Process Safety Management (PSM) & Incident Investigation

Key Takeaways from SOCMA’s Safety Series Webinar

Best practices were shared during SOCMA’s Safety Webinar on PSM and Incident Investigation that can be utilized to maintain a consistent level of safety and awareness across all operational areas and for facility workers. Below are key takeaways specialty chemical manufacturers can use as guidance for their facility.

Process Safety Management (PSM)

  • OSHA issued the Process Safety Management of Highly Hazardous Chemicals Standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes.
  • Even if a chemical facility does not utilize process(es) that trigger the OSHA PSM regulation, there are elements of the regulation that are beneficial for all chemical manufacturers. For example, Process Hazard Analysis, Operating Procedures, Training, Emergency Planning and Response, Incident Investigation and Compliance Audits.

Reactive Chemistry Hazards

  • Hazard Recognition: Recognizing and controlling hazards are critical to the prevention of incidents and potentially catastrophic events including fires, explosions, toxic releases and/or high energy events that may occur in a chemical facility.

PHAs, Safety Reviews and LOPA

  • Process Hazard Analysis (PHA): PSM requires a PHA be performed for all regulated processes. A PHA is an assessment of potential hazards, that is anything that puts the employees and equipment at risk within industry.
  • Safety Reviews: For non-PSM processes itis best practice to perform a safety review prior to starting a new process or to evaluate the risk/hazards associated with changes made to a process.
  • Layer of Protection Analysis (LOPA): LOPA can be used to identify safeguards as well. The first layer of protection starts after the initial layer with redundancy and is limited to single cause consequence.
  • HazOps: A HazOp is the method for identifying safety concerns/hazards, their severity/likelihood, and the safeguards in place for their prevention. HazOps can be done around the process unit, each piece of equipment or major step of the process, assessing:
    • Severity and likelihood correspond to a risk ranking.
    • Reduction of the risk ranking corresponds to credits give for safeguards that are already in place, such as policies and procedures, training, etc. Note, these only reduce the likelihood and not the severity of a risk.

Other Methods for Identifying Hazards

  • Job Hazard Analysis (JHA): Job Hazard Analysis (JHA) is a technique that focuses on a job “task” to identify hazards and mitigate them before they occur. JHAs focus on the relationship between the worker, the task, the tools used for the task and the work environment. These can be utilized for both routine and non-routine tasks both in the field and in the office.

Incident Investigation

  • Incident Investigations utilize leading versus lagging indicators to evaluate the following:
  • Safety Training, Including:
    • Near Miss Reporting
    • Implementation of initiatives to improve safety culture
    • Positive feedback and recognition of EHS performance.
    • Risk assessment, identification, and mitigation.
  • Near Miss Reporting, why is it important? Near-miss reporting evaluates potential incidents, enabling a better understanding and anticipation of risks to mitigate more severe incidents that may occur.  
  • Root Cause Analysis: Root Cause Analysis (RCA) Is defined as the process of discovering the root causes of problems to identify appropriate solutions. These solutions can be in the form of corrective and preventative actions:
  • Confirmation that corrective and preventative actions have been completed and/or implemented.
    • Evaluate the efficacy of corrective and preventative actions.
    • An RCA should rely only on facts.
  • Lessons Learned: It is always important to use the knowledge gained during an RCA to help improve procedures, training, etc. They are key for communicating the Root Cause (RC) of an incident, key learnings, and corrective/preventative actions. Communication should be driven towards front-line supervision; this makes employees proactive and less dependent.

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