Page 20 - OHS, May 2020

IH: CHEMICAL SAFETY
Intuitive tools built into many software packages are designed to simplify and streamline the PHA task. Built-in menus and con- figured calculations within selected PHA methodologies save time by reducing confusion, while also decreasing simple data-entry errors that could lead to an underestimation of risk. Workflows with integrated notifications ensure PHAs are reviewed regularly, according to regulatory timelines, so they are always up-to-date. However, the true benefit of software comes from its ability—with advanced analytics and business intelligence tools—to identify and track patterns of risks across operations. Such data provides clear actionable insights that better enable organizations to prioritize what needs to be done to reduce the chance of process failure.
It’s often forgotten is that PHA is a team-based exercise. Since front-line workers are the individuals who actively manage these critical processes on a daily basis, their feedback is essential to un- derstand the risks and how best they can be controlled. Yet, workers are often excluded from PHAs, which itself can contribute to disas- ter. Such a lack of participation was cited by the CSB during their investigation of a fatal explosion at a petroleum refinery in Wash- ington state in April 2010, which cost the lives of seven workers.3
Employee engagement is a key ingredient in developing robust safety cultures critical for operational excellence.
Software offers a unique vehicle to engage workers in process safety. Mobile applications now allow workers to view completed PHA’s directly from a mobile device, as well as initiate process change requests, report chemical releases, or even track related ac- tions to help drive closure and accountability. By providing easy ac- cess to highly visual PSM data from a mobile device, organizations can strengthen perceptions of transparency and trust between leaders and the workforce, ensuring that everyone is knowledge- able of and contributing to effective process safety management.
Management of Change
Change in business is constant. Well-executed change can improve productivity, quality and morale. Poorly-managed change creates inefficiency and added costs—it can even lead to catastrophe.
That’s exactly what happened on June 13, 2013. That morning, a maintenance crew at the Williams Olefins petrochemical facility, located on the outskirts of Baton Rouge, La., were responding to an issue with a reboiler on the propylene production line. The work- ers involved at the time decided to restart a standby reboiler to al- low production to continue as they worked to resolve the problem. These workers were unaware, however, that as part of taking the reboiler offline months prior, the propane fuel system feeding the equipment had been isolated from its pressure relief valve. As hot water was re-introduced to the system, the gas pressure from heat- ing the liquid propane mixture inside the reboiler rose to almost 1,200 psi. The pressure caused the vessel to rupture and ignited a massive gas explosion. Two workers were killed in the explosion, and nearly 200 others suffered injuries.
In their subsequent investigation, CSB described a deficient safety culture at the plant, which they attributed to multiple process safety management failures in the years leading up to the event. Particularly, the CSB focused intently on process changes that had occurred over 10 years prior, in which the company “failed to ap- propriately manage and effectively review two significant chang- es that introduced new hazards involving the reboiler.”4 A CSB spokesperson later remarked that engineers had failed to identify
scenarios where the absence of the pressure-relief valve could have introduced unintentional hazards.
The event exemplifies perfectly how vital management of change is to process safety. Yet most organizations struggle with change management at the best of times, often because they lack a well-designed and repeatable workflow to review changes, consider their impacts and ensure actions necessary to mitigate impacts are completed before the change can occur. To complicate matters, paper-based Management of Change processes that rely on indi- viduals to initiate and track changes are subject to human error, forgetfulness, complacency and competing priorities, each increas- ing the risk of unapproved change squeaking through unnoticed.
Creating that integrated workflow is perhaps the chief benefit of shifting to a digital change management process. Software solu- tions optimize our ability to manage change by providing a reli- able platform within which prospective changes can be prioritized, review and assessed. Based on the type of change considered, dis- tinct actions within the change workflow—whether process hazard analyses, development of operating procedures, updates mechani- cal integrity inspections or worker training—can be automatically assigned and tracked. As a result, employers have greater assurance that crucial validation steps in the change workflow aren’t missed or skipped, driving process accountability. Integrated notifications and alerts based on task status available in most software solutions also enable prompt escalations without relying on individuals to initiate them.
While we cannot be certain, one could argue that a digital solution may have assisted Williams Olefins identify potential risks posed by reboiler over-pressurization at the earliest stage in the change process, and may have prompted the consideration of additional safeguards, which may have helped prevent tragedy.
Pre-Startup Safety Review
A final step in bringing any new facility online or executing any pro- cess safety change involves a pre-startup safety review. Yet, organiza- tions facing budgetary pressures and time constraints often forego this “last chance” opportunity to assess operations and mitigate po- tential impacts since they’re too focused on getting the new process up and running. But skipping that review can lead to trouble.
In 2005, a defective pressure control valve in a distillation tower at BP’s Texas City refinery led to a flammable liquid explosion that killed 15 workers and injured nearly 200, resulting in $1.5 billion in financial losses for BP and extensive property damage within a one-mile radius of the plant. The investigation assigned the in- cident, in part, to the fact that the ISOM unit start-up following a maintenance turnaround was “authorized despite having inad- equate staffing, malfunctioning instruments and equipment, and without a pre-startup safety review.”5
Pre-startup safety reviews are employed to verify that: equip- ment is installed and structures are constructed in accordance with good engineering design; adequate operating, maintenance, safety and emergency procedures are in place; Process Hazard Analyses have been conducted and recommendations have been resolved; and workers have been appropriately trained.
Ensuring that all these steps are completed is difficult enough for a single change. But changes are not always sequential. Many occur concurrently with others, which makes keeping track of the status of all tasks within a pre-start review process particularly challenging.
16 Occupational Health & Safety | MAY 2020
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