a global provider of integrated hsse solutions and services · a global provider of integrated hsse...

A GLOBAL PROVIDER OF INTEGRATED HSSE SOLUTIONS AND SERVICES

www.psrg.com

Sponsored by

9th CCPS Asia Pacific Regional Meeting

September 17, 2015

www.psrg.com

Welcome to

Introduction

• Robert J. Weber, P.E. – President/CEO/Director

• Annie Nguyen – Director

PSRG Asia Pacific Pte. Ltd.

JTC Summit

8 Jurong Town Hall Road 24-05

TEL. +65 6818 0967 FAX. +65 6818 0801

EMAIL: [email protected]; [email protected]

mailto:[email protected]


PSRG OVERVIEW • Established, 1997

• More than 80 professionals worldwide averaging 28+ years experience

• Diverse industry experience on 1,000+ projects with more than 750 customers in 74 countries

• Hands-on plant operations experience

• Single source, one stop shop for comprehensive PSM/RMP, and HSSE consulting and field services

• Tailored solutions to meet and exceed customer expectations

• Highly qualified resources enable customers to receive value that far exceeds cost of our services

PSRG Expertise

• Process Safety and Risk Management

• Facilitation of HAZOP/LOPA-SIL Studies, HAZID Studies

• Alarm Rationalization

• ALARP Workshop

• Quantitative Risk Assessment (QRA)

• Safety Case

PSRG Expertise

• Relief Valve and Flare Analysis

• Fire Protection Engineering

• Bow-Tie Analysis

• Audit / Benchmarking

• Training Services: Process Safety Management, PHA-HAZOP

• And much more…..

Upcoming Training

Courses (Singapore)

• November 11: Introduction of PSM

• November 12-13: Design and Implementation of Effective PSM Program

• November 16-19: PHA-HAZOP Leader Training (including LOPA)

FOR MORE INFORMATION AND REGISTRATION DETAILS:

[email protected]


Industries Served

• Exploration & Production • Gas Processing/ LNG • Petroleum Refining • Petrochemical and Chemicals • Specialty Chemicals • Pipelines and Terminals • Onshore / Offshore • Power Generation • Light / Heavy Manufacturing • Light / Heavy Construction • Food Processing • Pharmaceutical

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• History Incidents and Lessons Learned

• PSM – Common Deficiencies

• Conclusion

Presentation Outline

Industry Incidents and Lessons

Learned

Flixborough, UK (1974) Nypro UK

(Cyclohexane release & explosion)

• Killed 28 people and seriously

injured 36 out of a total of only

72 people on site at the time.

• The number of casualties

would have been more if the

incident had occurred on a

weekday.

• Offsite consequences resulted

in 53 reported injuries.

The Incident

• A 20 inch diameter temporary bypass pipe

around a reactor (R-5) Jack-knifed and failed

under thermal expansion stress.

• 40 tons of cyclohexane was released into a the

congested reactor area.

• Within 2 minutes, a vapor cloud ignited and a

Detonation Class VCE took place (35 tons TNT

Equiv).

The Consequences

• 28 Plant people killed.

• 53 people wounded; requiring medical treatment.

• 1,800 nearby houses damaged in the rural area

beyond the plant fence line.

• Property damage: $ 425MM USD.

Causes / Lessons Learned

• Lack of plant modification / change control.

Management of “temporary changes”; changes

in organization.

• Lack of design codes for pipework.

• Lack of siting considerations for placement of

control room and other occupied buildings.

Seveso, Italy (1976)

ICMESA (Industrie Chimiche Meda Società Azionaria)

(Tetrachlorodibenzoparadioxin release)

• Release of a Dioxin, a poisonous and

carcinogenic by-product of an

uncontrolled exothermic reaction.

• 25 km North of Milan.

• No fatalities. More than 600 people

evacuated; 20 people treated for

Dioxin poisoning.

• Long term health impacts.

• Led to development of initial EU

“Seveso” directive.

