Over the years, the process industries have evolved several strategic approaches for chemical accident and loss prevention. At any given time, industries, companies and facilities will not find themselves at the same point along this spectrum. In fact, different departments within a facility, different functions within a department, or the same departmental function at different times, may choose to implement multiple strategies at the same time.
Standards-based process safety management
For a long time, companies depends sorely upon experience-based standards to define their process safety and loss prevention efforts. These standards included both internal company practices and external consensus-based standards, such as standards issued by the ANSI, API, ASME and NFPA. In a standards-based process safety management strategy, an organization relies on applying proven design, operating and maintenance practices that have evolved through years of hard lessons (i.e., accident and other loss events). However, because process safety incidents are typically rare, past experience alone may not adequately alert at company about how to prevent future accidents.
Standards-based process safety management is a prescriptive approach that is fairy easy to implement; however, it can lead to a mixed spectrum of performance. Companies might limit their process safety effort to conformance with consensus codes or standards, event though many process-specific failure issues are not addressed in consensus-based standards or the standards may not address recently discovered failure issues. For many companies not subject to additional federal or state requirements, consensus standards remain the core of their accident prevention and process safety programs. Fortunately, standards organizations have begun to adopt policies that will help ensure that codes and standards are routinely updated to reflect new experience and technology. Some standards organizations have also begun to adopt performance-based and risk-based approaches in their codes and standards to allow companies more flexibility in managing risk.
Compliance-based process safety management
In reaction to public concerns about the actual and potential effects of major accidents involving the chemical process industry, government agencies issued regulations to define minimum levels of accident prevention activity for the protection of workers, the public and the environment. Many accident prevention regulations, including OSHA’s process safety management (PSM) standard and EPA’s risk management program (RMP) rule in the U.S., and the Seveso II Directive in the EU, are performance-based regulations that allow companies some degree of latitude to tailor their process safety activities to the appropriate level of risk.
Regulations establish minimum requirements that, in some situations, may not be enough to adequately manage risk while, in other cases, may force companies to overwork process safety issues. The PSM and RMP regulations prompted many companies to implement new activities that have achieved important process safety performance improvements. Although this catalyzed many positive results, these regulatory compliance drivers have also contributed to some companies adopting a compliance-only mindset.
Regulations tend to be experienced-based and take into account national resource constraints. Subsequently, situations deems hazardous in theory but that have not manifested themselves sufficiently to warrant national attention may not be addressed in regulations. In addition, facilities containing quantities of a hazardous substance that are below the threshold quantity stated in the regulation are not bound by process safety compliance, although risks still exist for these facilities. Thus, a compliance-only approach is not like to be the optimum strategy for a particular company or facility.
Continuous improvement-based process safety management
With the growth of various total quality management programs, many companies applies the same emphasis on continuous improvement, a hallmark of a quality focused operation, to process safety programs. Companies recognized that merely trying to maintain the status quo in chemical accident prevention was not good enough for three reasons. First, companies have found that “treading water” in process safety can lead to declining performance. Second, global competitiveness demands that companies seek to improve quality and reduce costs. Finally, society’s safety expectations are constantly increasing, and most companies intend to meet those expectations to remain welcome members of the community.
This desire led to the incorporation of continuous improvement mantras into the environmental, safety and health policies of many companies, “Let’s learn from our experience” evolved into a more proactive approach, with an expectation to “keep raise the bar.” A traditional continuous improvement-based strategy uses lagging indicators to define historical performance and to help guide management system changes based upon the feedback. This model works well when a highly responsive link exists between a business process and one or more lagging in indicators. However, this strategy is likely to fail when the lagging indicators are low-frequency, high-consequence events such as catastrophic accidents. The absence of loss events does not reliably indicate that a process safety management system is working well.
Risk-based process safety management
In a risk-based process safety management approach, the organization complies with regulatory requirements, appropriately applies lessons learns from experience across the company or industry, and continues to use lagging indicators to help guide its process safety program. However, risk information and leading indicators are also studies by management to help measure and reliably predict the performance of various aspects of the system, independent of any loss events. Risk information is also used to determine the level of effort and management attention that is appropriate for the risks that have been identified. Management review, a process in which the management team periodically sets aside time to determine how management systems are really performing, supplements risk understanding and metrics.
Understanding hazards and risk, monitoring a suite of leading and lagging indicators, and periodically conducting management reviews helps managers highlight strengths, identify weaknesses, and take corrective action in a timely manner. The major challenges in moving to this strategy are (1) developing an adequately detailed and accurate understanding of risk, (2) managing the initial difficulty in selecting the appropriate performance metrics, (3) acquiring the discipline required to maintain these performance metrics, (4) developing the organizational trust and integrity to candidly review performance, and (5) overcoming resistance to making management system changes based on the predictive metrics.
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