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288 Human Factors Handbook Figure 22-4: Stress management – training strategies 22.4.3 Achieving shared situation awareness in emergencies Shared situation awareness means the ability of team members to gather and use information to develop a common understanding of the task and the environment. Lack of situation awareness is another factor that can contribute to errors. Individuals often form different impressions of a situation without realizing they are doing so. Differences in understanding of a situation contribute to difficulties in decision-making and thereby impact the resolution of the problem. It is important that individuals receive information. However, this should only be information that is relevant to their jo b role and to the task in hand. Providing each team member with all the available information relevant to the error or incident would create information overlo ad. Effective error management requires awareness of individual team members’ tasks, and the whole situation. Cognitive control –mindfulness Individuals learn how to regulate distracting thoughts, to allow them to maintain concentration on the task in hand. Physiological control –tactical breathing Individuals learn how to step away from situations, calm their bodies' responses (shaking, heavy breathing), and regain control of their breathing. Modeling Learners are given the opportunity to observe another team in a stressful situation, and to then assess the effectiveness of their performance. Time-sharing skills Learners get the chance to work on task prioritization skills. Overlearning Learners are over-trained beyond the level of proficiency that would normally be required for the particular task. See Chapters 20 and 21 for information on situation awareness or loss of situation awareness.
10 • Risk Based Process Safety Considerations 201 potential failures that could forese eably occur in a complex process. Thus, the prudent PHA approach used in Element 7 assumes that all the other elements in Pillar III have been adequately designed, implemented, and are being sustained . This includes assuming that a robust ITPM program exists and is effective. Thus, “unexpected” equipment failures should not occur. A more detailed discussion of the types of assumptions made by a PHA HAZOP Team are provided in the Appendix. As was discussed in Chapter 4, the maintenance strategy for process shutdowns includes coordina ting the schedules between the operations and maintenance groups, as the equipment should be available when its maintenance is performed. Inspections and tests which do not require time for a process unit or utilities shutdown time are easier to schedule and perform; those that do require a shutdown time should be coordinated wi th the production schedulers. Emergency repairs on equipment that failed unexpectedly delay the expected production schedule, adding undue stress to personnel across the organization. Again, a ro bust ITPM program should be in place to help prevent unexpected failures, especially for critical equipment used in the engineeri ng controls required for safe operations. One approach to ensure a robust ITPM program poses two questions that help identify critical equipment: How are the essential controls identified and how are the controls maintained to prevent unexpected failure? These question s apply to all operating modes: normal, abnormal, emergency, and t ransient. The answers to these questions follow. 1) How are the essenti al controls identified? The critical engineering and administrative controls can be id entified through a Process Hazard Analysis (PHA), often by selecting high-risk scenarios from a Hazards and Operability Study (HAZOP) and pe rforming a Layer of Protection
Sustaining Process Safety Performance Learning Objectives The learning objectives of this chapter are: Understand the importance of investigating and learning from incidents, and Understand methods to sustain and continuously improve process safety performance. Incident: Space Shuttle Columbia, 2003 Incident Summary The NASA Space Shuttle, Columbia, was destro yed during its re-entry into the Earth’s atmosphere at the end of a 16-day voyage, ju st 16 minutes before scheduled touchdown. During the launch, a large piece of insulation foam became detached from the area where the shuttle had been attached to the external fuel tank and hit the leading edge of the left wing. After the incident, it was discovered that a fr agment of the thermal protective panel drifted away from the wing while in space. At the critical part of re-entry when friction with the Earth’s atmosphere is at its greatest, superheated air entered the left wing, destroying the structure and causing the spacecraft to lose aerodynamic control, and break up (Figure 22.1). All seven of the crew were fatally injured. Within tw o hours of loss of signal from Columbia, the independent Columbia Accident Investigatio n Board (CAIB) was established following procedures that had been put in place after th e Challenger disaster 17 years earlier. (CCPS 2008) Key Points: Process Safety Culture – It can take time to build a strong process safety culture but not long for it to degrade. Having a strong process safety culture requires constant vigilance and leadership. Measurement and Metrics – “You get what you measure” is a quote attributed to Peter Drucker, a widely recognized management consultant. However, if you are not measuring the right things, you likely won’t get the best results. Choose what you measure carefully. Description Columbia was launched on January 16, 2003 for the 28th time. At 81.7 seconds into the flight, a large piece of insulation foam became detach ed. The detached piece of foam hit the leading edge of the left wing 0.2 seconds later (Figure 22.2). The event was not observed in real time. This event was not detected by the crew or ground support functions until detailed examination of the launch photographs and vide os took place the following day. A Debris Assessment Team was created to determine whet her the event had caused critical damage to the shuttle. No adverse effects were noticed by the crew or support staff as the mission
Plant Process Control 295 Here, plant‐wide hydraulics means the adjustment of parameters in such a way as to guarantee the movement of fluid from point “ A” at the beginning of a plant to point “Z” at the end of the plant. Flow, pressure, and level control loops are what pri- marily dictate the hydraulics of a process plant. Table  15.1 shows their functions in different process items. This table basically says: ●A pressure loop in a gas container is similar to a level loop in a non‐flooded liquid container. ●A pressure loop on a gas pipe is similar to a flow loop on a liquid pipe However, it should be mentioned that it is not very common to use pressure loops on liquid‐filled enclo-sures (including pipes and containers). Possibly the best approach is to use flow/pressure loops paired with level/pressure loops on an adjacent container (Figure 15.3). However, the question still remains: what would be the “arrangement” of flow/pressure loops paired with level/pressure loops on an adjacent container? This question will be answered when we learn about surge control.15.4 Surge Control The second purpose of plant‐wide control is surge management and control. Change, surge, disturbance, fluctuation, or whatever you want to call it, is part of our life. Everything around us is changing. However, a plant is supposed to generate a product with a specific flow rate and a specific compo-sition (quality). Therefore, somehow surge needs to be managed in a plant. This is one of the duties of plant‐wide control. Be careful: when we install a control valve on a pipe, we don’t “eliminate” surge; we only try to prevent the surge from spreading to downstream equipment. This “blocked” surge needs to be managed somehow. The following section explains different types of disturbances in a process plant. 15.4.1 Disturbanc es in Process Parameters Let’s have a look at some examples of disturbances occur - ring with each process parameter: ●Flow. Process plants always experience disturbances in flow. This is the most important and most frequent parameter to consider when considering disturbance management. ●Temperature. You can have a disturbance when there is a change in ambient temperature that will affect the process. Temperature disturbance can be com-pensated for (managed) in heat transfer equipment. There are two main types of heat transfer equip-ment: fired heaters and heat exchangers. Temperature disturbance is managed in a better way if there is a fired heater. When there is a heat exchanger, the temperature disturbance can be managed in a better way when it is a utility heat exchanger, rather than a process heat exchanger.Table 15.1 Plan t hydraulic control. Purpose Gas/vapor Liquid Container Inventory controlP‐loop Non‐flooded: L‐loop Flooded: F‐loop Pipe Material transportation controlP‐loop(or F‐loop if it is around a gas mover)F‐loop Level/pressure loop on a container Level/pressure loop on a container Flow/pressure loop o a pipe Flow/pressure loop o a pipe Figure 15.3 Plan t‐wide control – third attempt.
TOOLS AND METHODS FOR MANAGING ABNORMAL SITUATIONS 147 Many of these categories are appropriate across the process industries. Practical measures have been deve loped that can assess both the process of acquiring situational aw areness (SA) and the product of situational awareness. Improvement of situational awareness seems to focus on two main strategies, either the design of the system interface to encourage better sampling and re duce the cognitive workload or training in situational awareness at the individual and team levels. CRM assessment and training can therefore be an effective tool to help in the management of abnormal situations, and not just in the aviation sector. It has been adopte d in other areas including medical, shipping, nuclear, as well as the oil and gas sectors. The assessment uses a behavior rating system based on a defined set of skills, with their component elements and associated examples of desirable and undesirable behaviors. Suggested content for a training syllabus for CRM can be found in the IOGP guide (IOGP 2020) and in the Energy Institute Guide (Energy Institute 2014). For the chemical and process in dustries, the shift teams could undergo a similar assessment to ensure they work together effectively, especially during an abnormal situation. 5.8 LEARNING FROM ABNORM AL SITUATION INCIDENTS CCPS has included Learn from Experience as a pillar for Risk Based Process Safety and listed Incident Investigation as one of the primary elements under Learn from Experience. Table 5.9 references some tools that are frequently applied to learni ng from incidents and can be applied to abnormal situation incident prevention.
16 Task planning and error assessment 16.1 Learning objectives of this Chapter By the end of this chapter, the reader should understand: • The importance of effective and realistic task planning. • The role that “error assessment” can play in foreseeing and preventing error, by engaging in effective task planning and preparation. Task planning refers to developing a maintenance or turnaround plan, a start- up plan, temporary operating instructions , re-commissioning plan or producing a work instruction. It may also include setting people to work in operating a process, such as briefing operators at the start of a shift. 16.2 Incident example 16.2.1 What happened? The Energy Institute’s “Toolbox” provides many examples of failures in task planning. One example, planning a confined space entry, is repeated in Table 16-1. If heating oil had been introduced into the tubes while personnel were in the heater, they could have been injured. The example refers to locked blinds, as part of HEC (Hazardous Energy Control). In some countries it is more common to use blind tags. The U.S. OSHA equivalent of HEC is LOTO (Lock Out- Tag Out). Human Factors Handbook For Process Plant Operations: Improving Process Safety and System Performance CCPS. © 2022 CCPS. Published 2022 The American Institute of Chemical Engineers.
6 Guidelines for Revalidating a Process Hazard Analysis Regardless of the origin of a partic ular What-If or Checklist Analysis question, the analysis prompts the haza rd evaluation team to consider and document potential abnormal situatio ns, their consequences, and the risk controls. The team judges whether the risks are controlled within the organization’s tolerance, and if not, makes recommendations for improvement. FMEA. The FMEA technique is a systematic analysis of single component or functional failure modes and each failure mode’s potential effect(s) on a system. For each failure mode, the team (1) determ ines if any consequences of interest would result, (2) identifies engineering and administrative safeguards and controls protecting against the failure mo de, (3) evaluates risk associated with the failure mode, and (4) if necessary, makes recommendations to reduce the likelihood of the failure mode or the severity of the consequences. The FMEA method is best suited for analysis of mechanical and electronic systems, so it is sometimes selected as the core methodology for processes involving compressors, centrifuges, or highly automated systems. However, FMEA is poorly suited for processes involving reactive chemistry or human interactions where the PHA needs to co nsider human errors as causes of hazardous events. Therefore, the overwhelming majority of PHA teams use the HAZOP or the What-If/Checklist combination as their core methodology. FMEA is more often applied as a complement ary analysis for specific, complex equipment to generate a systematic refe rence list of components, their failure modes and effects, and prioritized ma intenance task lists for increasing equipment reliability. 1.2.2 PHA Complementary Analyses In a PHA, complementary analyses are used by the PHA team in addition to the core methodology to help provide focus and direction on specific topics. The two most common complementary analyses address human factors and facility siting. These complementary analyses are often reviews of checklists that have been developed by a company or adap ted from industry publications and standards. However, complementary analyses can involve much more sophisticated studies such as comput ational fluid dynamic analysis and modelling of vapor dispersion or finite element analyses of structural response to overpressure and dynamic loads. While the selection, development, and application of these analyses are outside the scope of this book, it is important to note that complementary analyses required by a regulation or company policy must also be revalidated.
284 INVESTIGATING PROCESS SAFETY INCIDENTS Recommendations targeted at “softer” issues, such as human and organizational factors including the work environment, safety culture, leadership and management. 12.3.1 Inherently Safer Design Recommendations that lead to inherently safer designs are preferred to those that add extra mitigative or preventive features (Kletz, 1985). Inherently safer designs limit reliance on human performance (e.g., following procedures), equipment reliability (such as control systems and interlocks), and properly functioning preventi ve maintenance programs for the successful prevention of an inci dent. Inherently safer design features are more practical and economical if they are implemented during the design stages of a facility. Making design ch anges to an existing process may not be feasible or practical. Nevertheless, the investigation team should consider whether there is an oppo rtunity to recommend a study on possible design changes that incorporate inherent safety concepts. An early reference to inherent safe ty was the subject of a lecture by Trevor Kletz in 1977 entitled: “What you don’t have, can’t leak.” This principle has evolved over the years and is typically presented in a hierarchy (minimization, substitution, moderat ion and simplification (Amyotte, 2018), as explained below: 1. M inimize: Advancements in process control, improvements in logistics and changing acceptable risk standards may have removed the initial justification for large inventories of hazardous raw materials, intermediates or prod ucts. For example, tight quality control of on-time deliveries of hazardous raw materials may allow for a one or two day supply on hand versus a one- or two-week supply. 2. Substitute: Sometimes substitution of a less hazardous material is feasible. For example, many chlorinating systems for water purification have been converted from pressurized cylinders of liquid chlorine to a pelletized, hypochlorite salt. 3. M oderate: Sometimes it is possible to achieve significant reductions in reactor size (and inventory) with improved mixing technology. Another example of inte nsification is changing from a batch operation to a smaller scale continuous operation. 4. Simplify: It may be possible to use a totally different process or method to accomplish the same objectives.
INVESTIGATION M ANAGEM ENT SYSTEM 71 are practical and will adequately address the root ca uses. Additionally, site management should ensure that any changes to equipment or procedures as a result of recommendations are properly evaluated before implementation. The space shuttle Challenger disaster is a classic example of the need to evaluate proposed recommendations. Before the Challenger incident, NASA was aware of the poor performance (Winsor, 1989) of the ring joint seal systems from previous near-miss incident investigations. In a well- meant effort to improve the safety margin, a decis io n was m ade to increase the pressure test from 100 to 200 psig (6.8 to 13.6 atmospheres) after the ring joints were reassembled. In reality, this recommendation actually decreased the integrity and reliability of the ring joint seals by increasing the deformation of the sea ling putty. An effective MOC analysis might have uncovered this increased risk. Chapter 12 provides guidance for formulating effective responses to investigation findings. 4.2.10 Recommendation Responsibilities The incident investigation team has the responsibility to develop practical recommendations and submit them to management. The investigation team may include comments on resuming no rmal operations and/or suggesting recommendations to be implemented befo re restarting the process. It is then the responsibility of management to: review the recommendations; approve them as written or ask for clarification, revisions, or alternative solutions; establish process safety re-start and ramp-up (normal capacity), criteria (CCPS, 2007) approve the final recommendations; assign action item priorities and target completion dates; allocate resources; and track implementation stat us and effectiveness. Regulatory agencies usually take special interest in the status of previous recommendations made at the same fa cility or similar recommendations made across the organization. Lawyers give this issue significant attention. The assumption is that prudent and responsible managers should promptly
174 | 13 REAL Model Scenario: Internalizing a High-Profile Incident 13.4 Drilldown As an experienced process safety professional, Rakesh knew well the concept described in CCPS Vision 20/20 of “Disciplined Adherence to Standards (CCPS 2020), especially as it applied to equipment designed to an older version of a standard. He clearly understood that even if the equipment, process, or practice has been legacied, the company must still determine if that process, practice, or standard manages risk adequately. With that in mind, he felt confident to skip the drilldown on the Baton Rouge incident and proceeded to examine the additional supporting cases. • Port Neal: Reading further, Rakesh discovered that not only was the automatic pH control out of service, the jacket coils that were supposed to keep the reactor warm during shutdowns without overheating had also failed. Essentially, the site operators had allowed failures to accumulate and were improvising to keep running; this was classic normalization of deviance. • Anonymous 2 and Aichi: The incident investigations did not describe the training the operator had received or how the layout of the systems could have fooled the worker into doing the wrong thing. Both factors could have contributed to the incident. But in any case, not verifying the material being unloaded and not sampling for a flammable atmosphere are both failures of operational discipline. • Healdsburg: Rakesh had previously worked in a brewery and was familiar with the type of hatch door used in the industry. Did the hatch seal go bad? he wondered. That would have caused a slower leak. Normally, the spring tension would provide enough resistance to keep the hatch shut, so perhaps the spring failed. Perhaps, he thought, the quick-release handle snagged on the belt or pocket of a passing worker, providing a much larger opening for the wine to drain out. Either way, a critical component that put the entire process at risk had not been maintained. At his former brewery, they had changed their procedures (from car- sealing the valve handle to locking it) to protect the handle from snagging on pallets of product being moved by forklift. • Shuttles: In both cases Rakesh reviewed, NASA was under tremendous political and economic pressure to launch. This pressure drove leaders to minimize the safety concerns raised by members of the program team and continue to operate under unsafe conditions. Rakesh recognized the conflict between production and safety when he saw it.
