SEARCH

SEARCH BY CITATION

Keywords:

  • process safety information;
  • process safety management;
  • process chemical;
  • process technology

Abstract

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

Many accidents in process industries have occurred because of employees did not recognize the hazards and risk associated with the activities they were undertaking such as when operating, changing, or maintaining processes, plants, and equipment. Recognizing these hazards and risk requires a company to develop and maintain a corporate memory through an effective management of process safety information (PSI). One of the established standards that addressed the above issue is PSI of Process Safety Management (PSM) 29 CFR 1910.119(d). This article presents a PSI implementation technique that could fulfill with 29 CFR 1910.119(d) requirements. It provides organized strategies to manage documentations, communicate information, and written program for maintaining, revising, and updating hazardous chemical, equipment, and technology information. Process and Instrumentation Diagram (P&ID) is used as a foundation for data management. The developed technique has been transformed to computer database prototype known as Process Safety Information Management System (PSI4MS), which articulately demonstrate the concept. Implementation of this technique could help employers manage and control hazards of process plant and compliance with PSM regulation. © 2013 American Institute of Chemical Engineers Process Saf Prog 33: 41–48, 2014


INTRODUCTION

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

With the rapidly increasing scale and complexity of the modern process industries, it is becoming harder to control accidents in these process plants [1]. Industrial accidents not only provoke a decrease in human capital; they also generate financial losses due to disruptions in industrial processes, damage to production machinery and technology, harm to the firm's reputation, as well as provoking catastrophic damage to the environment. They, consequently, have a negative effect on the competitiveness and economic potential of both companies and countries. Their consequences highlight the need to develop strategies to prevent accidents, or at least a cushion their adverse impacts [2].

Statistical analysis conducted by Kidam [3] found that majority of accidents happened in the chemical process industry were mainly caused by technical and engineering failures. A similar figure has been discovered in nuclear industry [4, 5], aviation industry [[6]], and the other process industries [7]. However, accident not only causes by technical factors but can be from human and organizational. It is also typical to have all factors contribute to the accidents at the same time [8].

To prevent major accidents from occurring, regulatory bodies worldwide posted certain industrial process safety standards that come in many forms, including mandatory standards, voluntary standards, and consensus codes. One of the established mandatory standards is Process Safety Management (PSM) of Highly Hazardous Chemical, 29 CFR 1910.119 by the US Occupational Safety and Health Administration (OSHA) in 1992 [9]. The industries and regulatory bodies worldwide agreed that PSM would drive a major improvement in process plant safety and to protect human and capital assets [10-12]. The implementation of PSM could prevent accidents if process plants follow the regulation as intended [13].

It is assumed that the number of plant accidents would be reduced significantly after implementation of the standard. However, 46 full investigation reports (1998–2008) of plant facility accidents published by U.S. Chemical Safety and Hazard Investigation Board indicate that accidents have not decreased as expected [14]. Half of the reported accidents occurred in the PSM implemented plants while another half in smaller plants that are not covered by PSM [13]. The Canadian Chemical Producers Association 2004 process related incidents measure analysis report of 89 incidents has shown that six PSM elements contributed to 85% of occurred incidents. Namely, these elements were, “Process and equipment Integrity,” “Process knowledge and documentation,” “Process risk management,” “Human factors,” “Management of change (MOC),” “Capital project review and design procedures” [15]. These reports clearly demonstrate that there are potential issues in implementation of regulations from OSHA.

Currently, the PSM implementation degrees were varied from plant to plant due to lacking of systematic technique for industries to comply with PSM requirements and maintain the effective process safety programs [16, 17]. Actual implementation costs for the PSM regulation have been orders of magnitude higher than originally estimated [18]. PSM auditing costs are high, and people are doubtful about its effectiveness [19]. PSM documentation is very difficult and requires great effort. Also, good documentation is just beginning and proper utilization is again difficult [15]. In general, the PSM implementation requires much effort and time but pays off well if implemented fully [20, 21].

The PSM standard contains 14 elements, including Process Safety Information (PSI) 29 CFR 1910.119(d). PSI is the backbone of a process safety program and used for other PSM elements. The compiling of this information will provide a necessary resource to a variety of users, including the team that will perform the Process Hazards Analysis (PHA), developing the training programs and the Operating Procedure, those conducting the Pre-Start up Safety Reviews, local emergency preparedness planners, and enforcement officials. However, the usefulness of PSI is dependent on the accuracy and reliability of the information [22]. It is also essential that all employees know that the information exists, where it is located and how it can be accessed [23].

