Maximum ‘return on audit’ depends on zero loss of containment

Maximum ‘return on audit’ depends on zero loss of containment

PSM internal audit survey results

My thanks to the 22 persons who participated in the survey. The survey results are as follows:

1.  Over 65% of repsondents say that their PSM internal audit is carried out once in 6 months
2. All respondents say that they audit all their elements at a time
3. 30% of respondents replied saying that they audit process safety culture also
4. 50% of respondents use a rating system for the PSM internal audits
5. 85% of respondents replied saying that they feel the PSM issues are coming out during the audits
6. 60% felt that management was not viewing the PSM internal audits seriously
7. 85% felt that technical competency for conducting PSM internal audits needs improvement
8. 50% of the respondents say they classify audit findings as per risk.

 
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Process safety management internal audit survey

I would appreciate if, for those who are running PSM systems, you answer this survey (8 questions). Results will be published in the blog later.
Take the survey in this link.


 Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

The importance of pre start up safety review

OSHA has cited a company in the US that produces of liquid natural gas through a cryogenic process." The incident occurred while employees were restarting the process. Cryogenic liquids were improperly routed through equipment not rated to withstand extreme cold temperatures, resulting in the explosion and fire.The willful violation is for failing to conduct an analysis of pre-startup safety conditions and systematically managing changes to process-related technology, equipment, procedures and facilities".
Read the citation in this link.

Contribute to the surviving victims of Bhopal by buying my book "Practical Process Safety Management"

Refinery cited for PSM violations

A news item mentions that a refinery has been cited in the US for PSM violations. Included in the serious violations are "failing to investigate incidents as being related to process safety management, equipment repair, address inconsistent thickness measurements collected during pressure vessel inspections, maintain accurate and updated engineering drawings, and ensure that written operating procedures were certified as being current and accurate".
Read the article in this link

Chemical company cited for process safety violations

A chemical company has been cited by OSHA for 11 process safety violations. They include the following
"failing to provide a written plan for employee participation, written shift change procedures, adequate process chemistry documentation, pressure relief system design and design basis, electrical classification documentation, and written mechanical integrity procedures.
Additionally, the company’s operating procedures lacked documentation of chemical properties and hazards, documentation of control measures to occur after physical and inhalation exposure to hazardous chemicals, and emergency shutdown procedures. The company also failed to ensure equipment complied with recognized and generally accepted good engineering practices, conduct compliance audits, conduct initial process hazard analysis, inspect and test equipment, and manage changes to the operating procedures before they were made".
Read the article in this link.

OSHA proposes fines

A news article mentions the following : OSHA has proposed fining a company $119,000/=  for 17 serious safety violations. These include "allowing cylinders to be exposed to physical damage; having inaccurate field verifications on tanks and values; using equipment that was not in compliance with recognized and generally accepted good engineering practices; failing to have clear written operating instructions for processes such as unloading hydrogen fluoride into storage tanks and switching storage tanks; failing to address human factors in relation to remote operating valves on the hydrogen fluoride storage tanks; failing to document and resolve issues addressed by the process hazard analysis team; failing to establish written procedures to maintain the integrity of process equipment; failing to implement written emergency operating procedures for emptying hydrogen fluoride tanks; failing to perform appropriate checks and inspections to ensure equipment was properly installed; and failing to establish and implement written procedures to manage changes to process chemicals, equipment and procedures. The company also was cited for a deficient incident report that did not include factors contributing to the vapor release and the recommendation resulting from the internal investigation. "
Read the article in this link.

Process Safety Violations and fines

OSHA has cited a chemical plant for 18 violations, 16 of them considered serious and one labeled "willful."
The news article mentions the following:
"A willful violation is one committed with knowledge of and disregard for the law, or with indifference to worker safety.
OSHA's serious violations included failure to provide a proper hydrogen gas detection system, over-pressure protection, emergency egress, personal protective equipment and hazard communication training. It also cited AL Solutions for failing to safely store flammable materials and ensure the safe use of forklifts.
A minor violation was for failing to keep proper injury and illness records.
OSHA said AL Solutions is now in its Severe Violators Enforcement Program, designed to focus on "recalcitrant employers that endanger workers by committing willful, repeat or failure-to-abate violations."
Read the article in this link.