Mexico City, Mexico (1984)

• PEMEX LPG Terminal BLEVE (Boiling Liquid Expansion Vapor Explosion) and fire after Loss of Containment in local sewer system

• Over 650 fatalities, mostly offsite; $20MM damages

• CONTRIBUTING FACTORS:

• Plant layout

• Active / passive fire protection

• Emergency isolation

• Emergency response / spill control

Bhopal, India (1984) Union Carbide India Limited (UCIL)

(Methyl isocyanate (MIC) tank rupture & release)

• Considered the world’s worst industrial disaster.

• Accident was a result of poor safety

management practices, poor early warning

systems, and the lack of community

preparedness.

• Estimates vary on the death toll.

• Eventually, resulted in the demise of Union

Carbide, one of the world’s largest integrated

chemical companies.

Bhopal, India (1984)

• Methyl isocyanate release at Union Carbide insecticide plant

• 3,000+ fatalities; 100,000+ injured

• Accident a result of many failures in safety management systems; equipment; human errors

• Considered world’s worst industrial disaster

PIPER ALPHA

North Sea (1988)

• Occidental Petroleum, Piper Alpha Platform

• 167 fatalities

• $3.4B insured loss

• CONTRIBUTING FACTORS:

• Lack of adequate emergency evacuation and egress

Pasadena, Texas (1989) Phillips Pasadena Chemical Complex

(Vapor Cloud Explosion)

• Explosion with a force of 2.4 tons

of TNT.

• 23 killed; more than 130 injured.

• Property damage was $750MM+.

• The evidence showed that more

than 85,000 pounds of highly

flammable gases were released

through an inadvertently open

valve.

History of Process Safety

• Process Safety Management was initiated by U.S. OSHA in

1992 as a way to respond with government regulations/

oversight of industries using highly hazardous chemicals

(HHCs).

• PSM emphasizes the management of hazards associated

with highly hazardous chemicals and establishment of a

comprehensive management program that integrated

technologies, procedures, and management practices

Elements of Process Safety

PROCESS SAFETY

MANAGEMENT

Employee

Participation

Process Safety

Information

Operating

Procedures

Trade

Secrets

Emergency

Planning and

Response

Management

of Change

Mechanical

Integrity

Incident

Investigation

Pre-Startup

Safety Review

Training

Compliance

Audits Contractors

Process Hazard

Analysis

Hot Work

Permit

History of Process Safety

IS IT WORKING???

BP Texas City (2005) (Vapor Cloud Explosion)

• 15 workers were killed and more

than 170 others were injured.

• Both the BP and the U.S.

Chemical Safety and Hazard

Investigation Board identified

numerous technical and

organizational failings at the

refinery and within corporate BP.

Deepwater Horizon (2010) BP / Transocean / Halliburton

(Explosion and sinking of the Deepwater Horizon oil rig

followed by oil release)

• Considered the largest accidental marine oil spill in the

history of the petroleum industry.

• Oil flowed for ~90 days; 134MM- 176 MM bbls. spilled.

• Eleven workers were never found despite a three-

day Coast Guard (USCG) search operation.

West, Texas– April 17, 2013 West Fertilizer Company

(Ammonium nitrate explosion)

• 15 people killed; more than 160 people

injured.

• More than 150 buildings and homes

were damaged or destroyed due to

blast.

• Investigators have confirmed that

ammonium nitrate was the material

that exploded.

• USGS recorded the explosion as a

2.1-magnitude.

History of Process Safety Regulations have NOT changed since their

promulgation, but……

• OSHA Petroleum Refinery Process Safety

Management National Emphasis Program (NEP)

Directive – 2007

• OSHA’ PSM Covered Chemical Facilities National

Emphasis Program (NEP) Directive – 2011

• Executive Order 13650 (August 1, 2013)

• More chemicals, lower TQs, more covered facilities

• Stay tuned……

Singapore Standard SS 506 Part 3

• A systematic way of managing

• Occupational Safety and Health risks

• Process Safety of the chemical industry through Plan-Do-

Check-Act cycle

1993

Recommended

Practice on

Process Safety

Management

2001

Code of Practice

on Safety

Management

System for the

Chemical

Industry

2006

Singapore

Standard SS

506 Part 3

Process Safety Focused 14-Element format comprising Process Safety and OSH elements.