It is motivating to note that for most accidents, companies are cited for failure to comply with this standard, and no companies are cited after the accident for having a good PSM program [24]. Among all OSHA citation data, incomplete PSI was one of the most frequently cited [22]. Updating of PSI information is quite common in process plant, especially, when changes involving hazardous raw materials, facilities issue, organizational structure, etc. Any changes of these components need to be adequately managed, so that process hazards and risk could be effectively controlled. While this sounds simple, companies often find they lack the internal expertise or resources to get the job done, which can have major regulatory and safety implications [15-17].

The objective of this study is to propose a structured technique toward implementing PSI element of OSHA PSM. The document filling and tracking systems of information identifying workplace hazardous chemicals, equipment, and technology used in processes plant will further be discussed.

FRAMEWORK

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

Compliance with PSI of PSM Regulation

PSM as specified by OSHA requires a company to meet certain PSI requirements and documentation. However, OSHA does not specify any method for industries to follow in order to comply with the standard. Failure to produce documentation will become a citable deficiency. The intent of this paragraph is to provide complete and accurate information concerning the process.

A framework in Figure 1 summarizes vital information and a strategy to manage and implement PSI as required by 29 CFR 1910.119(d). The first step in PSI implementation is by checking the availability of PSI program at the process plant. If the information is not available, the employer is required to take necessary actions for the development of the PSI program as required under 29 CFR 1910.119(d)(1).

image

Figure 1. Framework of PSI management based on 29 CFR 1910.119(d). [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

Next step, the written information of highly hazardous chemicals, the process, technology, and equipment are compiled and tracked following 29 CFR 1910.119(d)(1)(i-vii), 29 CFR 1910.119(d)(2)(i)(A)-(E), and 29 CFR 1910.119(d)(3)(i-iii), respectively. The availability of the information is checked using checklist system and stored together with revision date, approval information, and evidence location. For any incomplete information, the data should be obtained in order to comply with the PSI requirements as above. However, it is crucial to have all the relevant information available prior to the development of PHA as stated in 29 CFR 1910.119(d)(2)(ii).

Using Piping and Instrumentation Diagram (P&ID) as a Foundation for Data Management

In this article, a technique is proposed by following the node system based on P&ID to manage and track documents of PSI. The P&ID is used as a foundation for its development since it represents the details of the equipment and auxiliary in the process plant. Therefore, all the information can be rigorously traced and missing information can be prevented. Using P&ID as an interface for this technique could enhance end users' acceptance since it is commonly used in a process plant. Figure 2 shows the framework of how P&ID is utilized in managing process information within a process plant.

image

Figure 2. Framework of PSI development using P&ID as a foundation.

Download figure to PowerPoint

The P&ID is divided into several nodes. The number of nodes selected depends on the design intent and the number of equipment within the process plant considered manageable by the end users. The PSI implementation for each node is carried out according to 29 CFR 1910.119(d)(1)—(d)(3) standards as shown in Figure 1. Once information has been compiled and updated for the selected equipment or stream, the end users can choose another equipment or streams within the selected node. After all the information within the node has been updated, the end users can select the next node to review or update the data. The updating information process will continue until all nodes in the P&ID are completed. For some cases, the node size may be quite large depending on the scope of the process. One P&ID may not capture the whole process well. Regardless numbers of P&IDs involve; similar steps should be adopted until the whole process plant is covered. This is one of the structured techniques for PSI data compilation in order to overcome large data fuzzy and messy situations, which are common problems in handling PSI data.

PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

Even though the provision contained in OSHA PSI can be done manually, the best results can be obtained through the help of a computer database system. The amount of time and effort can be significantly reduced and on top of that, implementation of PSI element can be done effectively. A prototype database management system known as PSI4MS was developed to demonstrate the concept as illustrated in Figure 1 and 2 using Microsoft Office Access 2010. PSI4MS provides an improvement of the database developed by Early (2006) [17], whereby it provides in detail how to comply with all the PSI requirements and could ensure that information is kept current throughout process changes, equipment maintenance, and other normal activities.

PSI4MS interfaces contain details of the mandatory requirements for employers to comply with PSI element of PSM. The system provides the mechanisms for capturing information throughout the various stages of process development, design, construction, operation, maintenance, and decommissioning. Individuals involved in each stage of the process “life cycle” could also receive guidance on the types of information to be documented, where and how the information is to be retained. As the information may be found in many different places, such as standard operating procedures, P&ID, and original equipment manufacturer's manual. The system has been designed to allow for capturing documented data at specific evidence location either it in paper form within files, in computer data bases or on a computer-aided design system.

