM
What is External Auditing
What is internal Auditing
What External Auditing can help

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PSM

Flixborough

Flixborough,
UK 1974
5

Bhopal, India Dec. 2-3, 1984

2,000 deaths
Isocyanate release
Methyl Isocyanate Tank Rupture and Release

Source: United Nations

Environment Programme

PSM

Photo Source: Indian state government

of Madhya Pradesh

On the night of December 2-3, 1984, a sudden release of about 30 metric tons of methyl isocyanate (MIC) occurred at
the Union Carbide pesticide plant at Bhopal, India. The accident was a result of poor safety management practices,
poor early warning systems, and the lack of community preparedness. The accident led to the death of over 2,800
people (other estimates put the immediate death toll as high as 8000) living in the vicinity and caused respiratory
damage and eye damage to over 20,000 others. At least 200,000 people fled Bhopal during the week after the
accident. Estimates of the damage vary widely between $350 million to as high as $3 billion.

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PSM

LEGISLATURE, AGENCY ACTIONS

Clean Air Act of 1990 required
OSHA and EPA to issue
regulations

OSHA Process Safety
Management (PSM) regulations
first published in 1990, effective
1992

EPA Risk Management Program
(RMP) regulations published in
1992, effective in 1996.

PSM & RMP

Process Safety Management (PSM) &

Risk Management Plan (RMP)
Whats the Difference?
PSM - OSHA
Protects the Workforce
Protects Contractors
Protects Visitors to the Facility
Basically Protects the
Workplace
29 CFR PART 1910-119 PROCESS SAFETY
MANAGEMENT

EPA 40CFR-68
Protects the Community
Protects the General Public
Around the Facility
Protects Adjacent Facilities
Such as Schools & Hospitals
40 CFR PART 68CHEMICAL
ACCIDENT
PREVENTION PROVISIONS

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OSHA PSM PROGRAM GOALS

PSM & RMP

HISTORY

Targets protecting workers, on-site personnel

OSHA list of Highly Hazardous Chemicals focused on
immediate, on-site hazards

Seeks implementation across chemical processing
industry of key findings from incident investigations

Requires maintaining documents and records as long as
the life of the process

Is a performance-based standard, identifies minimum
program expectations

EPA RMP PROGRAM GOALS

PSM & RMP

HISTORY

Primarily concerned with preventing off-site

consequences, short- and long-term

Separate list of chemicals of concern (primarily
airborne materials)

Adopted or referenced OSHA PSM as basis
of program

Requires submitting various documents, plans and
updates to the agency

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29 CFR PART 1910-119

PROCESS

PSM

SAFETY MANAGEMENT 40 CFR PART 68CHEMICAL

ACCIDENT PREVENTION PROVISIONS

 (Employee
Participation)

(Process Safety Information)

(Process Hazard Analysis)
 & (Operating
Procedures)
 (Training)

(Contractor Safety Management)
 +
+ (Pre-startup Safety Review)

 (Mechanical
Integrity)
 +
(Hot Work Permits)
(Non - routine Work
Permits)
 + (Management
of Change)
 (Incident
Investigation)

(Emergency Planning and
Response)

(Compliance Audits)
 (Trade Secrets)
11

KEY POINTS OF PROCESS SAFETY

WHY PSM

MANAGEMENT

(Incident) +
(Accident)
Accident)


(Catastrophic)

12

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PRODUCTS

1992 PSM(eff)

ISO 14000

. ISO 9000
. ISO 14000
18001

1987
ISO 9000

PERSON

1999 ISO
18001

1996

1990 PSM (issue)

ENVIRONMENT

1992-1996 EPA-RPM

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WHY PSM
PERSON

PROCESS

PRODUCT

ENVIRONMENT
APPLICATION

process

A
is any activity or combination of activities
including any use, storage, manufacturing, handling or the on-site
movement of highly hazardous chemicals (HHCs) as defined by

OSHA and the Environmental Protection Agency

1987 ISO 9000 PRODUCT; 1992-1996 ISO 14000 ENVIRONMENT ;1999 ISO 18001 PERSON14

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MAKE THE PROCESS DRIVE

SAFELY

PERSON

PROCESS

PRODUCT

IF THE PROCESS IS RIGHT

OTHERS WILL BE TAKE CARE

HOW 
HOW ) +
( Catastrophic )

