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Process Safety

Process Safety Competence Assurance

April 18, 2017 - Kestrel Management

Organizations in the chemical manufacturing and energy industry face the daily challenge to safely manage the processing, storage, and transportation of hazardous materials. To enable this, a great deal of focus and effort is put into compliance, strong management systems, well-maintained equipment, and organizational capability.

A key component of organizational capability is the competence of employees. This is critical to an organization’s success—and very relevant for process safety. In fact, process safety competence is both a regulatory requirement and a business improvement driver. But what does competence mean when it comes to the management of process safety?

Defining Competence

Process safety competence is an area that is sometimes misunderstood as simply providing training to employees. However, it is much more. Organizations need to understand the definition of competence and ensure employees have the basic competence required to fulfill their job function successfully.

Competence is often defined as “an individual having the right level of training and experience to enable the successful execution of defined job responsibilities”. By this definition, competence is a step beyond basic job training—one that necessitates understanding and the ability to successfully apply what is learned.

To fulfill this intent, especially for those working around the management of process safety, it is critical that employers have a structured and sustainable approach to ensure process safety competence. This may include a clear process safety competence assurance program. Not only will this assist with regulatory compliance, it is a critical element in the prevention of a process safety incident.

Steps to Ensure Competence

To successfully create an organizational culture that values and emphasizes process safety competence assurance, there are some basic steps that need to be followed, including those outlined below:

  • Understand and define positions within the organization that impact or influence process safety.
  • Define desired competence levels and requirements for each of these positions.
  • Develop an organizational competence matrix for process safety that documents the positions and requirements.
  • Assess position holders’ (i.e., employees’) process safety competence against the requirements outlined on the organizational matrix.
  • Identify gaps in competence for each individual and develop individual closure plans.
  • Work with employees to address identified competence gaps and verify that they have been closed.

When filling a position that has process safety requirements, the identified candidate(s) should undergo an assessment against the defined process safety requirements for the position to ensure they are competent. It is important to ensure the new employee has the required competence before they are appointed or hired. Successful candidates may have some minor gaps that can quickly be rectified, but putting candidates into jobs that impact or influence process safety as “development” or a “learning opportunity” is a large risk to the organization and unfair to the individual. It is also a practice organizations should stop if they are truly committed to process safety.

Maintaining the Commitment to Competence

To further enhance the ongoing process safety competence of an organization, each position that impacts or influences process safety must maintain the required process safety competencies identified on the competence matrix. The commitment must be sustained to be successful; it should not be a one-time effort.

Organizations can do this by:

  • Reviewing competence requirements and adjusting the matrix as new requirements are identified;
  • Conducting regular assessments to verify employee competence; and
  • Providing opportunities for training and experiential learning that ensure process safety competence remains a top priority.

Submitted by: Ewan Ross

OSHA Releases Three New PSM Publications

April 4, 2017 - Kestrel Management

OSHA has released three new guidance documents to help employers comply with the agency’s Process Safety Management (PSM) standard. PSM is critically important to facilities that store highly hazardous chemicals. Implementing the required safety programs helps prevent fires, explosions, large chemical spills, toxic gas releases, runaway chemical reactions, and other major incidents. The new documents focus on PSM compliance for Small Businesses, Storage Facilities and Explosives and Pyrotechnics Manufacturing.

Submitted by: Ewan Ross

Improving Process Safety Leadership and Culture

February 15, 2017 - Kestrel Management

Over the past 30 years, there have been numerous events both nationally and internationally that have led organizations to bring a more concerted focus to process safety. Such a focus has many such organizations building process safety elements into their management systems. The goal is to not only comply with regulations, such as OSHA 1910.119, but to also ensure sustainable programs that prevent process safety incidents from ever happening.

A large part of this effort involves integrating process safety leadership into existing programs. Improving an organization’s process safety leadership and culture can have significant and lasting impacts on a company’s process safety performance. Three steps that organizations can undertake to advance this effort include the following:

  • Amending metrics to include more leading indicators that are designed to prevent process safety incidents
  • Cultivating communications geared toward process safety
  • Ensuring incentive schemes include measures related to process safety

Traditional Management Systems

Traditional management systems include personal safety, environmental management, and industrial hygiene as the core elements. Management systems, metrics, and communications have historically been focused on personal safety and environmental management. These areas have clear industry compliance drivers and easy-to-understand metrics for organizational leaders. The prevention of personal injury or actions to protect the environment are relatable concepts for most.

The addition of process safety to the management system structure has been a smooth transition for many organizations, as the majority of the elements that cover process safety are already part of a typical management system. However, process safety—and the incidents that can occur if not managed well—can be complex in nature to explain. The challenging part of integrating process safety into an organization becomes getting leaders both comfortable and equipped to address it.

Leading Metrics

Due to the generally low frequency of process safety incidents, the development and measurement of process safety indicators is often not a priority for organizations. Many companies rely heavily on lagging personal safety and environmental metrics (Days Away from Work Rate, Total Recordable Incident Rate, Spill Rate). Injuries are easy for leaders to understand and explain. Leaders demonstrate empathy towards their staff and contractors, again making it easier for them to relate to personal safety. Minor spills are also easily understood and easier to discuss.

While these lagging metrics are still important and can be used and communicated, organizations need to include different metrics to bring more focus on leading indicators that are designed to prevent process safety incidents. Some examples of leading metrics that can be developed, implemented, and tracked include the following:

  • Identifying systems/equipment that are critical to prevent or mitigate a process safety event, and tracking their effectiveness and operability
  • Tracking the completion of Management of Change (MOC)
  • Tracking the effective closeout of Process Hazard Analysis (PHA) and PSM audit actions
  • Assessing organizational capability around process safety and tracking identified gap closure plans
  • Tracking the number of Pressure Relief Valve (PRV) activations
  • Tracking anomalies from complete permit-to-work reviews

Communication

Once an organization has developed a set of leading process metrics applicable to the business, the metrics should be made visible to all staff and included in communications on business performance. Leaders also need to focus more of their strategic communications and site visits on process safety. This can include talking about leading process safety metrics and undertaking the following activities when at a facility:

  • Ask members of the facility staff about the major identified hazards from the PHA
  • Determine if staff are involved in reviewing and updating operating procedures
  • Ask staff about the last emergency drill and actions taken
  • Ask operations staff about the number of alarms they deal with on a typical shift to determine if alarm management/rationalization is required or if low criticality alarms are not burdening staff
  • Hold discussion groups focused on process safety during leadership onsite visits

Incentive Schemes

Another outcome of tracking lagging metrics involves translating them into part of the organization’s incentive bonus criteria for leaders. Organizations should work to transition leadership bonus/incentive schemes away from just traditional personal safety and environmental lagging metrics, namely injury and spill rates. Again, it would not be necessary to immediately drop existing lagging metrics. Start with adding the new metrics and gradually change the percentage weightings so leading process safety indicators become the dominant factor. This will serve to reinforce the importance of process safety and incident prevention in overall business performance.

To truly have an organization that demonstrates process safety leadership and has a strong process safety culture, there need to be some changes and effective actions taken. The steps outlined in this article—amending metrics, cultivating communications toward process safety, and integrating process safety into incentive schemes—can help organizations take a few of the initial necessary steps to build process safety culture and leadership and, ultimately, prevent process safety incidents from occurring.

Submitted by: Ewan Ross

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