High-hazard plant management

Data on accidents and incidents show that, for every major accident, there may be dozens or even hundreds of minor incidents, which might have escalated into a worse situation. It is important that the organization tries to learn from minor incidents and anomalies to ensure no repetition and to avoid possible escalation into something worse. Hence, the management of high-hazard plant should have processes in place to review incidents, learn the important lessons, identify the root causes, implement the necessary changes promptly, and educate all the relevant people about the changes. 

This is a situation where a plant appears to be operating successfully, without a major human error problem. However, management are interested in assessing the systems in the plant from the point of view of minimizing the error potential. This type of exercise is particularly relevant for plants dealing with substances or processes with high hazard potential, for example, in terms of... 

The regulatory environment will continue to change. As of this writing, the key regulatory instrument is OSHA 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, which pertains to process safety management within plants in which certain chemicals are present. 

An incident investigation shall be initiated as promptly as possible, but no later than 48 hours following a catastrophic release of highly-hazardous chemicals or one which could reasonably have resulted in a catastrophic release. Upon the recommendation of the shift superintendent or a second-level supervisor, the incident investigation will be initiated by the affected plant manager or one of his superintendents. 

These facilities do not fall under the requirements of OSHA s Process Safety Management of Highly Hazardous Chemicals Explosives and Blasting Agents standard (PSM), 29 CFR 1910.119 (i.e., they are not gas plants, nor are they classified under Standard Industrial Classification code — SIC 1321) ... 

The three major OSHA standards most frequently cited to employers regarding contractor safety are Process Safety Management of Highly Hazardous Chemical (29 CFR 1910.110), Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147), and Hazard Communication Standard (29 CFR 1910.1200). These regulations pertain to the hiring of outside contractors and subcontractors to perform repair work, plant modification, equipment maintenance, etc. Many countries around the world have their comparable standards. 

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