Process Safety for Non-Regulated Companies

As the world increasingly becomes aware of the importance of safety in the workplace, more and more companies are looking for ways to improve their safety processes. This includes the typical occupational safety aspects and the process safety aspects. Unfortunately, this can be daunting for companies not regulated by Occupational Safety and Health Administration (OSHA) standards for Process Safety Management (1910.119).

There are several ways that non-regulated companies can review their processes and identify potential safety and operational benefits. One common technique is called a Process Hazard Analysis (PHA).

A PHA is a systematic examination of a process to identify and evaluate the potential hazards that could lead to an incident. PHAs can be conducted using various techniques, Hazard and Operability Reviews, What-If Reviews, Failure Mode Reviews, etc.

Once the potential hazards are identified, the next step is to evaluate the risks associated with each hazard. Specifically, how severe and likely are the potential incidents.

Once the risks are identified and evaluated, the next step is to develop controls to mitigate those risks. This may involve a variety of measures, such as process changes, administrative controls, or the use of personal protective equipment.

By conducting a PHA, non-regulated companies can identify potential hazards and develop controls to mitigate the risks associated with those hazards. This can lead to a safer workplace and improved operational efficiency.

A non-regulated company contracted ETA, Inc. to review one of its processes using the PHA techniques to identify safety and operational benefits. They have even asked ETA to study several management systems of their business to see if there are aspects of a typical Process Safety Management program that may provide benefit to them. The attitude and forward-thinking of this client is applauded. It fits right in with what Dan Wilczynski has always said about Process Safety, “It is just good management of your business!” 

Engineering & Technical Associates, Inc. (ETA) is an engineering consulting and recruiting company that provides consulting and personnel recruiting (both contract and permanent) services to the refining, chemical, and petrochemical industries.

Oil Market Report – March 2022

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About this report

The IEA Oil Market Report (OMR) is one of the world’s most authoritative and timely sources of data, forecasts and analysis on the global oil market – including detailed statistics and commentary on oil supply, demand, inventories, prices and refining activity, as well as oil trade for IEA and selected non-IEA countries.


  • Surging commodity prices and international sanctions levied against Russia following its invasion of Ukraine are expected to appreciably depress global economic growth. As a result, we have revised down our forecast for world oil demand by 1.3 mb/d for 2Q22-4Q22, resulting in 950 kb/d slower growth for 2022 on average. Total demand is now projected at 99.7 mb/d in 2022, an increase of 2.1 mb/d from 2021.
  • The prospect of large-scale disruptions to Russian oil production is threatening to create a global oil supply shock. We estimate that from April, 3 mb/d of Russian oil output could be shut in as sanctions take hold and buyers shun exports. OPEC+ is, for now, sticking to its agreement to increase supply by modest monthly amounts. Only Saudi Arabia and the UAE hold substantial spare capacity that could immediately help to offset a Russian shortfall.
  • Global refinery throughput estimates for 2022 have been revised down by 860 kb/d since last month’s Report as a 1.1 mb/d reduction in Russian runs is not expected to be fully offset by increases elsewhere. In 2022, refinery intake globally is projected to rise by 2.9 mb/d year-on-year to 80.8 mb/d. Despite a downgrade to demand, product markets remain tight with further stock draws expected throughout the year.
  • OECD total industry stocks were drawn down by 22.1 mb in January. At 2 621 mb, inventories were 335.6 mb below the 2017-2021 average and at their lowest level since April 2014. Industry stocks covered 57.2 days of forward demand, down by 13.6 days from a year earlier. Preliminary data for the US, Europe and Japan indicate that industry stocks decreased by a further 29.8 mb in February.
  • As this Report went to print, ICE Brent oil futures slid to around $100/bbl after touching an intraday high of nearly $140/bbl on 8 March. Prices jumped from $90/bbl in early February following the invasion of Ukraine and as supply concerns mounted. Prices have eased again on economic concerns, surging Covid cases in China and traders reducing positions due to extreme volatility.

At a crossroads

Faced with what could turn into the biggest supply crisis in decades, global energy markets are at a crossroads. Russia’s invasion of Ukraine has brought energy security back to the forefront of political agendas as commodity prices surge to new heights. While it is still too early to know how events will unfold, the crisis may result in lasting changes to energy markets.

The implications of a potential loss of Russian oil exports to global markets cannot be understated. Russia is the world’s largest oil exporter, shipping 8 mb/d of crude and refined oil products to customers across the globe. Unprecedented sanctions imposed on Russia to date exclude energy trade for the most part, but major oil companies, trading houses, shipping firms and banks have backed away from doing business with the country. For now, we see the potential for a shut-in of 3 mb/d of Russian oil supply starting from April, but losses could increase should restrictions or public condemnation escalate.

