Process safety improvements are top of mind for North American organizations seeking to minimize the costs, liabilities, disruptions, and consequences of violations. Most importantly, a well-defined safety culture protects human well-being—with the potential to prevent injuries and save lives.
Consider that in 2023, reports of accidental releases involving hazardous chemicals at fixed facilities in the United States reached an all-time high, according to the Chemical Safety and Hazard Investigation Board. The report noted a 51 percent increase in reportable incidents, an 11 percent increase in incidents involving serious injuries, and a 78 percent increase in the number of chemical incidents involving deaths.
Meanwhile, the Canadian Centre for Occupational Health and Safety anticipates that changing climate patterns are likely to yield an increase in process failures. Potential impacts include:
- Extreme weather may increase the likelihood and severity of losses of containment, leading to increased potential for injuries and even unintentional chemical mixing.
- Heat or cold-related illness, injuries, and psychological stress to worker health and safety, with the potential to lead to increased rates of human error.
- Loss of power and damage to critical infrastructure that may result in disruptions.
A practical focus on process safety is a must. It is now more important than ever to address shortcomings, missteps, and opportunities for improvement. In the sections below, I recommend six focus areas for improvement.
Six Common Shortcomings
- Applicability. A fundamental yet often overlooked aspect of process safety is the applicability of Process Safety Management (PSM) and Risk Management Program (RMP) regulations. More commonly than you may expect, facilities fail to conduct systematic assessments to determine whether the PSM and RMP regulations apply to their operations. Without a documented maximum intended inventory of highly hazardous or toxic chemicals—and relevant regulations—facilities are unlikely to address process safety in a structured manner. Ensuring that all relevant regulations are understood and applied is a crucial first step to improving process safety.
- Mechanical Integrity. Mechanical integrity programs for managing fixed equipment like vessels and piping, for example, are generally well structured. However, I have seen issues commonly arise with rotating equipment and control systems with problems such as:
- Inadequate lubricating oil monitoring systems for larger rotating equipment.
- Insufficient vibration monitoring and tracking for rotating equipment.
- Inadequate maintenance of sensors, alarms, emergency stop functions, and interlocks, including safety instrumented systems (SIS).
- Lack of safety-critical equipment categorization and adequate testing.
I feel that many companies could improve their mechanical integrity programs in these areas. Existing PSM-compliant PHAs can be used to identify critical safeguards and they can be tagged as such in maintenance management systems; and then proper application of inspection, testing, and preventative maintenance (ITPM) of these safeguards can greatly enhance the reliability and safety of the process systems.
- Incident Investigation Methods. One-size-fits-all approaches, while common, often lead to under-investigation or over-investigation. There are several factors pertaining to incidents and near misses with respect to the selection of an appropriate investigation methodology, and in my opinion, the most important factor is the actual and potential severity. A variety of more involved methods involving deep-dive root cause investigations and formally trained leaders and teams should be reserved for the more serious incidents and near misses. For medium-impact incidents and near misses, consideration should be given to “lighter touch” root cause investigation methods, including, among others, the five-whys investigation. And for the lesser severity incidents and near misses, I am a big fan of the after-action review (AAR) method. AARs can also be used in the immediate aftermath of an incident to compile essential evidence and obtain the views of the people most closely involved with it. I should not fail to mention that some equipment-centric incidents may be best suited for investigation using reliability engineering techniques.
- Action Item Management. While organizations may be tracking actions, what tends to be lacking are whether managers—and their direct reports—have a clear handle on appropriate response and remediation protocols. Actions come out of a number of process safety elements including process hazard analyses, incident investigations, audits, and management of change activities. One of the most frequently identified concerns I see in audits, is a concept I like to call future-looking closures; that is, an action closed out today with a comment that it will be addressed in some future activity. Sadly, many times that future planned work never happens and the well-intended action is lost. This issue can be tackled in several ways, but the best tracking systems I have seen set up clear expectations for what documentation and evidence are required to close an action (which excludes promises of future work) and have a secondary review and sign-off by a management representative to ensure those expectations are met.
- Emergency Training, Planning and Response. Emergency training, covered by the PSM standard and OSHA 1910.38, tends to be a strength for most facilities. Key focus areas often include incident command structures, internal response capabilities, equipment availability, and loss of containment scenarios. However, with a focus on internal operations, teams will often de-prioritize external coordination—an area where emergency response tends to be lacking. For instance, what are the protocols for reviewing and discussing the potential for serious releases with facility neighbors? How are neighbors alerted to releases? Is there adequate involvement with local emergency response planning committees and coordination with municipal emergency responders? Not only do potential problems have the potential to impact surrounding communities, but those same communities also provide support for mitigating additional consequences for the most serious process safety incidents.
- Change Management. Over time, organizations and facilities evolve. It’s common to overlook the personnel shifts that accompany these transitions. Use of a management of organizational change system, backed up with strong templates to trigger thoughts about potential process safety knowledge gaps due to personnel changes, is a crucial and woefully underutilized tool. Here are some situations in which important information is likely to fall through the cracks:
- Integration of new employees, whether through hiring or restructuring.
- Providing clear expectations for how employees contribute to a facility’s process safety culture.
- Management and technical staff turnover that results in loss of institutional knowledge.
A robust process safety culture is a powerful value-add for your organization. Beyond simply adhering to legislation, regulatory, and compliance requirements, well-defined processes can drive safety and environmental performance, along with improving the capability of your facility staff. It can even improve camaraderie and a sense of facility personnel feeling valued on the job, which can lead to a virtuous cycle of ongoing process safety improvements.