How do we make PSM work in India?

PSM is an administrative control over process safety. The elements may vary from 14 to 30 and above but finally it is an administrative control. Human beings take decisions that can have an effect on PSM. For example, the CSB has released the safety video of the Bayer Crop science explosion where it mentions an interlock was bypassed by operators with the knowledge of the manager. Whatever systems you have, there will be a time, when under pressure for production, mistakes can happen and the administrative control fails. Behaviour based safety, developing process safety culture, operational discipline all are dependent on the Human Being. Especially the ones at the top…

Why do the same mistakes keep happening over and over again? It’s because of a basic human trait ….. if   nothing has happened for so many years, one does not expect to see anything bad in the future, too.

What you do not see may cost you terribly!! Whose job is it to see that the human being at the operational level does not deviate from set procedures? It’s the job of the top management. But it’s a chicken and egg situation. Today’s top management in Chemical Plants are under severe pressure themselves and often loose sight of what is going on at the ground level. Whenever a new system that brings in top management involvement is implemented, I often see, that initially, everything is working all right and top management are focused on process safety. As time gets by, and people (including top management) and priorities change, the effectiveness of PSM changes, too. I feel that the only way to make PSM work is through effective legal enforcement. In this connection, I am happy to see in the CSB video that the Costa County officials have been able to bring down incidents by effective auditing of PSM systems.

I do not see this happening in India where PSM is not even Mandatory! Let’s not wait for another Bhopal to occur. Do write in your comments.

Refinery cited for multiple safety hazards

OSHA has cited Pasadena Refining Services Inc. with 21 serious violations for exposing workers to multiple safety and health hazards at the company's facility in Pasadena. Proposed penalties total $115,650.
"The serious violations include failing to provide properly constructed scaffolds, provide supports to hold piping, provide controls to prevent valves from closing, conduct annual confined space audits, ensure guard rails are adequate, and ensure that operating procedures are up-to-date and accurate. A serious violation is one in which there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known".

It is interesting to note that these violations have occurred even though PSM is mandatory.
Read the article in this link

Fire in a chlor alkali plant and citations from OSHA

A blast in a chlor alkali plant in China has been reported to have killed three people. Resons are being investigated. Read the article in this link.
In another development, OSHA has cited Huntsman Petrochemical of Houston Texas of violations in PSM. The article is quoted below:
"OSHA began its investigation June 7 in response to an incident in one of the company’s process units.Alleged serious violations include failing to incorporate operating procedures for all safety devices in the company’s operating guide; adequately train employees in safe operating procedures; properly shut down process equipment; identify and isolate all energy sources to the equipment; and to ensure lockout/tagout energy isolating devices such as line valves prior to employees performing maintenance on the equipment. A serious citation is issued when there is a substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known. The company has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s area director in Houston, or contest the citations and penalties before the independent Occupational Safety and Health Review Commission".

Read the article in this link.

PSM violations in refinery

OSHA has fined a Louisiana refinery for deficiencies in its PSM program.
Serious violations found include failing to provide accurate process safety information for piping and instrumentation diagrams, conduct incident investigations, provide written operating procedures, resolve recommended actions resulting from compliance audits, and adequately address the citing of control rooms and employees working in process units.
Read more of the article in this link.

Enforcing Process Safety Management

I always wonder that even in the US where PSM is mandatory and companies face stiff fines, there are always violations taking place. Recently OSHA has proposed to fine a seafood company a total of $279,000, for deficiencies in its process safety management program. "The inspection identified other PSM hazards that resulted in 12 serious citations, with $84,000 in proposed fines. These conditions included failing to update process safety information, conduct an incident investigation of a January 2001 ammonia leak, certify or evaluate the PSM program every three years as required, establish and implement procedures to maintain changes in the process, and provide and document employee training".
Read the full article in this link

Process Safety Information

I was reading an article where it mentions that a company in the USA was penalized for not having proper process safety information. Specifically the article mentions the following:
"The piping system was not provided with labels to indicate the contents or direction of flow. The proposed penalty is $5,600.