336 Human Factors Handbook 26.2 The importance of understanding error 26.2.1 Preventing reoccurrence People often assume that learning occurs automatically once an incident has been analyzed and lessons have been drawn from it. This thinking excludes the most important element of learning, which is ch ange. This refers to the application of learning (behavioral change) into the work environment. Learning is a continuous, ongoing proc ess, and takes place in day-to-day activities. The possibility of human error occurring exists in every task performed by any person working in the process industry. Error can happen, but it is manageable. Error should be fully understood to prevent its repetition. Individuals should look beyond the immediate causes and focus on the root causes and the sequence of events that took place before the error occurred. Blaming an individual is a barrier to truly understanding the error and will likely lead to the error reoccurring. For example, if the individual is blamed, then the procedure does not get rewritten and the operators will still be overly fatigued due to poor shift patterns. The error is likely to happen again. As stated by Todd Conklin [106]: "You can blame and punish or learn and improve, but you cannot do both." Learning requires that a person understands an issue and takes action. It requires changing behaviors and systems. Both understanding and behavioral change need to take place for learning to be fully accomplished. This will ensu re that the lessons learned are robust, and sustainable across time and changing circumstances. For example, do not focus on the operator failing to follow procedure. Instead, focus on the fact that the procedures were poorly written and difficult to comprehend, and that a high level of fatigue in the operator made it even harder to follow the procedure accurately.
B.2 Advancing Safety in the Oil and Gas Industry – Statement on Safety Culture |263 Leaders take action to address hazards and PSMS deficiencies. Leaders value safety efforts and expertise. The PSMS specifies an accountable officer with authority and control for hum an and financial resources. The PSMS specifies direct reporting lines between personnel with key process safety roles and the accountable officer.Timely action taken to mitigate hazards even when it is costly. Process safety roles receive equal status, authority, and salary to other operational roles. Leaders stand up for process safety even when production suffers. This usually presents an ethical dilemma for leaders. See Section 4.3 for a discussion of process safety culture and ethics. Safety is regularly discussed at high-level meetings, not just after an incident. Foster M utual Trust Attributes and descriptors for mutual trust include: Everyone proactively reports errors, near-misses, and incidents. Policies are in place to encourage everyone to raise safety- related issues. Employees know and believe that they will be treated fairly if they are involved in a near-miss or incident. Disciplinary policies are based on an agreed distinction between acceptable and unacceptable behavior. Mistakes, errors, lapses are treated as an opportunity to learn rather than find fault or blame. Positive labor relations.• • • • • • • • • • • • • •
188 Guidelines for Revalidating a Process Hazard Analysis Example Facility Siting Checklist 1 OBJECTIVE: To aid in identifying facility siting issues relevant to process safety issues within the scope of the PHA. Th e PHA team completing this checklist should seek assistance from subject matter experts as necessary. Q T R I. Spacing Between Process Components Are operating units and the equipment within units spaced and oriented to minimize potential damage from fires or explosions in adjacent areas? Are there multiple safe exit routes from each unit? Has equipment been adequately spac ed and located to safely permit anticipated maintenance (e.g., pulling heat exchanger bundles, dumping catalyst, lifting with cranes) and hot work? Are vessels containing highly ha zardous chemicals (HHC) located sufficiently far apart? If not, what hazards are introduced? Is there adequate access for emergenc y vehicles (e.g., fire trucks)? Can adjacent equipment or facilities withstand the overpressure generated by potential explosions? Can adjacent equipment and facilities (e.g., support structures) withstand flame impingement or radiant heat exposures? When provisions have been made fo r relieving explosions in process components, are the vents directed away from personnel and equipment locations? II. Location of Large Inventories Are large inventories of HHCs locate d away from the process area? Is temporary storage provided for raw materials and for finished products at appropriate locations? Are the inventories of HHCs held to a minimum? Where applicable, are reflux tanks, surge drums, and run-down tanks located in a way that avoids the concentration of large volumes of HHCs in any one area? Where applicable, has special consideration been given to the storage and transportation of explosives? Have the following been considered in the location of material handling areas: • Fire hazards? • Location relative to important buildings and off-site exposures? • Safety devices (e.g., sprinklers)? • Slope and drainage of the area?
76 Human Factors Handbook Further guidance on the management of job aids is given in the CCPS “Guidelines for Risk Based Pr ocess Safety” [5]. The United States’ Department of Energy guide “DOE-STD-1029-92 Writer's Gu ide for Technical Procedures” [36] is also useful. 7.7 Key learning points from this Chapter Key learning points include: • The content of job aids, including in structions, warnings and cautions, can be produced from task analysis , task walk-throughs and the results of HIRA. • Job aids should be developed with the engagement and involvement of front-line personnel who use the written guidance, if company human performance programs are to be sustained. • All job aids should be validated and kept up to date.
79 The steps for conducting an Inform ed Substitution process are as follows: 1.Form a team to develop a plan 2.Examine current chemical use 3.Identify alternatives 4.Assess and compare alternatives 5.Select a safer alternative 6.Pilot the alternative 7.Implement and evaluate the alternative There are a number of resources fo r researching alternatives to hazardous chemicals. These resource s include chemical substitution case studies and alte rnatives, including: •SUBSPORT - Substitution Support Portal – Moving Towards Safer Alternatives (www.subsport.eu/case-stories-database) •Intergovernmental Forum on Chemical Safety (IFCS) – Substitution and Alternatives Case Studies, Examples and Tools (www.who.int/ifcs/documents/sta ndingcommittee/substitution/ en/) •University of Massachusetts Lowell Toxics Use Reduction Institute (TURI) Case Studies (www.turi.org/TURI_Publications/Case_Studies) •ISTAS Risctox (in Spanish only) (www.istas.net/web/abreenlace.asp?idenlace=3911) •U.S. Environmental Protection Agency – Safer Chemical Ingredients List (www.epa.gov/sa ferchoice/safer-ingredients) Completed alternatives assessments (Interstate Chemicals Clearinghouse, www.theic2.org/aa- wiki-archive) are also included. Performing a single search of mu ltiple online resources related to substitution is another rapid way to identify possible alternatives. Guidance is also provided for asse ssing hazards, performance and cost (Ref 4.40 US OSHA). Comparati ve Assessment T ools include the following: •European Commission, Minimising Chemical Risk to Workers’ Health and Safety Through Substitution , 2012 •Ontario Toxics Reduction Program, Reference Tool for Assessing Safer Chemical Alternatives , 2012
68 Hydrofluoric acid (HF) has a number of industrial uses, including petroleum refining as an al kylation catalyst, detergent component manufacturing, metals processing, glass etching, organofluoride manufacture, semiconductor manufacturing, and uranium enrichment. Recent process developments have resulted in possible substitutes for liquid HF acid: oSolid HF catalysts have been demonstrated as a substitute for liquid HF alkylation processes. Alkylation units in petroleum refineries are used to produce high octane gasoline blending components that have no sulfur or aromatic content. One such process, currently under development, uses a liquid phase riser reactor with a solid catalyst similar in concept to a Fluidized Catalytic Cracking Unit (FCCU). The reactor operates at about 350 psia (24 bar) and refrigerated temperatures of 50-100°F (10 - 38°C). These operating conditions are similar to existing liquid HF Alkylation units, as are the feed input ratios (isobuta ne-to-olefin). Catalyst reactivation and regenerati on are key steps in these processes (Ref 4.21 McCarthy). oSolid bed HF catalysts are used in the production of linear alkylbenzenes, a material used in the generation of sulfonation compounds. These are components used in the manufacture of bi o-degradable detergents. oThe use of sulfuric acid as an alkylation catalyst in refineries, although less effici ent as a catalyst, presents a demonstrated opportunity for replacement of HF with a less hazardous alternative. Several refineries have performed this conversion as a way to reduce risk. HF often presents the potential for a large off-site (as well as on-site) impact in the event of a catastrophic release, whereas sulfuric acid norma lly presents a hazard to personnel in the immediate re lease area only, and as a liquid, is easier to contain. However, there is a risk transfer issue associated wi th using sulfuric acid in refinery alkylation units. Unlike HF alkylation units, where the HF acid can be regenerated and re-used, the
D Competency performance standards Table D-1 Competency standard s template – Skill-based task Task/sub-task knowledge & skills requirements Basic operational knowledge. Utilization of basic available information. Low new idea generation. Narrow range of knowledge. Established and familiar. Offer a clear choice of routine responses. Involve some prioritizing of tasks from known solutions. Competency standards 1. Monitor functioning of compressors & pumps. Take necessary action following Standard Procedures (SP). 2. Control (level & capacity) of materials to specification following SP. 3. Operate equipment as per job requirement following SP. 4. Maintain records to job requirement following SP. Safety criticality (High, Medium, Low) Medium Monitor process indicators & keep within safe operating limits. Share information about equipment faults or failures. Complexity of task (High, Medium, Low) Low Freq. of task (High, Medium, Low) Medium Time required to complete task (Long, Medium, Short) Medium Competency - Knowledge, Skills and Attitudes required Knowledge Function of equipment including safety devices. Interpret signs, signals, & symbols. Knowledge of safe operating limits, & process hazards. Procedural Establish procedures. Skills Alertness, communication, task planning, interpreting info, basic reading & writing. Human Factors Handbook For Process Plant Operations: Improving Process Safety and System Performance CCPS. © 2022 CCPS. Published 2022 The American Institute of Chemical Engineers.
25. Indicators of human performance 329 25.4.5 Observations of performance Observations of performance can also cont ribute to leading indicators. The focus of these observations may include: • Mistakes and Lapses: o Are individuals making frequent mi stakes/lapses? If so, is there a pattern in these mistakes/lap ses? Is there a common cause? • Task completion: o Are tasks being completed on time? Are they being completed effectively, or do they need to be redone or corrected? • Effectiveness of audits: o Do audits detect errors and om issions? For example, do they detect failure to tag lock outs? • Lessons learned: o Are lessons learned and applied? For example, have incident recommendations been implemented? 25.4.6 Signs of psychological safety and teamwork Psychological safety is an important indica tor of safety culture and allows for free, open discussion about human performance. Indicators of psychological safety include: • Open reporting of errors without fear of repercussion. • Conversations about lessons learned. • Discussions about potential error traps. • Challenging others (including superior s) on safety-related issues e.g., mistakes, incorrect commands. • Effective communication and informat ion sharing across business units. • Leaders tend to reserve judgment until all facts are obtained and not jump to conclusions, blame workers, and seek unwarranted disciplinary action. It should be noted that task safety observations conducted in the field by a small group of individuals (e.g., a mana ger, a supervisor, and the worker) often results in a psychologically safe environment in which the worker may freely escalate concerns. The reality of leakin g pipes, broken equipment, and faulty instrumentation are in clear view of the manager and/or supervisor when they are in the field together with the worker. Di rect engagement with the worker by the
5.1 Senior Leader Element Grouping |163 Contractor Management (Elem ent 11) Companies frequently use contractors in place of employees, for several reasons. Contractors can for example provide unique skills needed only occasionally and supplement staff during periods of high activity such as turnarounds. Contractor assignments m ay range from short assignm ents of hours or days to quite long-term . Contractors also provide professional services such as engineering, asset integrity inspections and expert consulting. Contractors may be exposed to the sam e process safety risks as em ployees, and in some cases the risks may be greater. Therefore, any process safety risk management activities should control the risk that contractors face to the same level as employees. However, preparing the contractors to work safely and within the framework of the facility’s PSMS can be com plicated. Often, the terms of the contract specify that the facility cannot manage or train contractors directly, to avoid co- employment issues. In such cases, the facility must instruct the m anagement of a contractors’ company about hazards and protection measures, and then the contractors’ management m ust instruct them . Similarly, providing corrective feedback may also have to go to the contractor through their m anagem ent. Finally, contractors sometimes use sub-contractors, and this adds to the management challenge. As challenging as managing contractors within the facility’s PSMS can be, aligning contractors with the facility’s culture can be m uch harder. Contractors arrive influenced by their own com pany’s culture and the cultures of other facilities at which they’ve worked. They are also usually motivated by business com mitments to provide services on a com petitive schedule and price, enhanced by a fear that failure to meet commitments could hinder repeat business. As discussed in section 2.9, this environment is quite conducive to norm alization of deviance.
