Page 18 - OHS, May 2020

IH: CHEMICAL SAFETY
Bringing Process Safety Management into the Digital Era
Why worry about reporting if you can prevent the release in the first place?
BY SEAN BALDRY
The regulatory landscape for process indus- tries in the United States became a little more onerous earlier this year. On February 21, 2020, the U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final rule outlin- ing new reporting requirements for facilities that suffer accidental releases of highly-hazardous chemicals.1
The new rule sets out stringent timelines for re- porting accidental releases of hazardous chemicals that result in serious harm to persons or extensive environmental damage. It also outlines the specific in- formation that must be released to the CSB at the time of the report. Organizations that fail to meet these new reporting obligations could face stiffer regulatory enforcement, including citations and fines.
While the new rule came into effect on March 23, 2020, CSB announced that it would provide the industry with a one-year grace period, so businesses could make the necessary changes to their operations in order to meet these new requirements, before ac- tive enforcement begins.
It’s understandable that, in light of these changes, process facilities will focus their efforts on updating their reporting workflows and emergency response protocols, so they’ll be able to comply with the rule if, and when, such a release occurs.
Companies would be better served to instead use the time available to assess whether their entire Process Safety Management (PSM) system is effec- tive enough to detect and control potential process failures before they result in harmful releases. Why worry about reporting if you can prevent the release in the first place? Remember the adage: an ounce of prevention is worth a pound of cure.
Prevention is the Best Medicine
PSM’s main purpose is to prevent unwanted releases of highly-hazardous chemicals. When properly de- signed, well implemented and rigorously maintained, PSM programs provide organizations with vast capac- ity to control risk, while building resiliency that en- ables the system to adsorb “shocks” without it result- ing in catastrophic failure.
So then why do hazardous releases continue to occur? Organizations that struggle to maintain effective PSM programs are often challenged due to a confluence of factors: highly-complex processes, a lack of technical and process risk expertise, the speed and scale of pro- cess changes, conflicting priorities, and a lack of re- sources to manage system outputs. Without solutions to manage these variables effectively, businesses are on borrowed time, and the potential for highly dan-
gerous releases becomes more of a question of “when” than “if.” It’s critical that employers begin to invest in solutions that will help them manage this burden, while keeping them competitive.
Enhancing your PSM Capabilities
Organizations that leverage software to assist in man- aging process safety are better positioned to limit their operational risk exposure, prevent potential acciden- tal releases and achieve regulatory compliance. But how specifically does software help? Let’s take a quick look at three of the most critical steps in your PSM process—process hazard analysis, management of change, and pre-startup safety reviews—and discuss how adopting a digital approach to PSM can help to effectively reduce the risk of unwanted releases.
Process Hazard Analysis
The ability to effectively mitigate risks posed by haz- ards within any complex system starts with identifying where, why and under what conditions those hazards may arise. A Process Hazard Analysis (PHA) refers to the thorough, orderly and systematic approach to identify, evaluate and control process-related hazards involving hazardous chemicals.
But completing a PHA is not the simplest of tasks. N. Hyatt describes it as “the industrial equivalent of a trip to the dentist—usually arduous and painstaking.”2 For organizations seeking to realize full value from PHAs, they need to discover ways of making the pro- cess easier to complete. Two of the biggest issues with completing PHAs is coordination and consistency.
In advance of any analysis, relevant process safe- ty information that describes the hazards posed by equipment, technology or the products themselves needs to be collected. Software solutions that enable users to easily assemble equipment inventories and process flow diagrams are particularly useful during these data-gathering exercises. Solutions that afford access to managed SDS libraries enable key chemical information—from toxicity or reactivity data to ex- posure limits—to be included directly in the analysis. This coordination of data is invaluable as it provides PHA teams with the right information to make in- formed judgments on risk.
Most PSM standards do not dictate the specific way in which a PHA must be performed. Instead, they require that employers select a PHA methodology appropriate for the complexity of the process, from what-if analyses to HAZOP and FMEA. These tools can be quite challenging to navigate, especially for those who do not complete them regularly.
14 Occupational Health & Safety | MAY 2020
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