Process safety management exceptions

Adopting an exception for a category of work such as that permitted in OSHA s Rule for Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119, is strongly opposed. That standard States ... 

Introduction Priorto September 11, 2001, known as 9/11, chemical process safety activities primarily focused on accidental release risks and excluded most considerations of intentional releases. Security was provided mostly for lesser threats than such extreme acts of violence, and terrorism was generally not provided for except in high-security areas of the world. Exceptions to this included general concerns for sabotage. This was due to a perception that these risks were managed adequately, and that the threat of a terrorist attack, particularly on U.S. chemical manufacturing facilities or transportation system, was remote. 

Management of Change. The work site employer must establish and implement written procedures to manage changes except replacements in kind to facilities that effect a covered process. The standard requires the work site employer and contract employers to inform and train their affected employees on the changes prior to start-up. Process safety information and operating procedures must be updated as necessary. 

The safety management system discussed in Chapter 4 presents the need to include all aspects of system operations in the safety process. Software use and control is no exception. A software safety program should be an integral part of the system safety program. In fact, it would be dangerous to segregate software safety from the rest of the safety process. 

While neutralizing an acid solution with a base (or vice versa) is a relatively simple process when done properly, treating wastes in a container used for accumulation can be considerably more risky. Since RCRA regulations require that waste containers be kept closed except when wastes are being added, treatment must not be exothermic reactions. In addition, it is necessary to have absolute knowledge of all wastes that have been added to the container. Such treatment should not be attempted without considerable planning and full anticipation of the end result. It should be noted that safety is a crucial part of the waste management process safety considerations include the selection of appropriate personal protection... 

Control systems will play a key role in future distributed plants ]139,145]. As a rule of thumb, plants will be smaller and simpler, but the control systems will be much more advanced, of a standard not known today. Plant personnel for operation and managing will ultimately no longer be required, except for start-up, shutdown, and services. This is a shift from a regulatory to a servo role, supported by a sophisticated sequence control. Control is needed for safety issues, operability, and product quality control. Sensors have a central role to provide the information needed for control and modeling and simulation is needed for process models. 

Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement-in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted. 

Other organizational groups are essential to safe and efficient operations. However, except for line management, other functional groups are assigned specific areas of responsibility such as product or process research, engineering, technical service, industrial health, environmental services, analytical development, safety and loss prevention, security, and so on. 

The initial investigation, which can start as soon as in the emergency response is completed, is carried out by what is sometimes referred to as the Go Team. Speed is of the essence at this stage of the investigation. The Go Team provides management with quick feedback as to what happened and what immediate corrective actions may need to be taken at other sites or facilities that share the same technology. The team collects information as soon possible, particularly information that may change quickly such as that do with process conditions. The team should not to dismrb evidence, except as needed to ensure the continued safety of the facility. One of the team s most important tasks is to interview participants and witnesses as soon as possible. People s memories quickly fade, and they start to adjust their memories based on what they think should have happened or on what other people tell them. It is vital that these people be asked to tell their story as soon as possible. 

Safety auditing is an exceptionally valuable process, but time-consuming and expensive. Safety professionals should not be surprised if informed managements expect substantial results from the audit process that benefit their operations. Safety and health professionals conducting audits should prepare well for their exit interviews. This means ... 

Another process-related issue that was encountered in outlining the HEAT/ACT PSC was the occasional temptation to include too much process information in the safety case outline. This was evident, for example, in the first attempt to show how explicit top-level safety requirements would be satisfied. This divided the requirements into two classes - those that could be satisfied directly by compliance with airworthiness directives, and those that were more complex and would require exceptional activities or the involvement of specialists. As the argument structures for these two classes of requirement were developed, it became clear that their evidence requirements were essentially identical. The split had been introduced because of ttic strong perception that they would be satisfied in fundamentally different ways whilst this was true from a process management perspective, it was an unnecessary complication in the safety case. 

As with other forms of tangible rewards, the challenge is to support the observation and feedback processes without generating false reporting. In general, the use of bonuses tied to safety is not recommended, except when safety is included as part of an overall management scorecard. 

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