DETERM INING ROOT CAUSES 215 10.4.1 Gather Evidence and List Facts The first task is to develop a list of all known facts. This list includes not only facts relating to the incident sequence, but also all pertinent background data, specifications, and recent past or external events that could or did have an influence on the overall system. A fact should be a true, proven piec e of data. Avoid drawing conclusions or making judgments at this stage. An example fact is— Hearing protection boundaries in the area are not marked . A conclusion may be that the boundaries are not clear, but do not make that jump yet. Sticking to the facts will help prevent people involved in the inciden t from becoming defensive and will prevent the team from jumping to conclusions. Sticking to the facts will also assist readers in understanding th e complete incident report. The team needs to take care to avoid being trapped by hidden or erroneous assumptions. All facts should be tested. The facts are essential inputs to ensure that the correct scenar io is selected later. Any apparently conflicting facts should be resolved throug h additional data gathering. Listing the source of each fact will facilitate conflict identification and resolution. 10.4.2 Timeline Development Next the team develops a chronology of events based on the available known times and sequences and prepares a timeline or sequence diagram. Unconfirmed assumptions regarding chronology should be clearly identified as unconfirmed, and action should be initiated to verify assumptions. Many investigators use relatively simple timelines (instead of sequence diagrams) with the logic tree methods because the logic tree itself shows the interactions of events and conditions. 10.4.3 Logic Tree Development After the initial facts have been listed and the initial timeline has been developed, the logic tree diagram can be cons tructed. The tree diagram is a dynamic document; it continues to expand and may even be rearranged as additional information becomes available or when new information changes the understanding of the original facts. Once the facts have been gather ed and the timeline developed, there may be sufficient information available to confirm or refute a hypothesis in the early stages of logic tree development. For many simple and straightforward failures, general knowledge of th e component failure mode
ACRON YM S YYYJ LNG Liquefied Natural Gas LOPA Layer of Protection Analysis LOPC Loss of Primary Containment LOTO Lockout/Tagout LSHH Level Sensor High High LT Level Transmitter MARS Major Accident Reporting System MAWP Maximum Allowa ble Working Pressure MCSOII Multiple-Cause, Systems-Oriented Incident*OWFTUJHBUJPO MES Multilinear Event Sequencing MHIDAS Major Hazard In cident Data System MI Mechanical Integrity MIC Methyl isocyanate MM Million MOC Management of Change MOM Singapore’s regulatory standard for incident JOWFTUJHBUJPO MORT Management Oversight Risk Tree MSDS Material Safety Data Sheet NAICS North American Indust ry Classification System NFPA National Fire Protection Association N 2 Nitrogen NOM Mexico’s regulatory standard for incident JOWFTUJHBUJPOT NTSB National Transportation Safety Board IOGP International Association of Oil and Gas Producers OREDA The Offshore Reliability Data project ORPS Occurrence Reporting and Processing System OSBL Outside Battery Limits OSHA United States Occupati onal Safety and Health "ENJOJTUSBUJPO P fatality Probability of Fatality Pignition Probability of Ignition Pperson present Probability of Person Present P Probability P& ID Piping and Instrumentation Diagram PCB Polychlorinated Biphenyl PFD Probability of Failure on Demand PHA Process Hazard Analysis PI Pressure Indicator LI Level Indicator LIC Level Indicator—Control
410 PROCESS SAFETY FOR ENGINEERS: AN INTRODUCTION Figure 19.6. OSHA QuickCard on permit-required confined spaces (OSHA)
282 safety measures have been verified before work begins. Additionally, the increasing practice of combining a ll safe work issues on one single permit form, i.e., basic job informatio n, authorization, and closure; hot work; confined space; equipment opening; lockout/tagout; PPE; vehicle entry; etc. has made these all-in-o ne permit forms very complicated. While this practice may reduce the number of separate permits required for a given job, it makes the all-pu rpose permit form very complex and more difficult to use. Finally, SWP permitting processes sh ould not be allowed to evolve into “check-the-box” activities. This can occur when complicated permits are used in a manner that does not give due consideration to each item on the permit and they are rapidly filled-out. This can sometimes be detected when each item is not indivi dually addressed, i.e., a line with a d o w n a r r o w i s u s e d t o q u i c k l y a n s w e r a l i s t o f q u e s t i o n s . I f t h e importance of having a completed pe rmit document seems to outweigh the thought process associated with carefully recognizing and addressing the hazards of each indivi dual job, then the permit processes may have become a “check-the-box” activity. Unfortunately, this may only become apparent when hazards are not addressed properly and incidents or near misses occur. 11.7 ASSET INTEGRITY AND RELIABILITY Asset integrity (sometimes referred to as Mechanical Integrity) includes a broad range of technical activities in a PSM/RBPS program, including: Identification of equipment to be included in the asset integrity program. Written maintenance procedures. Inspection, testing, and preventive maintenance (ITPM) programs Maintenance personnel training and qualification. Management of asset in tegrity deficiencies. Asset integrity quality assurance (QA), which involves the design, fabrication, and installation of the equipment, as well as the replacement of materials. Each of these sub-areas of asset in tegrity can involve consideration of the four IS strategies. For example, Substitution , Moderation , and
F.2 Culture Assessment Protocol |349 42. Are process safety perform ance and leadership significant considerations in career advancem ent and succession planning? 43. Has a com pany-level PSM S leader been designated? Is this designation m ade in writing and by title? Is this person technically com petent in PSM ? Does this person have sufficient positional authority to contribute m eaningfully to the most significant process safety related decisions, and has that authority been influential? 44. Has a facility-level PSM S leader been designated? Is this designation m ade in writing (e.g., job descriptions, organizational charts, etc.) and by title? Is this person technically com petent in process safety? Does this person have sufficient positional authority to contribute m eaningfully to the m ost significant PSMS-related decisions, and has that authority been influential? Note: This position can be either full tim e or part time, depending on the size of the com pany, the num ber of facilities included in the PSM S, and the applicability and com plexity of the com pany PSMS. 45. Are process safety issues identified dealt with by m anagem ent and not just "filed". 46. Have process safety culture surveys and/or assessments been conducted, and have actions or priorities resulting from the survey been resolved? Have the surveys/assessments resulted in changes to the process safety culture? 47. Are the same process safety issues raised at each m anagem ent meeting, but not resolved? Note: Management m eetings can consist of a variety of forums, from daily production meetings, maintenance m eetings, project m eetings, process safety m etrics, or other related meetings? 48. Does management resist taking responsibility for process safety concerns when they are faced with them ? 49. Does m anagement use em pty slogans regarding process safety repeatedly?
W ITNESS M ANAGEM ENT 117 A classic example of this “filtering” co ncept is the fable of four blind men who encounter an elephant as they walk down the ro ad together. Each blind man encounters a different part of the elephant and tries to communicate to his associates what he has found. The first man touches the trunk and believes they have met a boa constricto r. The second man grabs the tail and thinks it is a rope. A third who has en countered a leg begins to argue saying that both of his friends are wrong and th at the thing is a tree trunk. The last man, who has hit the side, insists they ha ve hit a wall of some sort. Each blind man was basing his conclusion on the information available combined with his previous experience. The entire pict ure is not accurately interpreted until the composite information is assimi lated. The task of the incident investigation team is to put these four stories together and realize that the men have encountered an elephant an d not a snake, rope, tree, or wall. Another natural human characteristic is to recall events, actions, observations, etc., out of chronologica l order. The human ‘replay’ mechanism does not function in order like a video pl ayer. This characteristic is one reason why retelling their account of what happened several times may help individuals remember additional details. Sometimes, witnesses may choose not to tell the complete story. A witness may have several motives for purposely modifying statements or choosing not to tell the incident investigation team all of the relevant information they have. The most signific ant of these influences is fear of punishment, either for themselves or a friend or colleague. When evaluating witness statements, the investigatio n team may need to consider the possibility that a statement given in an interview might be incomplete or modified. The strategies for dealing with fear of punishment are similar to those for encouraging the reporting of n e a r m i s s e s . T h e f o c u s o f t h e investigation is on fact finding, not fault-finding. Although some incidents may be a result of horseplay, negligence, or malicious/criminal acts of sabotage, these causes are, by far, the exception. Th e root causes of the vast majority of incidents are associ ated with management-system or organizational failings. This message should be clearly communicated to everyone involved in the investigation, particularly to the witnesses. It is important for witnesses to understand that th e purpose of the investigation is to determine the root causes of the in cident to prevent a similar occurrence. In cases that in volve a failure to follow safety or operational instructions, personnel may have thought that the rules are unnecessary, incorrect, or an inefficien t use of time and it was in the best interest of the individual and the organi zation to perform the task in another
5 • Facility Shutdowns 79 outdoors), the following preserva tion techniques may need to be considered [31, p. 25]: Periodically turning or rotating motors; Capping of open piping connec tions to partially installed equipment, vents to atmosphere, or flares; Maintaining nitrogen blankets; Coating or filling machinery with oil, and Using desiccants or biocides if necessary. In all cases, a multi-discipline project team, in cluding process safety and asset integrity experts f amiliar with the equipment’s design, should determine the appropriate preservation approaches. Further information and guidance on asset integrity of m othballed facilities is available elsewhere [23] [43]. Inadequate preparation and handover during these project shut-downs an d start-ups have led to incidents. 5.3.5 Effective contractor mana gement during the project Contractors are more likely to be in volved in facility shutdowns due to their technical expertise, construction-related skills, and broader experience base. For this reason, contractor management becomes much more crucial since there are more opportunities for essential information to be missed during the handover communications between groups. The contractors and their sub-contractors have a clear understanding of all process sa fety expectations, the safe work practices, and most importantly, th ey have the operational discipline to adhere to them. A case study show ing the successful application of a successful contractor-managing ap proach for major, complex facility shutdowns is provided in Section 5.6 [44]. Further information and guidance on contractor management is available elsewhere [14] [31]. When managing a facility shutdown, complex project-related issues that can adversely affect pr ocess safety can and do arise. The next section will cover the two facility shutdown transient operating
Table B.1. Generic Risk Matrix (R) 457
Anatomy of a P&ID Sheet 19 Whether to keep the design notes or not is another issue. Some companies believe that the intention of design notes is directing other designers during the design stage of a plant and that all of the design notes should be eliminated after issuing IFC version of P&IDs. However, other companies leave the design notes because they can be helpful during the operation of the plant when something needs to be changed and replaced with another design note. Also the deletion of each note – either the design note or the operator note – does not leave a clean space as the note number should be left so that the remaining note numbers still stand. Visual notes can be used in some circumstances. They can be the detail of construction for a complicated part. They are, however, are not usually placed on P&IDs. 3.6 Main Body of a P&ID On the main body of P&ID, the main elements that can be seen are “item identifiers, ” which will be discussed in the next chapter. There is always a debate about what needs to put on the main body of the P&ID. If the P&ID is a focal document in the process plant, do all the information provided by all groups need to be put on the P&ID? It is NOT easy to decide what and how things should be shown on P&IDs; this topic will be expanded more in Chapter 4. However, it should be mentioned that the amount of information shown on a P&ID can be problematic. Thus a P&ID is created “universal” for everyone involved in process plant. If the amount of information is not enough, the P&ID becomes useless. If the amount of information shown on P&ID is too much, the P&ID also becomes useless because of its illegibility. It is important to know that a P&ID will be used in the process plant during operation, including emer - gency situations. An operator should be able to grasp the information needed from a P&ID as quickly as possible. However, it is not always easy to gauge and find the sweet window for the amount of information that should be shown on a P&ID (Figure 3.9). There was a time that there was no single “footprint” of interlock system on P&IDs. Now, a lot of P&IDs show the interlock systems, too.Lack of information Legibility Congestion Figure 3.9 The amoun t of content on P&IDs.
58 | 5 Learning Models Gardner’s work has led many other educators to develop evaluation and teaching tools based on this framework. Typically categorized as following the Learning Styles Model, these tools help educators and trainers present lessons and communications in forms that best fit their students’ intelligences, in order to boost learning. Gardner’s theory of multiple intelligences was intended to be used primarily in box III (Check) of Figure 5.1. However, since learning and communication are opposite sides of the same coin, Gardner’s model should also be extremely useful for helping to refresh learning, a key feature needed in box IV of the model (Act). In all but the smallest companies, we can expect that all eight forms of intelligence—and therefore all eight learning styles—will exist among our leadership and workforce. It follows that to effectively drive learning about process safety across the company, we need to communicate using multiple styles. This will also help promote workforce involvement. 5.2.2 Career Architect® Model Lombardo and Eichinger have developed a model for individual learning and development in a corporate setting (Lombardo 2010) in which individuals partner with their managers (and possibly with mentors) to identify competencies they should develop and career hurdles they can overcome. The learning-and-development plan the employee and manager agree on focuses on providing the employee with on-the-job experiences in the areas where development is needed. During these experiences, about 70% of an employee’s learning comes from doing, 20% by interacting with and observing those around them, and only 10% from courses and reading. The model identifies 167 different competencies an employee may have to develop. For each, Lombardo describes a process to assess the need for development, then suggests means of learning from self-study, feedback, development in the current position, and development in a new position. The Career Architect® Model’s focus on a broad list of possible employee and company objectives links corporate goals in box I (Plan) and box II (Do) of Figure 5.1. The 167 potential development competencies represent an important use of metrics to guide where learning should take place. Use of metrics is a necessary feature of the new learning model that is the centerpiece of this book.
105 eliminated if the vaporizer which precedes it is equipped with a disengaging space, which duplicates the functionality of the catch pot (Ref 6.10 Kletz 2010). By incorporating the technique of reactive distillation, a process which uses a reaction step with subsequent distillation can be simplified by combining the reaction and primary separation steps into one vessel, si mplifying the design and eliminating several separate distillation columns. Not only is this design simpler, it also results in greatly reduced in-pro cess inventory (Minimization!), and involves less vessels, piping, and fl anges which can leak. An important consideration with reactive distillation is that it does make the process itself slightly more difficult to operate, however the tradeoff in reduction in risk more than offsets th is. See Figures 6.1 and 6.2. 6.2 ELIMINATING U NNECESSARY SPARES In many plants, spare pumps are prov ided as a standard design, without a proper analysis as to whether each installed spare is truly justified, based on the duty requirements. Non- installed spares are estimated to cost 5 to 6 times less than installe d spares, and eliminating unnecessary installed spares simplifies piping in stallation, and also may eliminate unnecessary contained volume in th e piping (an application of the “Minimize” technique. (Ref 6.10 Kletz 2010)
384 implemented early in the facility development, and have broad and wide-ranging impacts on the proc ess design. Tactical approaches, including the active and procedural categories of the hierarchy of controls, can be implemented late in the design process and are characterized by repetition and high costs associated with maintenance (Ref 14.9 Hendershot). Costs have to be evaluated on a holistic basis, and it has been proven that the life cycl e costs and risks may be reduced after implementing IS measures. Both the Contra Costa County and New Jersey programs explicitly include a consideration of economic feasibility as part of an IS evaluation. 14.3.2 Needed Tools Chapter 12 discusses a number of tools and approaches for evaluating different and potentially conflicting IS options and measures. Additional tools and approaches will be needed to support IS regulatory programs including those to support system atic IS reviews, and economic evaluation and performance evaluations. Systematic review methods . Methods for systematic IS reviews are needed to provide consistent and comparable IS evaluations within and across facilities. Such an approach provides greater assurance that dissimilar facilities will conduct reasonab ly equivalent IS evaluations, and that the results of those evalua tions will be understandable and acceptable to regulators and the public. Economic valuation methods . Since economic feasibility is a critical factor in identifying viable IS opportunities, better methods for estimating this variable would benefit both regulatory and voluntary IS programs. Methods to estimate the va lue of IS and to quantitatively assess whether a given process is “as inherently safe as is practicable” are currently unavailable or unproven. Though examples are increasingly available in the literat ure, case studies documenting the economic benefit of IS projects do not cover a wide array of industrial situations. Evaluation of performance . A constraint to regulation is the lack of consensus on appropriate IS metrics. Assuming that the regulation is performance-based, rather than spec ification-based, metrics should be developed to help provide consistenc y. It is difficult to measure the
198 PROCESS SAFETY FOR ENGINEERS: AN INTRODUCTION Distillation (see Figure 11.16), stripping, an d absorption frequently involve flammable materials; therefore, loss of containment can re sult in fires and explosions. High temperatures are used, especially in the reboilers, to drive the distillation/stripping; therefore, the thermal stability of the materials being handled should be understood. Loss of cooling to a reflux condenser can affect the composition of materi als in a distillation, which again leads to the need to understand the effect of composition on the thermal stability characteristics of the material being handled. The Concept Sciences expl osion in Chapter 7 is an example of a failure that led to a higher, and more hazardous, concentration than expected or intended. High levels of liquid in columns can lead to plugging of inte rnals, high pressure, and loss of containment. The Texas City explosion in Section 3.1 is an ex ample of this. Higher liquid loading on trays can result to damage to trays and result in more serious temperature upsets. An electrical power failure will stop all cooling water pumps but no t necessarily any fired heaters. Thus, heat continues to enter the process, but no cooling occurs. This is often the design basis for the largest flare case for a process. Packing material fires can occur where hydrocarbon residue that remains on column packing can self-ignite at elevated temperatur es when exposed to the atmosphere. Iron sulfide, which is pyrophoric, can form from sulfur found in crude oil. Corrosion of carbon steel components can settle on packing and can ignite when exposed to the air or oxygen (Ender and Mannan). Adsorption processes are exothermic. Carbon bed adsorbers are subject to fires due to this overheating. For certain classes of chemic als (e.g. organic sulfur compounds [mercaptans], ketones, aldehydes, and some organic acids) reaction or adsorption on the carbon surface is accompanied by release of a heat that may ca use hot spots in the carbon bed. Adsorption of high vapor concentrations of organic compounds also can create hot spots. If a flammable mixture of fuel and oxygen are present, the heat released by adsorption or reaction on the surface of the carbon may pose a fire hazard (e .g., a fire may start if the temperature reaches the autoignition temperature of the vapor and ox ygen is present to support ignition) (OSHA a and Naujokus). Figure 11.17 is a schematic of a carbon bed system, In Figure 11.17, the top bed is in absorption mode and the bottom bed is in recovery mode.