Russian oil continues to flow for the time being due to term deals and trades made before Moscow sent its troops into Ukraine, but new business has all but dried up. Urals crude is being offered at record discounts, with limited uptake so far. Some Asian oil importers have shown interest in the much cheaper barrels, but are for the most part sticking to traditional suppliers in the Middle East, Latin America and Africa for the bulk of their purchases. 

Refiners, particularly in Europe, are scrambling to source alternative supplies and risk having to reduce activity just as very tight oil product markets hit consumers. There are scant signs of increased supplies coming from the Middle East, or of a significant reallocation of trade flows. The OPEC+ alliance agreed on 2 March to stick with a modest, scheduled output rise of 400 kb/d for April, insisting no supply shortage exists. Saudi Arabia and the UAE – the only producers with substantial spare capacity – are, so far, showing no willingness to tap into their reserves.

Prospects of any additional supplies from Iran could be months off. Talks over a nuclear deal that paves the way for sanction relief have apparently stalled just before the finish line. Should an agreement be reached, exports could ramp up by around 1 mb/d over a six-month period. Outside of the OPEC+ alliance, growth will come from the US, Canada, Brazil and Guyana, but any near-term upside potential is limited.

In the absence of a faster ramp up in production, oil stocks will have to balance the market in the coming months. But even before Russia’s attacks on Ukraine, the industry’s oil inventories were depleting rapidly. At the end of January, OECD inventories were 335 mb below their five-year average and at eight-year lows. IEA emergency stocks will provide a welcome buffer, and member countries stand ready to release more oil from strategic reserves if and when needed, in addition to the 62.7 mb of crude and products already pledged. 

Surging oil and commodity prices, if sustained, will have a marked impact on inflation and economic growth. While the situation remains in flux, we have lowered our expectations for GDP and oil demand in this Report. We now see oil demand growing by 2.1 mb/d on average in 2022, a downgrade of around 1 mb/d from our previous forecast. There are actions governments and consumers can take to cut short-term demand for oil more rapidly to ease the strains and the IEA will publish recommendations for how to do so later this week. The current crisis comes with major challenges for energy markets, but it also offers opportunities. Indeed, today’s alignment of energy security and economic factors could well accelerate the transition away from oil.

Safety: Do companies have the right tools to make proactive safety decisions?

A process safety management/operational risk management survey conducted by Sphera in 2020 polled respondents on the following items:

  • Safety culture
  • The reality of risk across hazardous industries
  • The methods organizations use for identifying, understanding and communicating risk
  • Priorities and company plans for digital transformation.

The industry breakdown included oil and gas (36%), chemicals and petrochemicals (19%) and manufacturing (17%), as well as other industries like oilfield services, utilities, metals and mining. Participation was offered globally, and feedback was received across all regions.

Some of the key statistics include 88% of participants indicating that safety is part of corporate value structures, supported by upper management; 78% of respondents continuously monitoring safety performance; and 60% of participants striving to reduce operational and major accident hazard risk exposure. The survey suggested additional drivers for improving safety performance, including continuous process improvement, operational excellence, regulatory compliance, and satisfying corporate and board priorities, among others.

Risk awareness can pay for itself

Despite good intentions, 49% of survey respondents said most organizations are unaware of their major accident hazard risk vulnerability, and only 37% are confidently and proactively managing process safety risk exposure. For the last 5 yr, the percentage of companies that proactively manage safety have been surveyed; year on year, the result is somewhere in the 36%–40% range.

This statistic gives reason for pause. Earlier this year, Marsh published its 100 largest hydrocarbon loss report. It is striking that over the past 2 yr, the industry faced its largest losses on record—$4.5 B, which is 10% of the combined 50-yr total. Aging infrastructure and high utilization in the downstream sector were largely to blame (FIG. 1). Over those 2 yr, the oil and gas industry was recovering from its previous oil price downturn, which may very well repeat itself again 2 yr from now. It begets the question: Do companies actually have the right tools to proactively manage infrequent, high-consequence events?FIG. 1. Aging infrastructure and high utilization in the downstream sector are largely to blame for the $4.5 B of hydrocarbon losses reported over the past 2 yr.

Sphera asked companies how they identify risks. Audits and inspections, hazard and operability studies (HAZOPs), “what-if” studies and process hazards analyses (PHAs) are the most common means. Around 46% of participants suggested that they have deployed technology systems to support their risk assessments. However, they also highlighted concerns about the frequency and effectiveness of those studies. Half of the companies said they review risk every 1 yr–6 yr, with only 8% reporting that they review risk daily or weekly. Approximately 53% indicated that they are assessing only a portion of their facilities, while half are concerned with the consistency and quality of their assessment and audit practices. On average, companies reported that they are able to complete only 68% of their average safety-critical maintenance and asset integrity inspections every year. Data is siloed, systems are static and information is dated and incomplete.