• The process safety information pertaining to the equipment in the process did not include the piping and instrument diagrams. The proposed penalty is $5,600.
• The process hazard analysis did not address the hazards of the process. The proposed penalty is $5,600.
• The standard operating procedures for the anhydrous ammonia rail car offloading rack did not address how the operator was to inspect the coupling or ensure that the coupling was serviceable. The proposed penalty is $5,600.
• The employer did not establish and implement written procedures to maintain the ongoing mechanical integrity of process equipment. The proposed penalty is $5,600.
• The ammonia offloading rack, including the coupling on the liquid ammonia offloading arm, had threads that were worn, resulting in the coupling coming apart, releasing more than 8,000 pounds of ammonia.
• The alarm system for evacuation voice alert was unintelligible in all locations within buildings on the plant site. The proposed penalty is $2,400".
Read the complete article in this link.

Process Safety - OSHA penalises plastics plant

OSHA has penalized a plastics plant for deficiencies. The article says "The violations include the company's failure to properly contain polyvinyl chloride dust particles; evaluate contractors' safety programs and procedures; properly inspect process equipment; provide fire retardant clothing for employees; require employees to wear adequate eye protection with side shields; provide proper training; and provide employees with an infirmary, clinic, or person trained in first aid. Additionally, inspectors identified hazards involving a lack of machine guarding; a deficient process safety management program; inadequate lockout/tagout procedures for energy sources; and unguarded machinery, floor holes, and walkways. OSHA issues a serious citation when there is substantial probability that death or serious physical harm could result and the employer knew, or should have known, of the hazard".

It is interesting to note that the investigation was launched on the basis of a complaint of an employee! Read the full article in this link.

Process safety -Pressure Relief and Flame out devices - Take care of them!

According to a news release dated 8.3.2010, "The U.S. Department of Labor's Occupational Safety and Health Administration has cited BP North American Inc. and BP-Husky Refining LLC's refinery in Oregon, Ohio, with 42 alleged willful violations, including 39 on a per-instance basis, and 20 alleged serious violations for exposing workers to a variety of hazards including failure to provide adequate pressure relief for process units. Proposed penalties total $3,042,000.Forty-two willful citations with proposed penalties totaling $2,940,000 are proposed as follows:

1. Thirty-eight (38) per-instance, willful citations with penalties totaling $2,660,000 allege as follows:
1. Twenty-six instances allege deficient pressure relief, a violation of 29 CFR parts 1910.119(d)(3) and 1910.119(j)(5), with total penalties of $1,820,000;
2. Three instances allege the lack of flame-out protection on heaters and a furnace, a violation of 29 CFR 1910.119(d)(3), with total penalties of $210,000; and
3. Nine instances allege facility-siting hazards, a violation of 29 CFR 1910.119(e)(5), with total penalties of $630,000.
2. Four willful citations with penalties totaling $280,000, allege as follows:
1. Lack of pressure vessel information, a violation of 29 CFR 1910.119(d)(3), with a penalty of $70,000;
2. Cross-connections between fire-emergency water supplies and process systems, a violation of 29 CFR parts 1910.119(d)(3) and 1910.119(e)(5), with a penalty of $70,000;
3. Failure to conduct thickness measurements at designated test sites and as required at the flare header, a violation of 29 CFR 1910.119(j)(4)(ii), with a penalty of $70,000; and
4. Failure to conduct thickness measurements in accordance with RAGAGEP, a violation of 29 CFR 1910.119(j)(4)(iii), with a penalty of $70,000".
Of particular interest is the twenty six instances of deficient pressure relief and three instances of lack of flame out protection.