Evaluating Operating Experience Since the Prior PHA 83 the training and performance a ssurance systems are not being adequately resourced are warning signs. The previous PHA team’s judgments about the likelihood of human errors causing upsets and the probability that operators will fail to properly respond to indications and alarms may be overly optimistic, so the risk assessments need to be reviewed and Updated , as appropriate. If the affected number of nodes or scenarios is significant then a Redo may be justified. • Conduct of Operations. Are routine activities being reliably executed? Is good housekeeping being performed? Are signs, labels, and lighting being properly maintained? Any metrics that indicate a breakdown in operational discipline are warning signs. The previous PHA team’s judgments about the likelihood of upsets may be overly optimistic, so the risk assessments need to be reviewed and Updated , as appropriate. • Emergency Management. Is there a backlog of overdue tests or inspections of equipment relied upon to execute the emergency response plan or procedures? Are emergency drills or exercises overdue? Are tabletop exercises be ing postponed? Any metrics that indicate the emergency systems are not being adequately resourced are warning signs. The previous PHA team’s judgments about the mitigation of losses of primary containment may be overly optimistic, so the risk assessments need to be reviewed and Updated , as appropriate. Metrics can provide leading indicators of performance that are critical to a facility’s ability to determine if process safety incidents are likely to occur. The revalidation study leader should make a judgment as to whether any current performance gaps are being corrected or whether they will likely persist. The more widespread the performance gaps and the longer they are likely to persist, the more likely the Redo approach is needed to judge current risks accurately. 4.3 HOW OPERATING EXPERIENCE AFFECTS THE REVALIDATION A review of operating experience since the prior PHA revalidation should be completed as part of the assessment to determine whether a Redo or an Update will be the more appropriate approach fo r the upcoming revalidation. Chapter 5 will discuss making this revalidation a pproach selection in detail, but the operating experience review by itself can necessitate one approach over the other.
8. Format and design of job aids 81 Figure 8-2: An example grab card (Compiled by CCPS for this handbook.) Figure Note: This grab card is for managi ng gas leaks in a public gas pipe network where the gas leak may not be known at first. Therefore, it starts with identifying the gas leak and then makes reduces the likelihood of ignition sources (makes them “safe”).
Figure 6-3: Example of a formal safety critical task assessment Safety Critical Task index Hot oil furnace flame detector proof test (drawn from Step Change in Safety [30]) Major Accident Hazard scenarios Loss of containment of flammable gas Nature of tas k Maintenance Roles Instruments Task criticality overview How hazardous are the systems involved? 3 To what extent are ignition sources introducing during the task? 0 To what extent does the task involve changes to the operating configuration? 1 To what extent could incorrect performance of the task cause damage? 3 To what extent does the task involve defeating protection devices? 3 Total 10 Task and human error analysis Preconditions Interface with the control room to identify the test to take place Task/ error identifier Task Error guideword Error description Failure class MAH consequence of error Existing controls / recovery Training & competency Actions required 1.1 Liaise with the control room to and carry out risk assessment Wrong info Wrong info passed on Mistake No MAH Trips 1.2 Ensure test measuring equipment calibrated Operation omitted Use incorrectly calibrated equipment Lapse MAH fail to detect flame out Yearly calibration (adapted from [30])
348 Human Factors Handbook Figure 26-3: “New” Just Culture Process (adapted from [114] ) *Expectations: Expected conduct in line with Values and Behaviors, Code of Conduct, rules, policies, and procedures 8 871 2 3 4 5 6 71 2 3 4 5 6 Was the individual instructed / influenced to do this by the supervision or other figure of authority?Assess Interpret Behavior 2 1 Start Here The individual acted on the instructions or under the influence of an authority figure. Was the expectation clear? If there was a procedure was it clear, available, current and workable?The expectations were unclear or impractical. Did they understand what was required, and did they have the knowledge, experience, skills, physical capacity and resources to do it?The individual did not have the capability or the resources to meet the expectations. Did they intend to act with company expectations, but made a mistake?The individual made an unintentional error. Were they following custom-and-practice which was common among their peers?A custom-and-practice had developed among the team. Substitution test: Could another person with the same knowledge, skills & experience have done the same thing in the identical situation?The individual found themsleves in a difficult situation. Is there evidence to suggest they acted to help self or company to save time and effort?The individual acted to benefit themselves of the company. Is there evidence to suggest they intended to cause harm, damage or loss?This is a special case - always consult Huam Resources. It's not clear why this happened. You may need to investigate furtherYes Yes Yes Yes Yes YesNo NoYesNo Yes No No No No No
11.8 Embed and Refresh | 153 engaged. Posting the newsletter around the rig was a passive form of communication, but it took little time to do. The last part of the plan was probably the most fun for the crew—creating a safety slogan or jingle. The valuable prize for the winner was additional time off. When it was time to judge the entries, there were so many to choose from. Some were very straightforward: “If you don’t think it will happen to you, find the person who had it happen to them.” Others were catchier: “If you mess up, ‘fess up.” Some were downright morbid: “Arms work best when attached to the body.” Lucas also received some musical suggestions. Although none of the crew could carry a tune, many of them remembered the new wave hit “Safety Dance,” by Men Without Hats (Doroschuk, 1982). He also had a few people suggest a search on YouTube for safety songs. He had a good chuckle over a safety rap and decided he would suggest that Oliver occasionally play a YouTube video at the safety meetings instead of having someone read a newsletter out loud. Lucas was so pleased with the results that he decided to run the contest every quarter, but with a prize of a dinner for two, instead of time off. 11.8 Embed and Refresh A year later, the pilot was deemed successful. There was a positive change in the attitude of the crew and no impact on operational efficiency. Lucas said to Charlotte, “I’m glad you took the initiative to try to make change. Sometimes, it takes a fresh pair of eyes to bring in a new perspective.” “So…does that mean I’m getting promoted?” Charlotte joked. Lucas laughed and said, “Keep this up and you most certainly will be.” Charlotte smiled. “Now that a year has passed, it’s time to do the fatigue assessment. It’ll be easier this time since Oliver and Mason have bought into the value it brings,” she said. Lucas said, “True, but don’t rest on your laurels. We have to keep reminding people it’s important to operate safely.” Lucas then started to hum the new song he’d heard at the morning safety meeting—the winner of the latest safety jingle contest. “It’s been stuck in my head all morning,” he said. “Our crew is more musically talented than I thought!”
10 • Risk Based Process Safety Considerations 207 Table 10.2 Examples of good operationa l discipline for operations and maintenance. (Adapted from [49, p. Table 1]) Process Safety SystemRBPS Element Examples of Good Operational Discipline During Transient Operations Operating ProceduresResourcing the operating facility adequately during the transition time; writing safe start-up, shut-down, and emergency shut-down procedures, including defining safe operating limits during the transition times; following these safe operating procedures (e.g., do not exceed safe operating limits); maintaining procedures; ensuring shift-to-shift consistency; and reviewing and validating critical procedures Safe Work PracticesFollowing safe work procedures (e.g., permit to work; job safety analyses; hot work, electrical isolation, etc.). Training and Performance AssuranceDefining position qualifications for the start-up and shut-down times; testing for theoretical understanding during the transition times; qualifying through skills demonstration during the transition time; and scheduling essential refresher training Contractor ManagementUsing qualified contractors (e.g., to install equipment or to inspect and refurbish/maintain the safeguards) Maintain Process Integrity and ReliabilityAsset Integrity and ReliabilityEnsuring an effective Inspection, Testing and Preventive Maintenance (ITPM) program for all safeguards; resourcing maintenance teams adequately in preparation for planned or extended shutdowns; adhering to the scheduling planned maintenance on critical safeguards; using qualified personnel to inspect, test, and refurbish safeguards, as needed before start-ups or commissioningOperate Safe Processes
2.1 Establish and Imperative for Process Safety |27 The work to establish an im perative for process safety parallels any other culture change a com pany would wish to m ake. A clear organizational vision and mission should be established, ideally with input from the front line. The vision and m ission should be exciting, and be urgent enough to create excitem ent and motivation for the employees. At the same time, it should be achievable, so that it is not shrugged off as impossible. Finally, the vision and mission should have a long- term outlook, to assure everyone that the new process safety culture is here to stay. (Ref 2.3) Signs that an imperative for process safety have been established include: The organization is very attentive to safety and process safety. The organization can anticipate areas of potential failure and maintain resilient processes and systems that can survive upset and return to norm al operation despite challenges. (Ref 2.4) Operational aspects of process safety are integrated into operations, but corporate oversight for process safety is m aintains independence. This helps align process safety with operations, while helping avoid conflict of interest. Sm aller organizations with lim ited staff with m ultiple functions should think this through carefully (see also section 4.3 ethics). Process safety resources survive budget cuts during downturns. This does not mean that process safety budgets are never cut. However, the process safety com petency required to operate safely should not be com promised. Management praises process safety as a value to the com pany. The process safety organization has strengthened due to its perform ance and has gained influence in the decision-making process. • • • •
8. Format and design of job aids 83 Regarding color contrasts, some guidelines are: • Only use color where it helps to convey meaning; • White text on red, blue, green, brown or dark grey backgrounds; • Black on white, or yellow/amber or beige background, and vice versa; • Pink, purple and orange backgrounds have lower contrasts but are best paired with black, white and black text respectively. It is also possible to utilize tone variance with color variance, especially to cater for color blindness. For example, a saturated red and a soft green. Figure 8-4: An example of icon and color coding
218 INVESTIGATING PROCESS SAFETY INCIDENTS investigation proceeds to the recommendation stage. If a problem or some incompleteness is noted, then the iterative loop is reactivated. After the tree is developed, an d before moving on to the recommendations and deliberations, the team should ask, “Are there any other causes that anyone had in mind at the beginning of this meeting that are not included in the tree?” If additional causes are identified, the team adds them to the tree if there is logic to support them. Some team members may have specific concerns that the logic tree has not adequately resolved. This is the point at which remain ing issues are brought forward and addressed. It is important that any new causes also pass the necessary and sufficient testing. In the deductive process of identify ing root causes, known facts are assembled and used to develop and test one or more possible scenarios. The process normally requires multiple iterations of the cycle shown in Figure 10.4 until at least one plausible scenario is identified that fits all the known facts. If a scenario is disproved by the known accepted facts, the reasoning is documented and the scen ario need not be invest igated further. If the scenario needs additional data in order to be proven or disproved, then the iterative loop path is followed and additional inform ation is gathered. Sometimes this new information is very specific, precise, and limited in scope. Examples of tasks initiated by this iterative loop include: • Follow-up witness interviews, • Revisiting or reexamining a certai n area of the incident scene, and • Commissioning expert consultant opinions. If the deductive process continues to indi cate progress, then additional facts are sought or the logic tree is restru ctured. For example, one witness stated a particular valve was open, yet the post-incident inspection found it to be closed. The team must be careful to ensure that the valve is closed because of the actions taken prior to the incident, and not as a result of post- event response activities. The position of this particular valve may be a critical item in determining which of two scenarios is the more probable case. The incident investigation team would then initiate a short-term action item to resolve this question. If the deductive process has stall ed and no further progress seems possible or likely, then the iterative loop calls for application of inductive
23. Working with contractors 307 23.4 Key learning points from this Chapter Key learning points include: • Working with contractors can create additional Human Factors risks. • Risks of working with contractors should be included in task assessment and planning. • Time and resource should be applied to provide the support contractors’ need, especially where they are unfamiliar with the site, its hazards, and/or its safety procedures. • Specific actions, such as joint planning, mobilization and readiness reviews, can help ensure that contractors are effectively supported.