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SAFETY
CONTROL

SAFETY CONTROL
Personal Protection Control
Administration Control
Engineering Control
Personal Protection Control
Personal Protection Equipment (PPE)


Administration Control
Hazard Communication, Label, Sign
Regulation

Engineering Control
Process Engineering Design

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SSAP

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Accident

The Swiss cheese model of

organisational accidents

Hazards

Some holes due

To active failures

Other holes due to

latent conditions

Losses
Successive layers of defences
This diagram, sometimes known as the cheese model, was developed by the
Reasons
Cheese
Model
British psychology professor
James Reason
to show
the way in which several
James
Reason,
to Eurocontrol
2004
barriers or systems are
in place
to presentation
prevent a triggering
event
from developing into a
major incident.
19

20

10

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LOPA

HSSE Standards
Community Emergency Response
Plant Emergency Response
Plant Emergency Response
Post-Release Physical Protection e.g. Dikes, Barriers

Physical Protection (RVs, Deluge, etc)

Safety Instrumented Function
Critical Alarms and
Human Intervention
Process Control
System
Inherently Safe
Design- Codes/
Standards

HSSE : Health, Safety, Security and Environment

21

LOPA

TYPICAL PROTECTION LAYER

Process Protection

Physical
Protection

Deviation
control Alarm/Alert
LL, L
Emergency Shutdown
HH,H
Return to safe state

Mitigation Process

Emergency
Response
Community EMR
22

11

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PLANT CONTROL

PLANT & PROCESS

INTEGRATION

23

PLANT CONTROL

Modernized PLANT CONTROL

ARCHITECTURE
Remote alarms

PLANT DIAGNOSIS
OPTIMIZATION
PREDICTIVE
MAINTENANCE

BUSINESS INFORMATION
NETWORK
Online
Machinery
Health

PLAT OPERATION
Abnormal Situation
ALERT

Asset
Management
Systems

PLANT CONTROL NETWORK

SAFETY
SHUTDOWN

PLANT FIELD
INSTRUMENT

PLANT
EQUIPMENT

24

12

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Process.
Mechanical Safety Action (if available)

Plant Shut-down

Wild Process
parameter
If Operator takes action
High Alarm level

DCS
Functionality
Certain Process
parameter value

High Control level

Normal behavior
Low Control level
Time
25

Safety System.
Mechanical Safety Action (if available)

Plant Shut-down
Safety Instrumented
System Functionality

ESD controlled
Trip level

Wild Process
parameter
If Operator takes action
High Alarm level

DCS
Functionality
Certain Process
parameter value

High Control level

Normal behavior
Low Control level
Time
26

13

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DEVIATION ALARM

System Safety
Engineering

27

System Failures
Incident / Near Miss

System Safety
Engineering

System Failures that result to Near Miss/Incident

Equipment Failure
Process Deviation
People - 40%
Equipment
40%
Human Interaction Error
Process - 20%

 + +
 ++ & &

 ++
28

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System Safety
Engineering

In cident P yram id:

1

S erio us/D isablin g/Fatalities

10

M edical A id C ase

30

P ro perty Lo ss/1 st A id
Treatm ent

600

N ear M isses
U n safe B eh avio rs/C o nditio ns

10,000

A proactive approach focuses on

these categories, but be careful you
may miss the really serious ones!

The Canadian Society for Chemical Engineering (CSChE)

29

HOW TO REDUCE UNSAVE

BEHAVIOURS

UNSAVE
BEHAVIO
URS

NEAR
MISS

INCIDENT

ACCIDENT

CATASTR
OPHIC

15

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HUMAN
RELIABILITY

MACHINE & OPERATION

RELIABILITY
MECHANICAL INTEGRITY
MANAGEMENT OF CHANGE
PRE STARTUP REVIEW

People - 40%
Equipment - 40%

SOP
CONTRACTOR SAFETY
TRAINING
EMPLOYEE PARTICIPATION
HOT WORK PERMIT

Process - 20%

PROCESS
RELIABLITY

PROCESS SAFETY INFORMATION

PROCESS HAZARD ANALYSIS
INCIDENT INVESTIGATION
EMERGENCY RESPONSE
COMPLIANCE AUDIT
TRADE SECRET

16