Also, only 51% of respondents said they thought it was practical to set 100% of their planned maintenance and inspections to active, because limited resources (72%), conflicting priorities (71%) and limited budget (49%) were getting in the way—the same three challenges seen in every survey for the last 5 yr running. Also, average scheduled maintenance and inspections achieved has hovered at the 70% level for the last 3 yr. These results reinforce the thinking that perhaps the right tools are not available to make proactive safety decisions.

Lacking and lagging insights are perhaps the reason the majority of industry leaders told us there are gaps between well-engineered process safety approaches and the reality on assets. They also agreed that risk changes between periodic process safety review periods due to a loss of experienced personnel, lack of operational risk visibility, conflicts between procedures and work practices, and poor process execution and management of change. The factors with the most impact on those elements, however, are organizational culture, senior leadership and human factors.

Shoring up safety with real-time technologies

Companies know they are operating without the right insights—they need something more comprehensive. They also understand the value of technology and how it makes their companies and teams safer. In fact, 2020 witnessed an 11% growth in this trend over last year. Survey participants also told us that they are using technology to remotely monitor facility and operational performance, to improve work prioritization and planning, and to monitor asset health.

Some of the technology solutions companies are using today are helping them understand process safety lessons learned, changes in operating procedures and changes in equipment health and performance. Organizations also shared that they are making big investments to implement remote sensors and equipment-related risk identification tools. In fact, equipment sensors (59%) and condition monitoring (50%) are the most commonly implemented systems, with 23% deploying new equipment performance solutions at the regional level to monitor when an answer requires service.

Companies understand that they are presently operating with piecemeal data. With that understanding, it is interesting to note that 39% of companies are working their digital strategies to integrate environment, health, safety and sustainability (EHS&S) and operational risk management (ORM) solutions at the enterprise level. Integration goals are in service of creating new, data-driven business processes across functions, understanding where to make safety improvements and map dynamic risk pathways. Such dynamic risk pathways are new. Sphera’s subject matter experts have shared more about this trend.

Industry is now looking for real-time condition monitoring solutions to bring operating and asset conditions together. The creation and ongoing validation of PHAs, HAZOPs and other risk studies are time-consuming and expensive, and it can be difficult to capture ongoing and evolving information. Operators know that when well-designed and well-specified processes and equipment enter service, things begin to change. Over time, assets age; but there are also daily interventions on the plant. Things change—whether because of new management-of-change (MOC) procedures being put into place or because of existing MOCs being extended.

Impairments, startups, shutdowns and permitted maintenance activities introduce hazards and risk to the assets. This is an interesting statistic because process safety leaders see technology as the digital leap needed to overcome their siloed, lagging situations. They are now moving in a direction to simulate and visualize, in real time, the health status of risk pathways that pertain to specific scenarios captured through bowtie risk visualization diagrams and PHAs. This idea would essentially bring live data from historian distributed control systems (DCSs), maintenance systems, inspection/MOC and control of work databases to understand the operational, maintenance and verification conditions and status of safety-critical equipment in real time.

One area where technology is rapidly taking off is fog/edge computing, which enables the gathering of more data that sits closer to the asset. Industry leaders expect sixfold growth in this area. Another area is digital twin technology, which promises to support safer operations, plantwide productivity and performance, and safer, more efficient shutdowns and turnarounds. Digital twin technology is anticipated to post threefold growth.

How to know what you don’t know

Looking at the results of this year’s survey, one of the industry trends that is visible between the data presented here and the data coming from others like Marsh, is that complex systems migrate toward states of high risk, but operators often do not realize it until something bad happens. For some companies, it is not that process safety is simply “out of sight, out of mind.” These companies have done their risk studies. They have noted their lagging indicators and lessons learned. What they do not have is a joined-up, real-time view of asset and operating conditions. They know the risk this poses, and they know that no single, siloed system provides good safety indicators. Here is seen the big leap from 51% reviewing risk every 1 yr–6 yr, to 52% wanting access to the nuanced state of process safety barriers in real time and wanting the ability to simulate operating conditions based on certain risk scenarios.

The stakes are simply too high to ignore the financial and reputational savings offered by advanced asset safety monitoring. The oil and gas industry, in particular, needs this level of resilience due to the critical nature of its assets. A recent article published in the Houston Chronicle described Total’s perspective: The combination of the coronavirus pandemic and the oil crash are accelerating digital transformation to help companies boost efficiency, cut costs and make money at lower commodity prices. We hope they also find value in improving safety.

Going back a couple of years to our 2018 survey, we asked the industry what they thought the safety impact would be following the low oil price. Of the total respondents, 72% said process safety risk increases. As we saw with the Marsh data and expectations about future years, meeting those projections will require a dramatic digital transformation today. HP