6 • Recovery 104 Figure 6.2 Transient operating modes associated with abnormal and emergency operations. (Adapted from [15]) This section continues with how abno rmal situations can be addressed (Section 6.4.2) and concludes with a description of how the operations group can respond to expected deviations with a successful recovery (Section 6.4.3). 6.4.1 Recovering from an abnormal situation Recovery actions for abnormal situ ations in both continuous and batch operations are the operating group’s response efforts to keep the process under control—to recover from the abnormal situation. During the normal operation, the proc ess is operating within its safe limits for both steady-state cont inuous and unsteady-state batch
358 | Appendix F Process Safety Culture Assessment Protocol before it is m ade. Establishing an MOC program only to com ply with a regulation and leave a paper trail for each change does not fulfill the real purpose and intent of MOC. This is a form of com placency. Understand and Act Upon Hazards/Risks 126. Does the organization know what standards govern the design, construction, m aintenance, operations, and m aintenance of its facilities? As with the boundaries, scope, and philosophy of application of the PSMS itself, has the organization taken a m inim alist view of which recognized and generally accepted good engineering practices (RAGAGEP) applicable to the organization? 127. Does the organization follow its own procedures or does it regard them as not m andatory? 128. Are hazard/risk assessments performed consistently for engineering or operating changes that potentially introduce additional risks? Who decides if a risk assessment should be perform ed? What is the basis for not performing a risk assessment? 129. How are risks for low frequency – high consequence events judged? Is there a strong reliance on the observation that serious incidents have not occurred previously, so they are unlikely to occur in the future? What is the basis for deem ing risks acceptable – particularly those associated with high consequence events? 130. Are the appropriate resources applied to the hazard/risk assessment process? 131. During HIRAs/PHAs are hazard scenario or type of hazard not included in study because it is bad news and will obligate m anagem ent to do something tangible to reduce the risk, i.e., it will create a liability for management to spend resources to m ake the necessary changes to reduce the risk? 132. Do HIRA/PHA teams intentionally avoid m aking recomm endations by applying risk rankings, IPL credits, or
OPERATING PROCEDURES, SAFE WORK PRACTICES, 405 CONDUCT OF OPERATIONS, AND OPERATIONAL DISCIPLINE performance targets. The proc ess parameter readings and evaluation portion of operating discipline and engineering discipline are closely related. Engineers should define what operators need to evaluate and define how th e evaluation is made. Operators or engineers should be thinking about what the process para meter readings mean, not just recording them by rote. When the criteria are not met, the op erator makes decisions (or informs supervision to receive instructions) to take actions to retu rn the process to the predetermined values. For example, if a pump should have a certain discharg e pressure to maintain a safe operating limit, that range is defined by the engineer and included on the evaluation sheet. If the range is exceeded, the operator notes the exceedance an d notes on the evaluation sheet what is done to return to normal. The engineer (or unit supervis ion) then closes the loop by shift/daily review of the evaluation sheets to ensure thes e concerns are adequately addressed. One of the most common failures in conduct of operations is to have ineffective process evaluation sheets that have operators simply “taking readings” without evaluating the equipment. When this happens, the value of understanding how the process is performing and the opportunity to identify potential up sets before they happen, can be missed. Good practice for operator evaluation is to include both outside operator evaluations and board operator evaluations. Since data from th e DCS can be printed or stored, it is often assumed that operators do not need to collect or write down that information. However, the purpose of writing the information down isn’t to collect it for someone else. The purpose is for the board operator to evaluate that variable or parameter and take pre-determined action if the expected value isn’t observed. Suggestions on how to create an effective process readings and evaluation sheet are included in Appendix F. Process Indicators. Engineers should identify process indicators used to track process safety, environmental, reliability, and economic optimization and have a defined schedule of review and action taken. Documentation on th ese indicators should include the operating range, steps to correct the situation if out of ra nge, who is responsible to monitor the indicator and at what frequency. Safe operating limits are an example of a process indicator. (Refer to Section 10.5.) Sample Collection. The process sample schedule should be defined by the engineers, documented, and be part of standard operating procedure. A good practice is to develop a process map of defined sample points to optimi ze the round. PPE and other safety precautions are identified for each sample point. The schedule should include: the sample point, frequency, technical analysis and target ranges, and action s to take if the sample is out of range. Operator Line-Up. The most fundamental responsibility of an operator is to understand and know the position of every valve in their area of responsibility and to control the energy among all points of material transfer. This resp onsibility is commonly referred to as “line-up.” While engineers usually don’t operate or “line-up ” equipment, they should clearly understand this aspect of an operator’s job and take it into account when designing equipment, developing operating procedures, and conducting operator training. Practical activities to support consistency in operations and minimize line-up errors, collectively called “walk the line” are discusse d in two papers by J. Forest. (Forest 2014 and Forest 2018)
Piping and Instrumentation Diagram Development 366 piping system. Steam hammering is a phenomenon that may happen in steam–condensate two‐phase flows where the steam carries the pockets of condensate and smashes them into pipe obstacles like elbows, partially open valves, etc. and damage them. This concern can be solved by placing steam trap on pipes with a chance of receiving steam–condensate mixed fluids. This stream trap prevents steam from pass - ing. As steam traps are available only up to certain sizes (say up to 6″), if the pipe is large enough, instead of a steam trap, a small steam–condensate vessel with level control could be placed. The generated condensate along the length of a steam carrying pipe should be removed from the steam as soon as possible. Therefore steam traps are placed along the route of the steam transferring pipes at certain intervals and the steam pipe should be installed so that they slope toward the steam traps. The steam trap inter - val is case specific and depends on several factors including pipe size, the effectiveness of pipe insulation, and the difference between steam temperature and ambient temperature. Steam traps are connected to the steam pipes through a device named a drip leg. Wherever we need to put drip leg, it should be from the bottom of the steam pipe. The detail of drip legs are not always shown on main P&IDs. If the detail of drip legs is not on the main P&IDs they could be on auxiliary drawings or even in piping documents. After all these consideration there could still be some condensate in the steam pipes. To avoid directing the generated condensate to the steam branches, all the steam branches should be taken from the top of the steam header. This can be covered as a note in P&IDs. As the bad reputation of valves in steam services is widespread, care should be taken to use suitable valves. 17.7 Condensate Collection Network The condensate collection network is the mating system for the steam distribution network. The condensate col-lection network collects the generated condensate from intentional and/or unintentional conversion of steam. This conversion happens because of heat transfer. The heat transfer could be intentional in steam heaters or unintentional in steam transfer pipes. As there are generally three types of steams: low pres - sure, medium pressure, and high pressure, there could be three corresponding condensate collection systems, including low pressure condensate, medium pressure condensate, and high pressure condensate. 17.8 Fuel as Utility Fuels are needed wherever there are burners in the plant. Burners can be used in different pieces of equipment including furnaces, boilers, some HVAC equipment, and others. Burners are a piece of equipment that has the duty of generating a flame and also maintaining it. Fuels could be gas, liquid, or solid form.A famous solid fuel is coal. If the usage of coal is justi- fied it is generally used in a way such that distribution of it is not necessary. Therefore, there is no such thing as coal distribution system in an extended scope. Here we cover two main types of fuel: fuel gas and fuel oil.Generally speaking fuel gas is the preferred fuel for burners rather than fuel oil or coal. 17.8.1 Fuel O il Fuel oil is another option as fuel in burners. Fuel oil is less favorable than fuel gas for burning. 17.8.2 Fuel G as Gas burners need to be supplied by streams of fuel gas and air. In some plants, there is one network to distribute natural gas both for blanketing purposes and as fuel gas (if natural gas is used as fuel gas). However, in some other plants there are two separate networks: one for blanket - ing gas distribution and the other for fuel gas distribu-tion. This could be because the blanketing gas specifications required by the client could be different from the fuel gas specifications. For example, in some Table 17.5 Some t ypical utility users in process plants. Steam type Pressure Temperature Applications LPS (low pressure steam)100–200 K Pag 120–135 °C In utility stations, In heat exchangers (steam heaters) MPS(medium pressure steam)1000–2700 K Pag 185–230 °C In heat exchangers (steam heaters) HPS(high pressure steam)>4000 K Pag >250 °C In steam turbines, as process steam
PREPARING THE FINAL REPORT 305 Table 13.2 Findings, Causal Factors, Root Causes and Recommendations Finding Causal Factors Root Causes Recommendations W ho By Waste product streams flowing from multiple process units to the power house holding tank were chemically incompatible. An exothermic reaction started in the waste material holding tank resulting in overpressure of the tank. The waste material holding tank was originally designed as a storage tank. It was not designed with cooling or pressure relief for a chemical reaction. Management of Change (MOC) procedure was not correctly followed when additional waste streams were supplied to the tank Staff carrying out the modifications did not remember to follow the MOC procedure 1. Review the MOC procedure to ensure it complies with corporate practices and requirements. Mike Feb 2. Issue safety bulletin to demonstrate the need to follow MOC procedure. Ben Mar 3. Include a training pack on MOC procedure with the annual safety refresher training. Sue Jul The chemistries of the processes that send chemicals to the holding tank have changed in the 30 years since the power house process was modified allowing waste products to be used as a supplementary fuel supply to the boiler. No control of the waste materials being sent to the power house by various process units. Failure of management and staff to recognize the risks associated with uncontrolled mixing of waste chemicals No PHA assessments carried out on the mixed waste streams from the processes 4. Conduct a PHA assessment of all waste and intermediate streams where mixing of chemicals can occur. 5. PHA on boiler fuel waste to be completed before restart of waste stream Bob Dec PHAs have not been conducted on the process for over 10 years. No program for redo of PHAs on the power house 6. Review scope of PHA program to include power house and to ensure that all services areas are included. Ted Dec Warm weather on the day of the incident likely escalated the reaction rate. Failure of management and staff to recognize the risks associated with higher ambient temperatures 7. Ensure that PHA scope includes consideration of ambient temperatures up to 50 °C. Dan Dec
INCIDENT IN VESTIGATION TEAM 99 example, the manager of a facility might lead an investigation, but the cause of the incident may be associated wi th management system problems for which the manager is responsible. Under these circumstances, the peer and senior management review should provide independent oversight and a path to further action, if required. Often, the investigation team leader’s first task is to systematically identify the resource requiremen ts and recommend individuals and organizations that should participate. As with management’s selection of the team leader, the leader’s selection of the team members will be based on the severity and nature of the incident. The team leader may choose to involve experts on an as-needed basis, allowing them to focus on key areas without affecting their normal work schedule. These experts may be internal to the organization or be contracted from an outside source. Part-time and expert participation should be carefully ma naged to ensure the scope is defined and adhered to, competing prioriti es are considered, and costs are controlled. The organization’s in cident investigation ma nagement system should specify the team leader’s responsibilities and authority. Once selected, the team leader should meet with senior management to review and agree on all responsibilities and authority (e.g., selection of team members, financial and technical resources) associated with the investigation, which should then be clearly documented. Typical leader responsibilities may include: • Ensuring incident investigation activities adhere to company, site, and scene safety practices • Ensuring that restricted access zo nes are identified and access is controlled • Ensuring that evi dence is preserved • Ensuring that the investigation team activities result in minimum disruption to the rest of the facility • Directing and managing the team in its investigation, setting priorities, and ensuring the objectives and schedules are met • Serving as principal spokesperson for the team and point of contact with other organizations and interested parties, including government agencies • Preparing status reports and ot her interim reports documenting significant team activities , findings, and concerns • Keeping upper management advised of status, progress, and plans • Organizing team work including schedule, plans, and meetings • Assigning tasks to team members in accordance with their individual skills, knowledge, capabilities, and experience
16. Task planning and error assessment 187 16.5 Key learning points from this Chapter Key learning points include: • It is possible to foresee error-likely tasks and situations. • The potential for error-likely situations and error should be foreseen, as far as possible, during planning tasks, and when creating work instructions and Permits to Work. • Work instructions should include mitigation for potential error-likely situations.
290 • Are equipment designed such that they cannot be operated incorrectly or carried out incorrectly, e.g., are valve operators on quarter-turn manual valves configured so that when th e valve operator is in-line with the flow direction the valve is open and when the valve operator is perpendicular to the flow direction the valve is closed? • Have DCS and other control panels been designed following well-known conventions for displays, colors, and other characteristics th at will make operations intuitive and easy-to-understand and therefore reduce human error? • Have DCS and other control panels been evaluated with respect to alarm management principles and conventions? • Can rotating equipment and other machinery be stopped locally and from central control rooms or locations? • Have other design and op erational conventions been followed so as to obviate human errors? • Has the opportunity to simplify procedures associated with the process, particularly emergency procedures, been evaluated to simplify the procedures, even if the ch ange was proposed for a different reason? 11.11 CONDUCT OF OPERATIONS / OPERATING PROCEDURES Conduct of Operations (COO) is a PS M/RBPS element that covers a broad range of process safety program activi ties. It is a very important aspect of process safety as this is elem ent of the program where operating
INVESTIGATION M ANAGEM ENT SYSTEM 57 questions that are premature or outside the scope of their knowledge or experience. The government agency will seek to interview employees. Unless subpoenaed to testify, employees ma y not be required to submit to interviews. Moreover, employees are entitled to have counsel, either company counsel or their own, present during agency interviews. The company should inform employees of these rights in a factual way that does not obstruct the government ’s investigative process. Consider involving legal counsel in these situations. In addition to conducting interviews, the government agency may also seek documents and physical evidence. Withou t a warrant, government investigators may or may not be authorized to take documents. Consider involving legal counsel when the govern mental agency requests documents. Generally, a facility should allow reviewing and copying those documents that the facility is required to keep and make available to the agency. Such documents may include copies of process hazard analyses, p r io r incidents, and prior compliance audits. Requ ests for other documents should be accepted in writing and considered by management and counsel. Procedures should be implemented to track an y documents supplied to an agency. Many chemical processing facilities use nonproprietary technologies that present common hazards. This allows for meaningful sharing of incident investigation findings throughout the industry. The management system should address methods for sharing incident causes and lessons learned through appropriate channels so that others can benefit. It is often a challenge for a company’s managem ent to share the details of investigations due to litigation concerns. However, when similar facilities might benefit, finding a way to share di splays a company’s interest in driving improved industry safety performance. In addition to litigation issues, practical logistics sometimes make it difficult to communicate lessons learned within and between companies. Determining which people or companies have a potential interest in the incident and learnings can sometimes be problematic. Despite these challenges, broad communication of investigation findings is a recognized good practice.
132 GUIDELINES FOR MANAGING ABNORMAL SITUATIONS The third most common failure was the lack of understanding the i m p a c t o r e f f e c t o f a p r o c e d u r a l a c t i o n o r f a i l u r e t o e x e c u t e a procedural action. In total, these top three failur es account for 35 of the 40 (87.5%) procedural execution failures under abnormal situations. [ASM® Guideline, Effective Procedural Practices ] (ASM® Consortium - Bullemer, Hajdukiewicz & Burns 2010). Typical tools and methods for eval uating the content and accuracy of process procedures are similar to HIRA tools: HAZOP, What-Ifs, and Checklists. An effective approach is to cond uct a procedure observation audit that involves an observer following along with the procedure as the operator conducts the work. The ob server ensures that the steps are followed in order and highlights where any steps are missed, or identifies confusing items. Another a pproach is to ask a newer operator to do this task following the step s in the procedure (highlighting any missing or confusing items that are encountered). Ensuring that operator technician s follow the most current approved procedure can be a challenge. Prin ted procedures can quickly become uncontrolled copies that are outdated or damaged in use (e.g., spills, tears, missing pages). Electronic copi es of procedures can be difficult to access quickly in an emergency, espe cially if a power or computer network outage occurs. Thus, a suitab le balance has to be struck and procedure control management pr actices must be established, communicated to personnel, and adhe red to ensure that up to date procedures are followed. 5.5.2 Emergency Procedures Responding to emergency conditions requires planning and training. Identifying the normally anticipate d types of initiating causes for emergencies such as chemical leaks, fi res, loss of a critical utility supply, on-site transportation events, or natural weather events are often already in place across most of the chemical industry. Emergency procedures for unusual, infrequent, or near impossible events, however, are not as easy to develop. Theref ore, identifying in advance possible abnormal situations that may requ ire an emergency response should start with the HIRA studies of the process plant and associated utility
Conducting PHA Revalidation Meetings 137 Typically, for a human factors checklist Update , these discussions include asking questions such as: • Are housekeeping and the general work environment the same or have they been improved? • Have there been any changes in the accessibility and availability of controls and equipment? • Is the equipment labeling still accurate and well maintained? • Have there been any changes in th e feedback/displays of controls? • Have there been any changes in personnel workload/stress (e.g., due to changes in staffing levels, experience or competency, assignment of new duties)? • Have the procedures been updated to reflect changes, and have they been field validated? • Have workers been trained on changes, and is refresher training up to date? Using both Redo and Update approaches is conceivable for complementary analyses that span the PHAs for multiple units. For example, a comprehensive facility siting study might have to be Redone for one particular unit and Updated for all the others. In that case, the expe rts may solicit more specific scenario information from the core revalidation te am, but the conduct of the revalidation is essentially the same as an Update. 7.1.3 Revalidation of Supplemen tal Risk Assessments The core analysis of any PHA includes at least a qualitative risk assessment. The mere fact that the PHA team made any recommendation implies that they concluded the “as found” risk exceeded the organization’s tolerance or that there were other opportunities for impro vement. However, past judgments have proven to be highly subjective, depending on the individual team members’ personal knowledge, experience, and interests. Thus, many organizations now require that their PHAs include quanti tative risk analyses that are more consistent within a particular study, acro ss all their PHAs, and across the entire organization. Often, only an order-of-magnitude risk analysis is required to align the PHA team’s risk judgments with the organization’s risk tolerance as expressed in its order-of-magnitude risk matrix. These simplified quantitative risk analyses, such as LOPA, follow a conservative set of simple rules that are standardized across the organization.
