Process Safety Lessons Learned

Emerson’s Mike Boudreaux shares some thoughts on a recent article on process manufacturing accidents:

Process safety has been a popular topic these days. Unfortunately, it has hit mainstream press because of high profile safety incidents such as last year’s Deepwater Horizon accident in the Gulf of Mexico. On a positive note, process safety isn’t just for the experts anymore. Many process industry business leaders and managers are taking a stern look at their organization and wondering if they are protected or not. Still, some are making the mistake of assuming that their past success operating safely is an indicator of future process-safety success.

I just read an article by Walt Boyes titled Process Plants Accidents – Careful. We Don’t Want to Learn from This. Walt makes some really strong points about the lack of process safety improvements over the past 25-plus years, since the 1984 Bhopal, India incident got the process safety management (PSM) ball rolling. Walt once corrected me on a point that he did not make in his article. A couple of years ago, I was talking to him about the need to simplify regulatory compliance and he told me that I had it all wrong.

Walt said, “If the goal is to be regulatory compliant, then you are missing the point.” Walt’s point was that regulatory compliance is not a goal to strive for. If you are hoping to improve your safety by becoming “regulatory compliant” then you are setting yourself up to fall woefully short of actually managing your process safety. The regulatory compliant mindset can lead you onto all sorts of stray paths if you are not careful. This is a major contributor to many ineffective safety programs and management cultures today. During the investigations into the Deepwater Horizon incident, we saw clear examples of very smart people making irrational decisions because their goal was to meet the regulatory compliance requirements set by the Mineral Management Service (MMS) in the Gulf of Mexico. Instead, it is important to focus on the goal–managing process safety.

In addition to the regulatory compliance goal inadequacy, many of the key points provided in the 2008 U.S. Chemical Safety Board (CSB) video title Anatomy of a Disaster are still valuable lessons for the process industry to learn. If you haven’t watched this video yet, I urge you to schedule an hour into your calendar and take the time to learn some lessons from a recent industry event. With permission from the CSB, I have picked out some of the more valuable quotes from the process safety experts that were interviewed in the video.

“There’s an old saying that if you think safety is expensive try an accident. Accidents cost a lot of money, not only in damage to plant and claims to injuries but also in the loss of the company’s reputation.”-Dr. Trevor Kletz
This week I read the IndustryWeek article, BP Refines Post-Spill Drilling Strategy. Less than a year after the Deepwater Horizon incident, there are already signs of BP’s top management taking a leadership role in driving process safety management in their company. Change like this isn’t something that can be driven from the bottom up. You need top down support to make this happen. The article discusses some of the safety culture and management changes that the new CEO Robert Dudley says are happening at BP. Dudley is quoted as saying that production shutdowns are costly, but “safety is good business.”

“My fear is that some of the other refineries within the United States will feel, that couldn’t happen to me. And the ones that feel that couldn’t happen at their site are the ones that are set up to have it happen there.” – Glenn Erwin
This is one of the major challenges that the process industry faces. After the Deepwater Horizon incident, leaders from several multinational oil companies testified before Congress that something like this couldn’t happen to them. This is a natural response to this kind of industry event. However, the major oil producers did come together after recognition that their emergency response plans were all pretty much the same and they were indeed subject to some of the same problems. Exxon Mobil, Shell, Conoco Phillips, Chevron, and BP have since formed a non-profit organization, the Marine Well Containment Company, which will provide a rapid response system to capture and contain oil in the event of another blowout in the Gulf of Mexico.

“Process safety deals with the fires, explosions, and toxic releases and things like that. You can have a very good accident rate for what we call “hard hat accidents” and not for process ones.” – Dr. Trevor Kletz
It is common to see process industry facilities with signs reminding you to hold onto handrails, watch where you are walking, and to be careful not to be burned by spilled coffee. If you drive down Highway 225 in southeast Houston, you are likely to see dozens of signs outside of refineries and chemical plants that display hundreds of thousands of man-hours without a lost time or total recordable incident. While this is very important to celebrate personal safety management milestones, it has little connection with process safety performance. Having a very low lost-time accident rate can induce a feeling of complacency and a false sense that safety is being well managed. Key lessons from recent incidents were the need to focus on leading and lagging indicators in addition to personal safety metrics. The AIChE Center for Chemical Process Safety (CCPS) has recently made significant progress developing process safety metrics.

“The fact that you’ve gone for 20 years without a catastrophic event is no guarantee that there won’t be one tomorrow.” – Prof. Andrew Hopkins
Personal safety focuses on preventing high frequency, lower consequence incidents like slips, trips, and falls. Process safety focuses on preventing much lower frequency events with a catastrophic consequence. Many process safety hazards are estimated to be likely to occur only once in the life of a facility, or even only once in the life of an industry.

Some hazardous event frequencies are measured in terms of once in thousands of years. These events typically result from multiple causes related to a complex sequence of failures in equipment, people, processes, and decision-making. So, often the process industry celebrates the personal safety successes while having to fight complacency on the need for continuous process safety vigilance. Some safety engineers complain that change is hard to justify because current practices have not resulted in any safety incidents. It often takes a catastrophic kind of event to invigorate the organization’s focus and commitment around process safety.

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