PDCA Format – Certifiable Standard Comprising Process Safety and OSH elements

Evolution of Singapore Standard SS 506

Process Safety Management (PSM)

COMMON DEFICIENCIES

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• Boundaries of PSM-covered process not well-

defined or documented; leading to inconsistent

interpretation by different departments across

Site and incomplete PHA assessment.

• Failure to include interconnecting utilities (e.g.,

cooling water, steam, nitrogen, etc.) in the

PSM-covered process and PHA review.

PSM – Common Deficiencies

• Lack of well-articulated management

expectations and defined goals; leading to

weaker employee morale and decreased

employee participation

• Employees do not know how to access PHAs

and other PSM information.


• Incomplete compilation of PSI prior to

performing PHA (PSRG recommends “PSI

Checklist” documentation with each PHA.)

• Design basis information for process

equipment incomplete (e.g., API RP520/521

contingency analysis not completed for

PSVs).


• Design basis for safeguards, which prevent or mitigate a potential release, incomplete (e.g., firewater systems).

• Materials of construction information not on file for all equipment in the “covered process”.

• Lack of reference Plant design codes and standards identified (RAGAGEP).


• API RP 752

Management of Hazards Associated with Location of Process Plant Permanent Buildings

• API RP 753

Management of Hazards Associated with Location of Process Plant Portable Buildings

Most Frequently Referenced RAGAGEPs

in Recent OSHA Inspections

• API 570

Piping Inspection Code: In-Service Inspection, Rating, Repair, and Alteration of Piping

• API 510

Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration

• API 521

Pressure-Relieving and Depressuring Systems

• API 574

Inspection Practices for Piping System Components



• API 574

Inspection Practices for Piping System Components

• API 520

Sizing, Selection, and Installation of Pressure-relieving Devices in Refineries

• ANSI/ISA S.84.01

Functional Safety: Safety Instrumented Systems for the Process Industry Sector



• PHA fails to comprehensively identify all hazards of the process because wrong methodology selected or incomplete set of Guidewords + Parameters (“Deviations”) utilized.

• Consequences not based on failure of engineering

controls; but instead taking into account

safeguards. Failure to assess consequences to

“ultimate” loss event.

• Independence of safeguards versus the cause-consequence.


• Failure to address Facility Siting

• Failure to address Human Factors

• Overdue PHA recommendations with no

updated timeline for completion.


• SOPs not written for all phases of operation (esp.,

non-routine operations, e.g., purging, cleaning,

sampling, etc.).

• Consequences of deviation tables with steps to

correct/avoid deviations and safe operation limits

not documented.

• No written procedure for Shift Change / Handover.


• Procedures not annually certified.

• No documented Equipment-specific

LOTO, Confined Space procedures.

• Lack of periodic LOTO, Confined Space

training.


• Missing records of initial training for qualified operations.

• Refresher training not conducted at least every three (3) years.

• No written proof that operators consulted on frequency or content of refresher training.

• Refresher training too much focused on “normal operation”.


• Out of date contractor prequalification.

• Too much reliance on third party clearinghouses (e.g., ISNetworld, PICS, SMI, etc.) for contractor prequalification; not enough Company due diligence for Site-specific hazards.

• Lack of qualification, certification records for contractor employees who perform “specialized skill or craft work”.

• Lack of documented periodic surveillance of contractors post-selection.


• PSSR not documented for each MOC.

• Weak, short-form PSSR checklist used

for major changes.


• List of covered M.I. equipment not

consistent with PSM-covered process

boundaries. Missing equipment.

• Lack of written deficiency management

program for non-conformances

identified during inspection and testing.


• Failure to review PHA and include all

“safeguards” in Mechanical Integrity

program.

• Focus on stationary equipment; less

well-developed Rotating Equipment and

Instrumentation & Controls.


• Overdue inspections.

• Failure to identify RAGAGEP used for inspections and tests performed.

