Remotely Performing PHAs in a Quarantined World

With the recent global health crisis temporarily closing schools, restaurants, and businesses, and most of the global workforce operating remotely, it’s easy to wonder whether our world of face-to-face interaction will ever fully return. Though much of the world is quarantined, essential businesses like refineries must find ways to continue their operations as usual, ensuring that their engineering processes like PHAs, HAZOPs, and LOPAs are being completed to ensure the safety of employees, consumers, and the environment. The good news is that performing PHAs, HAZOPs, and LOPAs remotely is an efficient and cost-effective option during these uncertain times. With advances in video calling platforms and the willingness of teams to use more flexible communication platforms, it has never been a better time to host a remote PHA to keep your teams and facilities safe, without compromising quality.

To complete a remote PHA at your facility, it is essential to plan and organize the people and technology you will need to make the analysis a success. This includes arranging any special needs around video-calling and telecommunication, such as additional computers, monitors, and a strong internet connection at each streaming location. It is also imperative to establish a main point-of-contact at each remote location who can troubleshoot challenges around equipment and technology and maintain order amongst their team.

Once you have established the initial team members and technology, the next step in carrying out your remote PHA is preparing your leadership and facilities for the meeting. An example of this is making arrangements for site access, technological support teams, and reserving meeting rooms at each remote location. Additionally, leadership should be communicating with internal teams to pre-define questions and causes that your team can review and focus on in advance. Not only does pre-defining questions and causes improve the completeness of the analysis, but it also facilitates structured brainstorming that will make the remote PHA more productive.

While these are just a few foundational steps for planning for a remote PHA, there are resources available to support you and your team in completing a successful analysis. If you have a PHA scheduled in 2020 and are interested in hosting a remote PHA, Engineering and Technical Associates (ETA) is here to help. For over 20 years, ETA has supported some of the largest refineries in identifying potential hazards, conducting a thorough analysis of all systems and operations, and developing plans and procedures to ensure safety standards are in place in the future. Learn more about how ETA’s PHA experiences and processes can support your facility.

The Top 3 Benefits Outsourcing Your PSM Services Can Bring Your Facility

Most facilities in the chemical, petrochemical, and refining industries strive to meet the strict compliance guidelines of OSHA standard 1910.119.

Unfortunately, following all these process safety management (PSM) standards can often prove to be harder than anticipated.

And in many cases, it makes more sense to partner with an outside resource for PSM services than to handle everything in-house.

Outsourcing your PSM services can bring your facility many benefits. Here are the top three.  

1) Guaranteed Expertise in all 14 PSM Elements = Prevention of Future Incidents

Most – if not all – industrial facilities run lean operations nowadays. Employees have to wear multiple hats, and as a result, many companies don’t have the manpower to build an internal team that has expertise in all 14 PSM elements:

  • Employee Participation
  • Process Safety Information
  • Process Hazard Analysis
  • Operating procedures
  • Training
  • Contractors
  • Pre-Startup Safety Review
  • Mechanical Integrity
  • Hot Work Permit
  • Management of Change
  • Incident Investigation
  • Emergency Planning and Response
  • Compliance Audits
  • Trade Secrets

By outsourcing your PSM services to the right organization, though, you can ensure that your PSM partners have expertise in all these elements – many of which have specific, detailed requirements.

You can then rest assured that all aspects of your PSM operations are being met fully to OSHA standards.

Key Takeaway: You can guarantee that all 14 PSM elements will be met – and effectively – by working with the right outside resource for your PSM services. 

2) A Wealth of Knowledge Beyond Just What’s in Your Facility = Industry Expertise

Most internal teams involved in PSM gain their knowledge and undergo their training in-house. This has some benefits in that your internal teams know your facility already, know your company’s goals and understand how your company works.

But the pitfalls can far outweigh the benefits.

Here’s the problem. In scenarios like this, your internal team’s knowledge only extends as far as the facility. They most likely don’t have outside PSM knowledge of best practices beyond their facility – and, indeed, beyond their industry. 

Also, PSM staff turnover is a real and common problem in many facilities, where chemical engineers assume this role but only view it as a stepping stone in their careers. Often, employees who work in PSM do so for a short time and do not want to do this permanently.

That’s why partnering with an outside resource who specializes in and has a wealth of knowledge about PSM can bring many benefits to your facility.

Their years of experience and expertise can provide you with more best practices and an impartial approach to all elements of PSM from training to compliance audits. You can also work with a team with years of experience in PSM instead of, say, recent training so that you know that you’re working with industry experts.

Consequently, you can mitigate the possibility of risks and hazards in your facility, avoid or prevent violations, and more.

Key Takeaway: Many internal PSM teams have limited time and knowledge, but an outside resource can have the industrywide knowledge and experience your facility needs to have the utmost in safety procedures.

