Process Safety Change

A Process Safety Change is any modification which is significant enough to require a... 

Some examples of Process Safety Change include, but are not limited to ... 

Unless some discipline is imposed, engineering personnel, especially where contractors are involved, will define far more alarms than plant operations require. This situation may be addressed by simply setting the alarm hmits to values such that the alarms never occur. However, changes in alarms and alarm hmits are changes from the perspec tive of the Process Safety Management regulations. It is prudent to impose the necessary discipline to avoid an excessive number of alarms. Potential guidelines are as follows ... 

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

CCPS Y-28. Management of Change—Computer Based Training Module. American Institute of Chemical Engineers, Center for Chemical Process Safety, New York. 

It is incumbent upon the toller to develop and follow internal management systems as appropriate to support business needs, production needs, process safety, environmental responsibility, and worker health. The selection process should have considered whether or not satisfactory systems are in place. Nevertheless, the contract or auxiliary documents may be the vehicle used to help ensure that the system reviewed is the system actually used for completing the toll in question. Within the process safety management system, the management of change and training elements are essential subsystems. 

Did the Process Safety Information Change O YES O NO ( items indicates PSI) (If YES, initiate PSM-ADM-08, Pre-Startup Safety Review)... 

The safety status of the process should be periodically reviewed against the guiding principles for the original design. Monitoring of add-ons can detect potentially dangerous modifications. Process hazards analysis or process safety audits are useful tools for this review. Documentation of inherently safer principles is critical to ensure that future changes don t nullify the positive features of the initial installation. 

Many maintenance risks are related to unclear and unsafe procedures. See Chapter 6. Additional information regarding management of change can be found in Chapter 7 of the CCPS Guidelines for Technical Management of Chemical Process Safety (CCPS, 1989b). 

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits. 

Organizational changes that may have an impact on process safety Variance procedures Temporary changes Permanent changes... 

Make sure your company s short-term objectives (e.g., updating aii P IDs) are consistent with broader PSM goais (e.g., accurate process safety information), sind communicate them in ways that clearly encourage work habits and procedures that support PSM performance. For exampie, your employees need to understand that the company will achieve its goal of reducing reportable incidents by changing its PSM procedures, not its reporting processes. 

These timeframes are guesstimates at this point, and are subject to change. Similarly, at each stage of the process there will be a number of activities that may affect overall scheduling. On completion of this process, we are confident that Company X will be well on its way toward achieving its goal of industry leadership in process safety management. 

Process Safety Information Process Hazard Analysis Management of Change Operating Procedures Safe Work Practices Training... 

Despite the lack of interest in human factors issues in the CPI in the past, the situation is now changing. In 1985, Trevor Kletz published his landmark book on human error in the CPI An Engineer s View of Human Error (revised in 1991). Several other books by the same author e.g., Kletz (1994b) have also addressed the issue of human factors in case studies. Two other publications have also been concerned specifically with human factors in the process industry Lorenzo (1990) was commissioned by the Chemical Manufacturers Association in the USA, and Mill (1992), published by the U.K. Institution of Chemical Engineers. In 1992, CCPS and other organizations sponsored a conference on Human Factors and Human Reliability in Process Safety (CCPS, 1992c). This was further evidence of the growing interest in the topic within the CPI. 

Sociotechnical approach (control of error through changes in management policy and culture) Occupational/process safety Effects of organizational factors on safety Policy aspects Culture Interviews Surveys Organizational redesign Total Quality Management More frequent in recent years... 

There are a variety of process safety risks one needs to assess with chemical processes. In general, these risks will lead to an evaluation of the potential for the process to have precipitous changes in temperature and or pressure that lead to secondary events such as detonations, explosions, over pressurizations, fires, and so forth. The most cost-effective way of avoiding these sorts of risks is through the adoption of inherent safety principles. Inherent safety principles are very similar to and complementary to pollution prevention principles, where one attempts to use a hierarchy of approaches to avoid and/or reduce the risk of an adverse event. The reader is referred elsewhere to a more complete treatment of this important area of process design. ... 

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