• Lack of fitness for service documentation.

• MOC process for changes to inspection frequency not used.


• Hot work permit does not clearly identify “object on which hot work being performed”.

• Pre-job safety checklist incomplete.

• Missing signature authorizations on hot work permit form.

• No documentation of fire watch training/qualifications.

• Hot work training not performed annually.

• Permit-required hot work areas inconsistent with definition of electrically classified area.


• MOC process not applied for: • Installation of temporary equipment

• Decommissioning or taking equipment out-of-service

• Changes to alarm setpoints

• Procedural-only changes (e.g., conversion from paper-

based to electronic systems)

• Changes in shift work; workforce reductions


• MOC process not institutionalized – may be strong in Operations; but weaker by Maintenance.

• PSI, SOPs, M.I. not updated.

• MOC forms completed and signed off before PSSR completed.


• “Near misses” not documented; focus more on

personnel safety incidents.

• Unable to confirm investigation initiated within 48

hours.

• Investigation team not identified (esp. contractors).

• Failure to identify “root causes” leading to repeat of

incidents.


• Emergency evacuation maps with routes not posted.

• Emergency action plan not up-to-date.

• Lack of training on latest EAP.

• No written process for testing and servicing plant alarms; no

documentation that alarm testing was completed

• Safe distances not addressed.

• Lack of documented drills and exercises

• Lack of coordination of EAP with local community, responders.


• Compliance audits performed; but not certified.

• Audit action items not tracked or completed in a timely manner.


Regulatory Update

Regulations have NOT changed since their

promulgation, but……

• OSHA Petroleum Refinery Process Safety

Management National Emphasis Program (NEP)

Directive – 2007

• OSHA’ PSM Covered Chemical Facilities National

Emphasis Program (NEP) Directive – 2011

Mechanical Integrity 202

Process Safety Information 189

Process Hazard Analysis 188

Operating Procedures 184

Management of Change 92

Incident Investigation 71

Compliance Audits 47

Contractors 33

Training 29

OSHA REFINERY NEP

ENFORCEMENT STATISTICS, 2007-2011

855

79%

Emergency Planning and Response 17

Employee Participation 15

Pre-Startup Safety Review 13

Hot Work Permits 8

Trade Secrets 0

Total PSM Citations

1088

OSHA REFINERY NEP

ENFORCEMENT STATISTICS, 2007-2011

Mechanical Integrity 156

Process Safety Information 140

Operating Procedures 114

Process Hazard Analysis 106

Management of Change 44

Compliance Audits 35

Training 21

Incident Investigation 19

Employee Participation 16

CHEMICAL NEP PSM

ENFORCEMENT STATISTICS

(98 NEP Citations Sampled)

516

76%

Contractors 14

Emergency Planning and Response 7

Pre-Startup Safety Review 5

Hot Work Permits 1

Trade Secrets 0

Total PSM Citations

678

CHEMICAL NEP PSM

ENFORCEMENT STATISTICS

(98 NEP Citations Sampled)

Vision 2020 – CCPS Project

CCPS Risk Based Process Safety (RBPS)

• Process Safety Culture

• Compliance with Standards

• Process Safety Competency

• Workforce Involvement

• Stakeholder Outreach

• Process Knowledge

Management

• Hazard Identification and

Risk Analysis

• Operating Procedures

• Safe Work Practices

• Asset Integrity and Reliability

• Contractor Management

• Training and Performance Assurance

• Management of Change

• Operational Readiness

• Conduct of Operations

• Emergency Management

• Incident Investigation

• Measurement and Metrics

• Auditing

• Management Review and

Continuous Improvement

• Implementation and the Future

Conclusion

• Relax and learn

• Ask questions

• Participate

• Share experiences

• Enjoy yourself!

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FOR MORE INFORMATION….

www.psrg.com

PSRG ASIA PACIFIC PTE. LTD.

JTC Summit

8 Jurong Town Hall Road #24-05

609434 SINGAPORE

Tel: +65 6818 0967

Email: [email protected]

Contact: Ms. Annie Nguyen, Director




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