INVESTIGATION M ANAGEM ENT SYSTEM 69 Leader training deserves special attention. Training for leaders could include role-playing for witness interv iews, conflict resolution, applicable laws, regulator powers, and confidentiality issues. They should feel free to request help or training when needed, especially at the early stages of an investigation. Other investigators ma y handle low to moderate complexity incidents. Leader training fo r lo w to m o derate co m plexity incid ents usually consists of classroom training plus expe rienced coaching during their first few investigations. These individuals can also benefit from participating as team members on an incident investigation led by an experienced leader. Low complexity in cidents may require one helper (team member) to support the leader in data gathering and analysis. Individuals who will lead major or complex investigations should be able to handle almost any incident within the company. The training for this level usually consists of considerable experience leading low to moderate complexity incidents and additional classroom training an d coaching by a more experienced investigator during their first few major investigations. In some cases, employees, rather th an supervisors, lead investigations for lower level incidents. Companies have found it beneficial for employees to feel ownership of the investigation results. This philosophy helps encourage workers to report more near -misses by reducing the fear caused when a supervisor leads the investigation. Most incidents are low complexity. Many of these are near-misses and benefit from investigation by persons who are closest to the process. Chapter 6 provides details on the selection, and organization of incident investigation teams. 4.2.7 Emphasizing Root Causes Identifying causes is a major objective of the investigation process, and this should be specified in the management system. Initial selection ( or custom development) of the root cause determination process will require special attention to the concept of multiple causes and to underlying system- related causes. The approa ch should emphasize find ing management system weaknesses and failures versus placing blame on individuals. Some employees may need to adjust to this approach, partic ularly if past methods did not encourage discovery of causal factors and associat ed root causes. Everyone involved in the resolution process for recommendations needs to understand the concept of multiple root causes of an incident.
Plant Interlocks and Alarms 349 TAH TAL TALLTLA 125 TLA 125 TLA 124 TL PAH PALPC 131 PAH 131PAL 131PAHH 153 PI IH L153 PT 151PC 131 PT 131123TE 124TT 124TAH 124TAL 124TALL 124 Figure 16.26 Some e xample of alarm systems on a P&ID.
334 | Appendix E Process Safety Culture Case Histories empowered the hauler and the well owner to make this verification. However, where does em powerm ent end and become abdication of responsibility, a culture negative? Did that happen in this case? The crude and inconsistent methods of determ ining the B S& W to hydrocarbon interface was prevalent throughout the industry. This suggests that hydrocarbon could be present in many such B S& W pum p-outs. If som e in the industry considered this to be a hazard and others did not, were there barriers to openly and frankly communicating this concern? Were there barriers to learning and advancing the culture ? How did the transfer of safety responsibility between the three com panies involved in the operation create other opportunities to weaken safety culture? Maintain a Sense of Vulnerability, Understand and Act Upon Hazards/Risks, Ensure Open and Frank Communications. E.42 Blindness to Chem ical Reactive Hazards Outside the Chem ical Industry A plastics extrusion plant suffered a m ultiple fatality incident when workers were attempting to open a waste plastic tank to clean it. The vessel pressure gauge showed no pressure in the vessel, but the gauge had become blocked with plastic and did not show the actual pressure in the vessel. After half the bolts fastening the vessel cover had been removed, the cover flew off, killing the three workers. The cover also severed hot oil lines, leading to a fire that took several hours to extinguish. Investigators (Ref E.9) discovered that the plastic had a reactive chem ical hazard, an exotherm ic decom position reaction at hot temperatures. As the plastic in the catch tank cooled on the outside, the plastic in the center rem ained hot and m olten, allowing the decom position reaction to continue to build pressure, while the solid plastic outer shell shielded the pressure gauge from detecting the high pressure in the tank. Actual Case History
Conducting PHA Revalidation Meetings 153 • Trying to force an Update of the PHA when a Redo is necessary. Updating a poor PHA can result in a poor revalidation product, without saving time or resources o The best course of action after making this revelation during the PHA sessions is usually to reconvene the team after the study leader has prepared for a Redo • Failing to consider the accuracy of previous PHA entries during an Update. This can allow errors to perpetuate in a PHA • Underestimating the meeting time requirements prior to the sessions, and therefore not having enough calendar or meeting time scheduled for the revalidation • Failing to perform the core methodology appropriately. For example: o Not considering causes if they originated in equipment or processes beyond the physical boundaries of the PHA being evaluated or taking credit for safeguards when evaluating consequences o Claiming invalid or ineffective safeguards or rejecting plausible scenarios as non-credible (i.e., "that has never happened here") o Using the same safeguards repeatedly without any real thought as to their effectivene ss or specific application to a scenario (e.g., overuse of “Operator Training and Knowledge”) o Failing to detect common cause failure mode issues between process control and safety/emergency shutdown systems o Inconsistently ranking the risk or consequence severity of similar scenarios o Being overly optimistic in estimating consequences or likelihood, resulting in an underestimation of risk • Failing to address facility siting, hum an factors, external events, or other required topics (typically as a complementary analysis) • Making recommendations that are either too vague or impractical to implement
84 | 3 Leadership for Process Safety Culture Within the Organizational Structure Leaders should understand that process safety culture is fragile. It can go from good to bad relatively quickly, but it will take a lot longer to reverse that trend. It takes years to create a positive PS culture, but only a few errant minutes to decimate it. Influence and Inspire Great process safety leaders have the ability to positively influence their subordinates’, peers’ and even superiors’ behavior and work practices and inspire them to do the right thing. They earn the respect of those that they lead by both word and deed and this respect is not based on fear. Those with responsibilities in the PSM S will work hard to avoid disappointing leaders they respect. Although others may exhibit leadership behaviors and assume a leadership role in the PSMS, facility managers are in fact leaders of the PSMS. Therefore, more than others, facility m anagers should strive to be great process safety leaders. Good leaders serve as role models to the subordinates or their colleagues. To be most effective as PS leaders, people need to be capable of influencing up, down, and across the organization. Act as Change Agents Process safety leaders should be change agents, developing strategy for developing the process safety culture, and then improving and sustaining it. When selected, they volunteer, or they m ake them selves known simply by setting a positive exam ple with their conduct. They should know the organization’s process safety culture strategy and the rationale behind it. They should be the primary communicators of the strategy, shepherding it through the organization to successfully implement and sustain it (Ref 3.17). Perhaps the most im portant leadership skill is to make the business case for process safety. This entails understanding risk at the operations level and being proficient at com m unicating that
APPLICATION OF PROCESS SAFETY TO ONSHORE PRODUCTION 97 shell to weaken and fail catastrophically . The NFPA has been active in alerting firefighters to this potential and of appropriate response measures. In upstream facilities it is common to install water sprinklers on pressure vessels that hold large inventories. The aim is to keep the vessel shell cool until a fire is extinguished. This protects against BLEVE events. Key Process Safety Measure(s) Process Knowledge Management : As in the Lac Megantic incident, it is important to understand the properties of the materials being handled and use the correct metallurgy for the equipment, piping and other accessories. Conduct of Operations : While both the Buncefield UK and Jaipur India incidents were noteworthy, they both started with a tank overfill. Paying attention to operations and conducting them appropriat ely each and every time helps to prevent significant incidents. Also, as in Buncefie ld, when a critical instrument (here a level gauge) signals a problem, this should be addressed. 5.2.4 Loss of Well Control Risks There are several activities during the production phase that can result in a loss of well control. These are primarily interventions and workovers to maintain or enhance reservoir production. Refer to Chapter 4 for discussions on these topics. A potential cause for loss of well control, onshore or offshore, is a wellhead mechanical impact or corrosion failure that allows well fluids to escape. The barriers protecting against this event are bollards, the Christmas tree installed on the wellhead, and a subsurface safety valv e (SSSV) where one is installed. Another production activity that can result in a loss of well control is associated with gas or water lift activities. These production enhancement procedures involve sending gas or water into the annular space and then injec ting this into the production tubing near the bottom of the well. A loss of hydraulic head or gas pressure, for example due to surface line da mage near the well head, can result in reverse flow up the annular space and a lo ss of containment event. The Christmas tree valve is designed and installed to close off this reverse flow potential. Subsurface safety valves, if installed, a pply to the production tubing and not the annular space, and they are not a barrier fo r this event. For the subsurface safety valve to be effective in a gas lift operation it must be set below all the gas lift injection points in the tubing. This is seldom practical. Key Process Safety Measure(s) Asset Integrity and Reliability : Arranging and protecting wellhead equipment to minimize the likelihood of mechanical impact aids in preventing loss of well control. Inspecting for and addressing any corrosion issues through a corrosion control management system reduces the likelihood of these events resulting from corrosion failures.
5 • Facility Shutdowns 80 modes: preparing for a facility project-related shutdown (Section 5.4) and starting up afterward (Section 5.5). 5.4 Preparing for a facility project-related shutdown The shut-down for a facility shutdown—transient operating mode Type 5, Table 1.1—is another transi ent operating time that requires non-routine procedures in ad dition to the normal shut-down procedures when stopping the proc ess equipment. Facility shutdown projects are complex, involve man y different groups, and have work- related timelines for weeks or even months, including the preparation time beforehand and the executio n time during the project. The additional time for a facility shutdo wn was illustrated in Figure 4.3. Personnel in the operations and maintenance groups typically have additional, sometimes specifical ly, project-related procedures for the steps used to prepare the proc ess equipment for the extended period. These additional administrat ive controls, including Safe Work Practices (SWP), help reduce the li kelihood of personnel exposure to any hazardous materials and ener gies when they are adequately written, understood, and followed [14] [21] [37]. Facility shutdowns typically take more time than a process shutdown due to these additional administrative controls for shutting the equipment down, preparing the equipment, working on or maintain the preservation procedures, and then preparing the equipment for handover back to the operating group. Since these additional procedur es may not be performed very often, it is essential that everyone involved in a facility shutdown understands what the different steps are, has the operational discipline to follow these steps, an d can quickly recognize and respond properly when things are not goin g as planned. When hazards have
CASE STUDIES/LESSONS LEARNED 185 7.2.2 Incident Overview – Texaco Milford Haven This case study concerns the release and ignition of flammable liquid and vapor hydrocarbons from a failed 30 -inch (0.76m) flare knockout drum outlet pipe. From the initial electrical disturbances that started at about 07:20 due to a thunderstorm, to the failure of th e pipe at 13:23 and its ignition some 20 seconds later, there we re a number of failed opportunities by operating staff to recognize an escalating problem on the facility and take appropriate action. However, operators were handling many issues at the facility and were focused on keeping the Fluidized Catalytic Cracker Unit (FCCU) from shutting down. At one stage, an outlet valve from a distillation column closed and failed to re-open, but the feed to the column continued until the level was well above normal. As the column level began to build, the pressure increased and relief valves op ened, carrying liquid and vapors into the flare line. Problems with high liquid levels elsewhere on the unit led to further demands on the flare system, including the use of hoses to drain hydrocarbons from one vessel and into another. Faulty and unreliable instrumentation made it difficult for operators to establish what was going on. The DCS pr oduced hundreds of alarms, all with the same level of priority but with no overview screen that would have provided operators with an indication of discrepancies on the mass- balance. A modification made several years before meant that an automatic pump-out facility for the flare knockout drum was not lined up for service. Previous inspection of the flare line ha d showed that it was thinning and it was due for replacement in the next major turnaround in the following year. However, the thickness measurements did not include the point of failure, which would have indicated that the dr um was in a far worse condition than the areas that had been measured. Venting of hydrocarbon liquid and vapors continued from several sources until the flare knockout drum was overfilled and large volumes of liquid were carried down the 30-inch piping. It failed at 13:23 at the weakened 90° elbow, the second bend downstream of the knockout drum. Up to 20 tonnes (44,000 lbs) of hydroc arbons released and ignited some 20 seconds later.
Manual Valves and Automatic Valves 115 decide to arbitrarily pick a failure position, such as FC or FO (which are cheaper than FL), and assign it to the automatic valve. However, some clients ask the practi­tioner to use a second decision tool if safety does not dictate a failure position. In such cases, the second decision tool (equipment protection) can be used and then followed by process smoothness if needed. This means that if safety does not dictate the failure posi­tion of the valve, the designer should check what the best failure position of the valve would be to best prot ect the equipment. A good example of deciding where to locate failure positions based on equipment protection is to make a control valve on a minimum flow line on a set of centrifu­gal pumps, all of which are FO. In this case, the decision is made not based on safety, but to protect the pump. Whether this valve is FO or FC does not impact the safety of the plant; however, if it is FC, it will impact the integrity of the equipment or pump. This means that if the valve is FC and instrument air is lost, then the minimum f low line of the pump will be blocked and the pump will not be protected against low‐flow cases and may be damaged. Process smoothness is the last decision element if the first two (safety and equipment protection) cannot deter ­ mine the failure position of the valve. Process smoothness basically recommends the failure position that is the best for the process and that minimizes the fluctuation magni­tude and extent when a failure happens. The concept of valve position is summarized in Table 7.12. When there is no constraint exerted by safety, equipment protection, or process smoothness, the fail­ure position is decided based on economic factors; if FO and FC valves are the least expensive automatic valves, then one of them is selected. And sometimes the fail position is not mentioned in the P&ID at all. 7.10.3 Mor e Concepts about Failure Position of Automatic Valves ●What Is the Failure in Failure Position Discussion? As was mentioned previously, failure means losing the driver. Driver is combination of all energy streams that direct the valve actuator (and consequently the valve stem) to a specific position. So, in this context, failure does not refer to mechanical failures or any type of jamming. Table 7.13 shows the different actuators and their drivers.Table 7.12 Failur e position of automatic valves. Only for: Automatic valves; blocking or throttling Concept Position when losing “operator” Examples FO FC Acronyms FC, FO, FL, FISafety Equipment protection Process smoothness Table 7.13 Failur e reasons of different actuators. Type Symbol Actuator driver(s) Failure cause(s) Diaphragm actuator ●Instrument air ●DC electricity ●Losing instrument air ●Losing DC electricity Piston actuator ●Instrument air ●DC electricity ●Losing instrument air ●Losing DC electricity Motor‐operated actuatorM ●AC electricity ●Losing AC electricity Solenoid actuatorS ●DC electricity ●Losing DC electricity
orders of magnitude less than the aqueous ammonia tank truck. See Table 15.4 for a comparison of the op tions based on mass differences. 15.5.6 Conclusion and Action The design team ultimately chose to use anhydrous ammonia vapor to supply the SCR. Receiving ammonia in the anhydrous vapor form was determined to be an economically vi able option, and the safety analysis indicated that the vapor form of anhydrous ammonia was safer than design options incorporating eith er liquid anhydrous or aqueous ammonia. In comparing both the anhydrous va por and aqueous liquid options to the liquid anhydrous option, using th e vapor decreases risks along the piping run without introducing ne w risks to the system. Based on modeling analysis perfor med for the piping run, the liquid aqueous 417
106 GUIDELINES FOR MANAGING ABNORMAL SITUATIONS 4.3.3 Skills and Competencies of Trainers Training may be provided by a vari ety of means, but the objective is always the same—to help plant operat ors to be successful in meeting their assigned responsibilities. Tr aining tools and techniques are discussed further in Section 5.6. Success can be measured by the number and severity of near-misses or incidents that occur, the number of emergency situations, and the nu mber of abnormal situations that have occurred. More details of le ading and lagging indicators are provided in Chapters 5 and 6. The quality and success of the tr aining program will most likely depend on the personnel providing the training. These personnel are typically assigned as Trainers across a plant site or within a specific process unit. They may report to a central training organization or a local process unit leader. The success of th e Trainer often depends upon that person’s formal training, years of tr aining experience, knowledge of the chemical process, interpersonal sk ills, willingness to share but also listen, and measurement of traini ng progress against objectives. Depending on the size of the facility, the or ganization’s personnel configuration, and the available st affing, trainers may be assigned additional tasks. Therefore, it is re commended to have the trainer’s role, responsibilities, and objectives exp licitly documented. Any changes to the trainer’s documented scope could affect the overall success of the training program and should be considered and managed via the MOC process. With respect to management of ab normal situations, the training curriculum should include, at a minimum, the topics that are covered in Section 4.3.2. 4.4 SUMMARY This chapter has provided guidance to organizations in the process industries about organizing and structuring training on management of abnormal situations, including advice on trainer competencies, training programs, and focused training topics. Chapter 5 will introduce the read er to tools and methods for management of abnormal situations including the range of abnormal situation control options. Section 5.6 provides advice on training and drills.