PSI4MS provides an effective communication process to all authorized employees by allowing access to the information and acknowledged when changes are made on the chemical, technology, and equipment being used in the process. On top of that, PSI4MS will not only provide company with what is most important, a safe workplace, but it will also provide the tools and methods to meet the requirements of regulatory compliance and verification audits.

End users may adopt the PSI4MS concept to develop and customize the database that suit with their plant. Information Technology experts are required to develop and optimize the database to be cost effective, and ensure the system can retain large data and maintain for the long term implementation in process plant. The same concept can also be applied to pilot plants, which do not fall under PSM requirements but need the same level of safety rigor as actual plants.

CASE STUDY

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

To verify the implementation of PSI element using this technique, a case study was conducted using real data from LPG treating unit (LPGU) of oil and gas refinery Plant X in Malaysia. The unit is used to remove hydrogen sulphide (H2S) and reduce mercaptan (R-SH) content in various LPG blend stock. Since the daily operation of the unit is more than 10, 000 pounds, Plant X is obliged to comply with OSHA PSM regulations. Sample of the conducted PSI using PSI4MS is presented in this article that articulately explains the concept. Referring to the idea described in section 2.2 and the framework in Figure 2, the P&ID was divided into several nodes according to its design intention. Figure 3 shows the selected node for this case study, which consists of a phase separator (V-201) with inlet and outlet streams.

image

Figure 3. Part of the overall LPGU P&ID showing phase separator (V-201). [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

Development of PSI Based on 29 CFR 1910.119(d)

Figure 4 shows the main interface of PSI4MS that consists of “Sub standard”, “Description”, “Complete”, “Incomplete”, and “Remarks” columns. This interface is used to assess and monitor the compliance status of all substandards under 29 CFR 1910.119(d). All the requirements are managed and monitored by PSI4MS using data captured through digital forms that can be stored in a centralized database. The forms tabular required written information for process chemicals, technology, and equipment that must be compiled pursuant to the compliance with OSHA PSM as shown in Figures 5, 6, 7, respectively. On the top of that, the end users would always be alerted of insufficient process information of covered processes that need to be compiled to ensure the accomplishment of hazards control and risk reduction program.

image

Figure 4. PSI development interface of PSI4MS. [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

image

Figure 5. Process chemical interface of PSI4MS. [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

image

Figure 6. Process technology interface of PSI4MS. [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

image

Figure 7. Process equipment interface of PSI4MS. [Color figure can be viewed in the online issue, which is available at wileyonlinelibrary.com.]

Download figure to PowerPoint

For instance, Figure 5 shows the interface of PSI4MS for chemical data with “Sub standard”, “Requirement”, “Description”, “Revision date”, “Approved by”, “Evidence location”, “Complete”, “Incomplete”, “Remarks”, “Action by”, and “Due date” columns. All hazardous chemicals involved in selected node are listed here with the overall compliance status of all substandard of 29 CFR 1910.119(d)(1). The listed substandard 29 CFR 1910.119(d)(1)(i-vii) in the interface act as guidelines to end users about the crucial information that needs to be documented and compiled.

The interface prompts the authorized personnel to describe the availability information as covered in the “Description” column. Authorized personnel can be PSM team member, process unit coordinator, etc. who involves in PSI implementation at the chosen study node. They have a responsibility to upload, update, and follow up all the required information and action in PSI4MS. Different access level is required for authorized personnel to ensure the security of the data. Other employees only can read the information and give any feedback if necessary. The document issued can be tracked by referring to the date of document as given in the “Revision date” column. This system allows for tracking the completion of PSI data changes and the frequency of updating the data is depending to the new data updated in the plant such as from PHA, MOC, PRRS, etc. The information on the revised date is important to ensure the compiled PSI data are updated, maintained, and consistent with the ongoing operations. For distribution of information and future references by affected employees, process safety team and auditing purpose, the documented information can be stored in the database. The system also allows the information to be kept in a hard copy as referred to the “Evidence location” column.

The completeness of the written process chemical information is tracked by a checklist in the interface. Once completed, the authorized personnel can tick the “Complete” check box. Then, lacking of information is directly discovered through the checklist that necessitates further actions. A superior can assign the qualified personnel to provide the specific information in the “Action By” column, and provide a reasonable due date at “Reply date” column. Therefore, the appropriate action can be taken, monitored, and resolved in a timely manner.