3) A Questioning Attitude that Helps You Uncover – and Prevent – the Root Causes of Incidents and Violations

As we previously mentioned, many refineries, chemical facilities, and petrochemical facilities have tended to run lean in recent years. Often, the internal teams handling PSM aren’t always passionate about their jobs. So, what happens when you have an incident?

Here’s something we’ve seen more times than we can count in our PSM work throughout the years.

An incident occurs. The facility gets in trouble. They’re already on the OSHA and EPA radars. Then there’s another follow-up incident. Things quickly snowball.

Why is this?

After the initial incident occurs, many teams do not have the time, expertise, or dedicated staff to do a root cause analysis and keep digging and questioning until the real root(s) of the problem are found. And that makes sense; this takes quite a bit of time.

Due to a lack of time, though, many facilities will just take what the problem is at face value, identify measures to remedy it, and then move on. But that often doesn’t solve the actual cause(s) of the problem. So, another incident occurs. And the issue isn’t really solved at all.

But by outsourcing your PSM services, you will have a team that has the time, expertise, and experience to find out the root causes of incidents in your facility. That way, you can identify these causes, come up with a plan of action to ensure they don’t happen again and prevent future violations.

Key Takeaway: If you outsource your PSM services to an organization that specializes in PSM, you will have the time, the team, and the process to uncover the root causes of incidents in your facilities and stop them in the future.   

Conclusion

Working with an outside resource for your PSM services can provide you with many advantages including:

  • Guaranteed expertise in all 14 PSM elements
  • A wealth of knowledge beyond just what’s in your facility
  • A questioning attitude that helps you uncover – and prevent – the root causes of incidents and violations

As experts in PSM consulting, ETA has been at the forefront of developing OSHA-specific programs and helping companies in the chemical, petrochemical, and refining industries to meet the strict compliance guidelines of OSHA standard 1910.119 since it was first issued in 1992.

ETA consultants and project managers serve as industry leaders in the world of PSM. If you are looking for a dedicated and experienced partner for your PSM services, start the conversation today. Get in touch with ETA.

The Top 4 Process Safety Management (PSM) Elements for OSHA Citations

Of the 14 elements which make up OSHA standard 1910.119, there are four which most refineries, chemical facilities, and petrochemical facilities can get citations from OSHA.

In today’s article, we’re going to explore what those elements are, why companies have findings for them, and how ETA can help ensure that you don’t have violations in the future.

Let’s dive in.

1) Operating Procedures

OSHA Number: OSHA Standard 1910.119(f)

How OSHA Defines It: “The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.”

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • An employer’s written operating procedures did not address emergency shutdowns.
  • One company did not certify annually that their operating procedures were accurate and current.
  • Another facility did not provide their employees with written operating procedures which provided clear instructions that addressed elements like temporary operations, operating limits, emergency operations, and consequences of deviations.

2) Process Hazard Analysis (PHA)

OSHA Number: OSHA Standard 1910.119(e)

How OSHA Defines It: “The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.”

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • One facility’s use of the What-if methodology did not completely evaluate the hazards of the process being analyzed.
  • Another employer did not complete a finding to address the toxic gas hazard from an uncontrolled release and dispersion identified in a previous study.
  • One company received a serious violation for not performing an initial process hazard analysis for their chlorine process.

3) Mechanical Integrity

OSHA Number: OSHA Standard 1910.119(j)

How OSHA Defines It: This relates to all aspects of process equipment in a facility, from written procedures to training for process maintenance activities, inspection and testing, quality assurance, and corrections to equipment deficiencies.

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • One facility did not perform inspection and tests on process equipment in their propane container filling and evaluation areas.
  • Another employer did not develop and implement a written integrity procedure for evaluating valves in the chlorine process.
  • One facility didn’t develop and implement a written mechanical integrity procedure that addressed inspective pressure vessels and piping for minimum wall thickness.

4) Management of Change

OSHA Number: OSHA Standard 1910.119(l)

How OSHA Defines It: “The employer shall establish and implement written procedures to manage changes (except for ‘replacements in kind’) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.” 

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • An employer did not ensure that written procedures were established and implemented for the installation of a larger container filling station.
  • Another facility did not establish procedures to address all process changes, and as a result, modifications affecting the covered process could not be completed without proper analysis and assessment.

How ETA Can Help

Through our PSM consulting services, we work with all of your staff to ensure that they are trained in the basics of PSM and the specifics of their role in implementing a PSM program.

Our goal is that every employee will fully understand the hazards involved in their industries and their specific role in eliminating and/or minimizing those hazards.

Most findings are uncovered during PSM audits. During this time, we turn these finds over to our clients so they can identify ways to prevent these findings from turning into citations.

We can work with your staff to develop programs to address potential issues and establish procedures for best practices within your facility.

But there’s more. In addition to PSM audits, we also can work with you for your PHAs and help you identify all potential hazards by using the HAZOP method to ensure that this element is fully addressed per OSHA standards.

Contact ETA today to prevent future violations and ensure that you do not have citations for these four – or any – PSM elements.