221 Chemical Sites in 2002. The Guidelines desc ribe a risk-based approach to managing chemical facility security that allows assessment of a wide range of threats, ranging from vandalism to terrorism. With the recognition of threats, conseque nces, and vulnerabilities, and the evaluation of security event risks, a security management system can be organized to more effectively miti gate the risks identified in the assessment. Several trade associations, such as the American Petroleum Institute (Ref 9.2 ANSI/API) and states require companies to use security risk assessment (SRA) or security vulnerability assessment (SVA) methodologies that meet the design criteria set forth in the CCPS Guidelines . New Jersey allows facilities to use CCPS or CCPS-equivalent SVAs to meet the requirements of Administrative Order 2005-05 (see Chapter 10); Maryland and the City of Baltimore also allow facilities, subject to their chemical security requirements, to use the CCPS or a CCPS-equivalent SVA methodology. The U.S. Department of Homeland Security also adopted elements of the CCPS methodology as part of the Chemical Facility Anti-Terrorism Standards (CFATS). (Ref 9.5 CFATS) The elements of a typical SVA approach are shown in Figure 9.2, which describes the methodology published by CCPS in Guidelines for Analyzing and Managing the Security Vulnerabilities of Fixed Chemical Sites (Ref 9.4 CCPS). Upon completion of an SVA, a report or other documentation is prepared to communicate its results to management for appropriate action. The report should be carefu lly protected as company-sensitive information, because it includes desc riptions of identified vulnerabilities and related countermeasures recommended to address those vulnerabilities. 9.6 INHERENT SAFETY AND CHEMICAL SECURITY Application of inherent safety (IS) pr inciples may allow a facility to go beyond traditional physical security measures. Physical security includes such considerations as security officers, barriers, and surveillance equipment. However, some assets may lend themselves to security evaluation using IS concepts, in addition to physical, technical, and even cyber security options. A combination of these strategies, that may also
122 low oxygen content or toxicity. An in herently safer system is a rotating pressurized water spray head that does the cleaning without vessel entry. Another example is to eliminat e filters that requ ire changing, to reduce the potential for exposure. Th is may require a redesigned filter (such as a self-cleaning design), or a process change that eliminates the need for a filter at all. Equipment that can be reached for inspection, repair, or monitoring from permanent platforms is more likely to be safely inspected, calibrated, repaired, and replaced than equipment that requires climbing with a safety harness or scaffold. Calibrating equipment usually requires disconnecting it from the process. Equipment that requires less calibration is inherently safer. •For example, a furnace oxygen analyzer is not protecting the furnace while it is being calibrated. Equipment that can function in abnormal operating conditions is inherently safer than equipment that fails in those conditions. •An oxygen analyzer that was designed to stop displaying the oxygen content in a furnace wh en the oxygen content went below 4%. While the oxygen analyzer shutdown tripped the furnace, it left the operators without any indication of the furnace oxygen level blind during the shutdown and delayed the re-start. An analyzer that conti nued to display the actual oxygen concentration during the upset would be inherently safer. Equipment should be designed so that there is only one right way to reassemble it. •If it is important for a pipe sleeve to be right side up, then it could be notched or pinned so it will only go in right side up. One plant experienced a vessel leak caused by a siphon-break hole in a dip tube which was not oriented away from the vessel sidewall. The constant impingement of corrosive liquid into the sidewall from the siphon-break hole resulted in accelerated corrosion/erosion. •It is common practice to use unique fittings for nitrogen utility service, different from the fitti ngs used for compressed air or water, in order to ensure against cross contamination of the nitrogen system.
INVESTIGATION M ETHODOLOGIES 45 Figure 3.4 Common Features of Investigation M ethodologies To ensure effective incident investig ation and identification of root causes, addressing three key challenges can guide the overall investigation strategy to be selected: 1. “W hat” happened? A component for describing and schematically representing the incident sequence an d its contributing events and conditions. 2. “How” it happened? A component for identi fying the critical events and conditions (causal factors) in the incident sequence.
196 Addressing transportation risk at va rious life cycle stages can increase the inherent safety of the overall op eration. This may mean minimizing the number of railcars sitting on trac k within or outside the plant, the selection of suppliers close to the plant, or other options. This section provides an overview of inherently safer concepts and their application to potential transportation risks. In choosing the location of a new pl ant, or in assessing risks related to an existing plant, transportation risk must be considered. The design of new chemical processing units should include at the earliest opportunity a qualitative or quanti tative risk assessment of the value chain for the material, including production, use, and transportation of materials in order to minimize overall risk. Risk assessments of existing processes, including an assessment of transportation risk, may result in the conclusion that the process should be moved. Process risk assessment techniques are availa ble in numerous references (for example Ref 8.12 CCPS 2000) and the analysis of transportation risk is documented in Guidelines for Chemical Transportation Risk Analysis (Ref 8.14 CCPS 2008). The assessment of transportation ri sk must include consideration of the capabilities, equipment, and pr actices of the entire value chain associated with the manufacture and distribution/shipment of chemicals. Other than en suring that the carriers, which are separate entities, have the correct and valid licenses, certifications, training programs, emergency response plans, and other documented practices. the fixed facilities where chemicals are manufactured cannot control the policies, practices, procedures, or equipment of the carriers other than to deny them business. Once the carrier leaves the facility with a shipment, the fixed manufacturing fa cility has released the materials into the care of the carrier and cannot directly control the safety or security of the shipment outside its property, even though they usually are still the owners of the shipment unt il it is delivered to the customer. The chemical/processing industry , i.e., the shippers by DOT definition and the carriers (i.e., railroads, trucking companies, marine transportation firms, air cargo compani es, etc.) have historically worked together to improve both transpor tation safety and response to emergencies. The American Associ ation of Railroads (AAR), among
178 between the variables. Another exam ple of direct readings is in valve position signals. The position of a valve should be derived from devices that directly meas ure the valve stem position or stroke. The signals should not be derived from control signals that tell the valve to go to a particular position. In other words, the open or closed indication for a valve or control functions derived from them should on ly be given when the valve physically reaches the intended position, not when it is “told” to move by the control system. Operating Modes of Control Systems . Process control and safety shutdowns must be provided during a ll modes of operation, not only in the normal, steady-state operatin g mode. This includes startup, shutdown (normal and emergency), inspection/testing, and temporary operations (if any) The design of the control system should achieve the highest level of Simplification for emergency shutdown and other abnormal/upset situations. If an emergency shutdown capability includes a single operator action to trip (a single mouse click or the activation of a single manual button/switch), it should be easily found, very clearly labeled, easily operated, and unambiguous as to intended function. Important controls for higher risk situations should not, if possible, actually cause the pr ocess parameter to approach a critical safe limit when undergoi ng testing. For example, using inherently safer principles, a hi gh-level shutdown that can be tested without actually raising the level in a tank or vessel is safer than one that requires raisin g the level. Another example involves the overspeed testing of high-speed rotating machinery. The governors should be able to be tested without actually forcing the machine to reach th e trip speed (most electronic governors incorporate this design feature). Older, mechanical and electro-mechanical governors do not have this capability. In order to test the full control loop/function, the final controlled element(s) must also be tested . To do so without creating a transient or frequent unit/plant s hutdowns, it is often necessary to perform full SIS functional tests during shutdown periods.
Pipes 87 6.6.2 Diversion of Flow T he diverting of flow can easily be done by using several valves or a few multiway valves. One arrangement can be seen in Figure 6.41. In this arrangement, diverting valves work together to send the flow to destination C, B, or D. Each three‐way valve could be replaced with two con-ventional (two‐way) blocking valves. The multiway valves will be discussed in Chapter 7. 6.6.3 Distribution of F low The distribution of flow is more difficult. From a purely theoretical point of view, it can be said that the solution is manipulating the branches’ diameter and length to get to the desired flow rate. This solution, however, is not practical. The length of pipes is generally out of the con-trol of the process engineer. The designer needs to needs to follow plant layout, which dictates the pipe lengths. Therefore, even though this solution may be financially attractive, it is not practical. One magic bullet solution is to put control valves on all branches except one. This solution is shown in Figure  6.42. However, this solution can be expensive, especially when large bore pipes (larger than 12″) are being used. One branch can always be left without a control valve because when the flow rates of other branches are regu-lated by control valves, the flow rate of last branch will be regulated automatically. It is important to consider that the branch without a control valve cannot be the route with maximum resist - ance. It means that when deciding on the branch without a control valve, that the branch does not get a minimum flow because the flow cannot be regulated in a pipe with constraints. One alternative solution that only works when the intention is to distribute the flow evenly is to use sym-metrical piping. The schematic in Figure 6.43 shows this solution. The distribution of flow is not uncommon and where ver there is parallel operating equipment, this requirement should be met. A note stating, “Symmetrical Piping, ” as in Figure 6.44 shows how this is used. However, there are still some clients who prefer the control valve solution for applications like parallel heat exchangers and who are willing to pay the extra cost for that. Placing a control valve to handle the flow distribution is known as active distribution, and when it is handled through symmetrical piping, it is known as passive distribution. The best symmetrical piping arrangement for a precise flow distribution is the type in which the main pipe (before distribution) is perpendicular to the distribution header. However, in practice there is generally not enough room to implement such a concept. In practice, the main pipe could be connected to the distribution header after a run parallel to the distribution header and after an elbow. This arrangement generates a deviation from an evenly distribution goal. Air coolers are a type of equipment that require good distribution because of their multiple inlets (and out - lets). This will be discussed in more detail in Chapter 11.Figure 6.39 Check valv e. (a) (b) Figure 6.40 (a, b) M ultiple check valves.A BC D Figure 6.41 Diver ting flow in a multiple‐destination pipe route. A BC D Figure 6.42 Distributing flo w in multiple‐destination pipe route by control valves. AB DC Figure 6.43 Distributing flo w in multiple‐destination pipe route through symmetrical piping.
26. Learning from error and human performance 361 Table 26-4: Effective learning tips Tips for information sharing and learning An incident description This should be a brief description of what happened, using only the facts known at that time. Use of photographs (e.g., images of the incidents) or other visual aids (e.g., process flowcharts) can help to understand the incident and to visualize the event. The immediate action taken This should clearly set out the steps that operators need to undertake, such as conducting additional checks, suspending certain activities, or stopping use of particular equipment or processes. A feedback loop Supervisors should seek confirmation that: • Everyone has received and discussed the report. • Individuals have taken on the required actions. It is then important to evaluate the lessons learned and to monitor the effectiveness of any improvements. Learning from incidents requires an appropriate attitude and a desire to learn from them. Further tips supporting learning from incidents include the following: • Empathize with the people involved. Try to understand the reasons behind their actions. • Appreciate the benefits of knowing the end results. • Pose a series of questions: • Could this has happened to other people? • Are the systems robust enough to withstand the threats posed by the incident under study?
368 Human Factors Handbook [73] C. Wickens, Engineering Psychology and Human Performance, Columbus, OH, U.S.: Charles.E.Merrill Publishing Co, 1984. [74] G. Hofstede, Culture's consequences: Comparing values, behaviors, institutions and organizations across nations, London: Sage Publications, 2001. [75] J. Mitchell, “Lessons learnt from th e introduction of human performance concepts and tools on oil and gas platforms.,” in Hazards 27 , Birmingham, 2017. [76] M. Thomas, “Error management training: defining best practice. ATSB Aviation Safety Research Grant Scheme Project 2004/0050 2007 ,” Autralian Transport Safety Board, https://www.atsb.gov.au, 2004. [77] M. Wright and S. Opiah, “Literature review: the relationship between psychological safety, human performance and HSE performance,” Energy Institute, London, 2018. [78] S. Dekker, Just culture: Balancing safety and accountability., London: Ashgate Publishing Ltd.., 2012. [79] T. R. Clark, The 4 stages of psychological safety: defining the path to inclusion and innovation., Oakland: Berrett-Koehler Publishers, 2020. [80] P. A. Edmondson, The fearless organisation: Creating psychological safety in the workplace for learning, innovation and growth, Hoboken: Wiley, 2019. [81] North Atlantic Treaty Organisation, “T he NATO phonetic alphabet,” North Atlantic Treaty Organisation, www.nato.int, Undated. [82] U.K. Health and Safety Executive, “Man aging shiftwork. Health and safety guidance,” HSE Books, www.hse.gov.uk, 2006. [83] U.S. Chemical Safety and Hazard I nvestigation Board (CSB), “Bayer CropScience Pesticide Waste Tank Explosion,” U.S. Chemical Safety and Hazard Investigation Board , Washington, DC., 2011. [84] M. Endsley and D. Jo nes, “SA Demons: The Enemies of Situation Awareness,” in Designing for Situation Awareness: An Approach to User-Centered Design , Boca Raton, CRC Press, 2011, p. pp. 31–41.. [85] International Association for Oil and Gas Producers (IOGP), “Report 502 – Guidelines for implementing Well Operations Crew Resource Management training,” International Association for Oil and Gas Producers, www.iogp.org, 2014.
361 modification or removal (8) • Process re-design to eliminate need for a second tower (1) Reduction of inventory by removing dead-leg piping (3) • Reduced the potential inventory • Eliminated tankage (thus reducing inventory) • Eliminated stored aqueous ammonia • Removed excess piping • Installation of a tubular reactor that reduced the inventory of ammonia • Reduced inventory by eliminating tanks or reducing the
56 Guidelines for Revalidating a Process Hazard Analysis differences, such as “effects” instead of “consequences”). The unique concern about PHAs using the FMEA method is whether they adequately considered scenarios involving issues other than discrete component failures, such as, human errors, variations in raw material chemical composition/properties, or other non-equipment related issues. If th e FMEA only lists specific component failures as causes, such as “valve fails open,” the Redo approach is likely required, perhaps using the What-If/Checklist or HAZOP method. 3.2.3 Logic Errors and Inconsistencies in the Analysis Information in PHA reports should be valid, accurate, and logical. To some degree, the validity can be evaluated by having persons familia r with the process review the report. Accuracy can be checked (to the degree details are documented in the prior PHA) by comp aring equipment tag numbers and other parameters (e.g., set pressure on a re lief valve) to the process knowledge documentation. Logic errors are best disc overed by reading the hazard analysis worksheets. The decision to Redo or Update the PHA depends on the prevalence and magnitude of these errors in the prio r team’s risk judgments. Examples of logic errors include: • Listing human error as a cause with no furthe r explanation. Trevor Kletz is often credited for the idea that “blaming accidents on human error is equivalent to blamin g falls on gravity” [36, p. 2]. Humans will make mistakes. PHA teams should explore reasons that an error might occur (i.e., an error-likely situation) and result in substantial consequences. If fe asible, the PHA team should have made recommendations to substantially reduce or eliminate the risk of consequential, unr ecoverable human errors.