Highly Hazardous Chemicals Used or Produced by the Process 29 CFR 1910.119(d)(1)

The information to be compiled is on the process chemicals. It needs to be comprehensive enough for an accurate assessment of fire and explosion characteristics, reactivity hazards, safety and health hazards, corrosive or erosive effects on the process equipment and instrumentation, and the existence of incompatibilities between materials commonly found around covered processes. While these data are required to be compiled for regulated substances, compiling the same information for other substances that may potentially impact the process would be recommended under this effort as well.

One of the methods to commence, this effort is by extracting the data from Material Safety Data Sheets (MSDS). Note that, PSI4MS does not specifically require the facility to have MSDS, but other regulatory entities such as Hazard Communication CFR 1910.1200(g) do have this requirement. Regardless the availability of MSDS, the chemical data according to 29 CFR 1910.119(d)(1) must be compiled. In the other words, the system should be flexible to accept any data as long as it can fulfill the above requirement.

In this case, it is found that the written information on process chemicals of the selected node is completed except for data on corrosivity (Figure 5). As an example, PSI4MS captured that the H2S documentation is stored at C:\Amine_Treater-V-201\Process_Chemical\H2S (REV.A120092008).pdf. The data consistency is checked against the document number (i.e., MHSD-061), the date of revision (i.e., 20-09-2008), and the approval authority (i.e., process unit leader).

For the incomplete H2S corrosivity data, the designated personnel was assigned to “Ahmad Samad Zainal (ASZ)” who should provide the information within the time frame as shown at “Due date” column. The data may content the corrosive or erosive effects of H2S on equipment and instrumentation. Once the information is updated, all the required information of H2S is considered completed. The process of compiling and updating the written information continue until all hazardous chemicals involve in the process nodes are accomplished.

Process Technology 29 CFR 1910.119(d)(2)

A thorough development of written information pertaining process technology is important to ensure a quality process hazards identification and assessment. Without this information, the consequences of many process deviations cannot be adequately defined. In this case, all required process technology information for this node is completed and ready to be accessed (Figure 6).

Process Equipment 29 CFR 1910.119(d)(3)

The PSI should contain detailed written information about the equipment in the system so that employees operating and maintaining the system know what components are involved. Referring to Figure 7, PSI4MS captures information pertaining materials of construction, updated P&ID, electrical classification, relief system design and design basis, design code and standard employed, and safety system of V-201.

The materials of construction, electrical classification and design code, and standard employed information have been recorded in Basic Engineering Data (BED) of LPGU, specifically for the pressure vessel. The document has been kept with reference number S-00–1222-001\BED\Carbinet-02\LPGU. After the reviewing process, it was found that information of materials used for constructing V-201 is outdated. The second and third coating materials have been changed and informed through changes notification. From here, appropriate action has been engaged to close the identified gap.

For other information including relief system design, safety system, and material balances for this node is written in Operating Manual of LPGU. Nevertheless, OSHA PSM also requires energy balance data to be included under process equipment. Thus, another gap was identified for this node. By using PSI4MS, appropriate action already taken to close the identified gap with a time frame to ensure the issue resolves in a timely manner. All the above information is accessible by PSM team members, authorized employees, affected contractor, and emergency response team for reference and task delegation.

CONCLUSION

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

A systematic technique toward PSI element of PSM implementation in process plant is presented in this study. The strategy for implementation and process data management is clearly tabulated through established PSI and P&ID frameworks. Besides that using node system has a potential to overcome large data fuzzy and messy situation. The developed model known as PSI4MS has shown that the introduced concept is capable of maintaining the updated process information in a structured manner. The system also assists the end user to identify the gaps and initiate the appropriate action should be taken in order to close the identified gaps. Implementation of this technique will not only provide company with the most important, a safe workplace, but it will also provide the tools and methods to meet the requirements of regulatory compliance and verification audits.

ACKNOWLEDGMENT

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED

The authors would like to thank Universiti Teknologi PETRONAS for the graduate assistantship awarded to H. Abdul Aziz.

LITERATURE CITED

  1. Top of page
  2. Abstract
  3. INTRODUCTION
  4. FRAMEWORK
  5. PROCESS SAFETY INFORMATION MANAGEMENT SYSTEM (PSI4MS)
  6. CASE STUDY
  7. CONCLUSION
  8. ACKNOWLEDGMENT
  9. LITERATURE CITED