1.2 Definition of Process Safety Culture |7 dimensions of culture. Chapter 4 will address culture from the standpoint of organizational dynam ics, hum an behavior, com pensation, ethics, external influences (e.g. contractors, vendors, public sector), and metrics. Chapter 5 will discuss the ways in which culture can directly impact each elem ent of CCPS’s Risk B ased Process Safety (RB PS) PSMS. Chapter 6 will provide a guide for getting started establishing a strong culture or improving culture. Chapter 7 will address how to achieve a sustainable culture. The appendices provide additional background on culture, case histories that may be useful in discussing culture issues, and a culture assessment protocol. Taken together, the concepts discussed in these chapters provide the concepts and guidance to make these concepts a reality in an organization. This book does not discuss regulations, but instead comes from the point of view that a strong positive culture adequately addresses process hazards, whether regulated or not. This represents the first concept of a strong, positive process safety culture: the organization’s leadership and all personnel believe in the necessity of process safety and comm it to it, even in the absence of regulatory requirements. Some people have expressed the belief that safety culture cannot change. They consider core principles, com pany values and principles, and how the com pany behaves. They then conclude that good cultures will stay good, while poor cultures cannot improve. Mathis disagrees, suggesting that those who claim culture is static may be resisting the culture change (Ref 1.5). From a sociology point of view, cultures of all kinds develop via social conditioning. With the right conditioning, applied patiently over time, leaders can build strong positive cultures. Typically, this requires patience and persistence. It can take some time to build workers’ trust and to convince them that the intended culture change is not a temporary fad.
xxii B.2 Inherent Safety Analysis - In dependent Process Hazard Analysis (PHA) 464 B.3 Inherent Safety Analysis – Integral to Process Hazard Analysis (PHA) 467 Glossary 469 Index 497
Piping and Instrumentation Diagram Development 130 rejuvenation all the operation are performed by operator(s) in the field. In automatic rejuvenation the operation can be done fully automatically without any action by an operator, or can be initiated and observed by an operator from the control room (and not the field). Manual rejuvenation is done if the rejuvenation doesn’t need to be very frequent, or the rejuvenation steps are not very complicated, or if the unit of interest doesn’t have very critical role in the plant. Otherwise automatic rejuvenation should be performed. Below are a few examples of equipment requiring rejuvenation activities. Sand filtering in water treatment operation is generally a semi‐continuous operation. After a certain time period, the filter should be taken out of operation for backwash-ing. This type of operation should be implemented dur - ing the design and be shown on a P&ID. The backwashing could be manual (in small systems) or automatic. The backwashing operation is a type of “in‐place in‐line care. ” Another example is a soot blower for heating coils in the convection section of fire heaters and boilers. These coils get covered with soot after a while. To keep the same efficiency of the fire heater or boiler this soot should be removed from them. A soot blower is a moving set of perforated pipes that slide into the convection section of fire heaters and, by injecting steam, dislodge the precipitated coke or soot. Another example is the cleaning of bin filters. Bin filters are a type of in situ treatment of bin vents. Bin and silo vents may have a large amount of dust. To remove the dust from the outgoing gas (air) a bin filter can be installed on the vent of bins or silos. It is very common to use bag filters in the role of bin filter. In each bag filter there are several filter bags (socks) that separate the dust from the gas stream. These socks get full after a while then need to be rejuvenated. The rejuvenation of each sock can be done by backflowing an air jet in it. As there are several socks in each bag filter. One sock can be cleaned during normal operation with marginal impact on the operation of the bag filter. The last example of rejuvenation is the regeneration of ion exchange systems. Ion exchangers in, for example, water treatment systems don’t work on a fully continuous basis. They function to adsorb the ions on their “exhaus - tion period. ” At the beginning of this period the resin beads inside of the ion exchange vessel are fresh and ready to adsorb ions. After a while the resign beads are “filled” with ions and become exhausted. To return them back to their fresh condition, the resin beads should be “regener - ated. ” This regeneration, which is a type of rejuvenation, is done by sending a solution through the ion exchangers. A large group of rejuvenation operations are catego- rized as “cleaning. ” The different cleaning methods are discussed later in this chapter. It is very common to do automatic rejuvenation. The automatic rejuvenation can be provided by a mechanical unit that recirculates the cleaning agent or object. The automatic rejuvenation systems are any of two main types of “mechanical‐in‐place” (MIP) systems, or “clean‐in‐place” (CIP) systems. These systems will be discussed later in this chapter. Activities related to monitoring equipment in in‐line care are mainly on the shoulders of the “rounding” operator. The operator could be equipped (beyond just personal safety equipment) or non‐equipped. If the operator is non‐equipped, he/she relies on his/her five senses. Among them, the taste sense never is used. Below is a non‐inclusive list of the use of the remaining four senses of the rounding operator: ●Vision: leakage, vibration, overflow of tanks, checking levels, checking flame color and shape ●Hearing: vibration, cavitation, hammering, PSV release, explosion ●Touch: vibration ●Smell: fire, leakage, PSV release to atmosphere. To facilitate the duties of the rounding operator, the process engineer can put some items on the P&ID. The examples are sight glasses to check liquid levels, catalyst levels, or filtering media levels, and peep holes to check the color and shape of flames in a furnace or boiler. An equipped rounding operator can have some small measuring devices to check some parameters that can-not be accurately checked without. It could be a portable pressure gauge, portable temperature sensor, etc. If it is the plan to have an equipped rounding operator, the pro-cess engineer needs to provide “test points” on impor - tant points of the system for him. They could be a “pressure tap” (PT), or “temperature point” (TP). However, these points should not be very important parameters because if one parameter is very important to check and monitor, it should be part of a control loop. An example of a PT could be the suction side of centrifu-gal pumps. In some companies the acronym of PP is used for “pressure point” and TW for “thermowell. ” This con-cept will be discussed in more detail in Chapter 13. 8.4 In‐place Off‐line Equipment Care “In‐place off‐line” care could be for small repair jobs, inspection, or as a preliminary step for “in‐workshop off‐line care” activities.Table 8.1 Differ ent types of equipment care. In‐line Off‐line In‐place By process group By mechanical group By mechanical group In‐workshop Not applicable
344 13.7.1 Dow Fire and Explosion Index (Ref 13.14 Heikkilä 1999) The Dow Fire and Explosion Hazard In dex was developed initially for use within company operations and was later disseminated in a book published by the American Institute of Chemical Engineers (Ref 13.8 Dow 1994b). The index quantifies the damage from potential fire and explosion incidents and identifies eq uipment that would be likely to contribute to the creation or escalation of an incident. The Dow Index is the product of a Unit Hazard Factor and a Material Factor . The material factor for a proc ess unit is based on the most hazardous substances or mixtures pr esent that would result in a worst- case scenario, and it quantifies the amount of energy released. A material factor is determined for each process unit. The unit hazard factor for a process unit is the product of both general and specific process hazards. General process hazards address such issues as exothermic chemical reactions, endothermic processes, material handling and transfer, enclosed or indoor process uni ts, access, and drainage and spill containment. Spec ial process hazard s include factors for toxic materials, operation in or near flammable range, dust explosions, relief pressure, low temperature operation, corrosion and erosion, joint and packing leaks, fired heaters and hot oil systems, and rotating equipment. 13.7.2 Dow Chemical Exposure Index Like the Fire and Explosion Index, the Chemical Exposure Index was developed by Dow to help its e mployees design and operate safer facilities. In 1998, an AIChE volume brought the index—which by then was considered a seminal tool for rati ng the relative acute health hazard potential of a chemical release to workers and the neighboring community—to the entire process industry. The newest edition uses a new methodology for estimating ai rborne quantity released, which allows for more sophisticated proc ess analyses (Ref. 13.7 Dow 1994a). 13.7.3 Mond Index The Mond Index was developed by I mperial Chemical Industries (now ICI, an Akzo Nobel Company) after th e Flixborough incident, and is based on the Dow Fire and Explosion Index . The Dow Index was modified to address: 1) a wider range of proce sses and storage in stallations; 2)
296 PROCESS SAFETY FOR ENGINEERS: AN INTRODUCTION Overpressure Outcomes Explosion overpressure can cause harm to people inside and outside of buildings. People can survive a higher overpressure than typical stru ctures can. The overpressure can cause objects inside the building to be thrown, damage to the building, and building collapse, all of which can result in harm to the building occupants. An alyzing structural response is a specialist topic requiring expert civil engineering assistance. Overpressure duration is important for de termining effects on structures. The same overpressure level can have markedly different effects depending on the duration. Therefore, some caution should be exercised in application of simple overpressure criteria for buildings or structures. These criteria can, in many case s, cause overestimation of structural damage. An object struck by a blast wave experiences loading. When the blast wave hits the front wall of a building, it is reflected off the wall and builds up a local, reflected, overpressure which can be approximately twice the incident (side-on ) overpressure. This is illustrated in Figure 13.12 and fully described in Guidelines for Vapor Cloud Explosio n, Overpressure Vessel Burst, BLEVE and Flash Fire Hazards . (CCPS 2010) Damage levels observ ed at selected overpressures are noted in Table 13.14. Figure 13.12. Interaction of a blas t wave with a rigid structure (Baker 1973) (CCPS 2010)
200 GUIDELINES FOR MANAGING ABNORMAL SITUATIONS There were five fatalities: four in the control building and one in the office block. There were two report able injuries (requiring hospital treatment) and fifteen employees who required treatment for minor injuries and shock. This report is mainly based upon the report by the UK Health and Safety Executive (HSE UK 1994). 7.3.2 Incident Overview – Hickson and Welch fire Problems were being encountered with the operation of a batch distillation operation that used a st eam-heated vessel known as “60 Still Base,” shown in Figure 7.7 (HSE 1994) and a decision was made to open it up and clean out an accumulati on of sludge on 21 September 1992. Figure 7.7 Manway at the End of 60 Still Base - Source of the Jet Fire
234 | 6 Where do you Start? Provide indemnity : Avoid disciplinary action related to the reported unsafe condition, as far as practical. Maintain confidentiality : Take steps to prevent identifying the reporting em ployee on incident reports and elsewhere. Make it easy : Remove red tape and make reporting user- friendly. Acknowledge rapidly : Thank the reporting em ployee and provide practical, meaningful feedback as soon as possible. Also, be careful delivering m essages. For example, in a strong culture, leaders and em ployees believe that all incidents are preventable. However, printing “All incidents are preventable” as a slogan on a sign may subtly convey the unintended m essage that m anagement does not want to hear about incidents or near- m isses. Consider m essages carefully to prevent motivating the wrong behaviors. Sim plify The m ore difficult employees find the PSMS, the more likely they are to seek shortcuts and normalize deviance . Therefore, seek to simplify the PSMS and the associated policies, practices, procedures, and activities as much as feasible. Suggestions for simplification mentioned earlier in this book include: Use a risk-based approach : Processes and units involving significant potential hazards and risks warrant a com prehensive approach. However, lower hazards and risks may be managed with a m ore streamlined approach. Most PSMS elem ents can benefit from a risk-based approach, but PHA, MOC, and MI tend to benefit the m ost. Metrics : As noted above, collect the m inimum set of metrics and use those metrics that can be obtained easily. Where possible, automate collecting the metrics (e.g. automatically extract from operating records) and rolling up site and corporate data. • • • • • •
200 Human Factors Handbook Figure 17-5: Schematic of some factors influencing attention span 17.6.2 Supporting attention The potential attention span should be co nsidered. Where there is a potential for loss of attention during a task, some tact ics for maintaining attention are noted in Table 17-3. Many of these tactics aim to either enab le people to take a break from a task before they lose attention or increase th eir stimulation levels by factors such as task or environmental enrichment. For low demand, task requirements may be created to keep people engaged. For example: • Verbal updates of the system status. • Providing other tasks as a break, such as updating logs. Taking short but regular breaks or alternating tasks, can help maintain people’s attention for low demand tasks, such as 20 minutes on a task followed by 5 minutes performing a different task. If tw o people are performing task, they can switch jobs occasionally or stop and check each other’s work. The scheduling of additional tasks needs to ensure that they do not distract from the primary task. For example, the secondary task may be short or performed with the primary task still within the visual field of the primary task, such as completing a log at the same workstation. People’s circadian rhythms (body clocks) respond to light. People’s energy levels cycle between periods of feeling awake and periods of feeling sleepy. People are usually least alert between 02:00 and 04:00, and between 13:00 and 15:00. This does vary between people. If someone’s sl eep is disrupted, they can experience Sleep cycle Hot/humid Fatigued Singular task Low workload Low motivation Awake cycle Temperate Not fatigued Diverse task High workload High motivation Shorter Longer Attention span
339 To get an overall assessment of the process options, it is necessary to use a variety of indices and qua litative techniques and then combine the results. A number of quantitative tools for evaluating inherent safety have been developed or are in the process of being developed. These include Khan and Amyotte (Ref 13.19 Khan), Heikkilä (Ref 13.14 Heikkilä 1999), and Edwards, et al. (Ref 13.10 Edwards 1996). 13.6.1 Tools for understandi ng and resolving conflicts The CCPS book, Tools for Making Acute Risk Decisions with Chemical Process Safety Applications (Ref 13.5 CCPS 1995), presents a list of factors that, in addition to cost and risk, should be taken into consideration: Alternatives available for reducing or eliminating the risks Availability of capital Codes, standards and regulation s and good industry practices Company and/or personal liabilities Company image Costs of implementing available alternatives Economic impact of the activity on the local community Employment opportunities provided by the activity Frequency level(s) of the risk Inequities in how the risks and benefits are distributed among members of society Number of people at risk Perceived benefit of the activity and its impact on the public and/or stockholder image Profitability of the activity Societal component of the risk, such as the maximum number of people impacted by a single event Strategic importance of the activity to the company’s growth and survival Type(s) of risk, such as human fatality, injury, and acute environmental damage It is impractical to develop an explicit algorithm for selecting a decision aid. But, decision aids can be flexibly applied, and most can be adapted to an organization's needs and to a wide range of problems. However, an understanding of the key characteristics of the problem, and of the decision aids, is basic to making an appropriate selection.
Piping and Instrumentation Diagram Development 312 Control Valve Versus VFD We learned that there are at least two methods of con-trolling pumps: by control valve and by VFD. Now the question is, which one should be used? Sometimes when we are not sure, we use both of them in the form of split‐range control. If we cannot afford to use both of them (in the form of split control), we need to choose one of them. Traditionally, we use a control valve because it is an older technology; however, there are cases where a VFD works better. The main consciously changing parameter in a water treatment plant is the flow rate. The flow rate is changing and we have to find “something” to adjust the flow rate of different pieces of equipment. There are mainly two types of device can be used to adjust the flow rate: control valve and VSD. A control valve is generally installed on the discharge line of a pump (or compressor) and the VSD is installed on the electromotor of the pump (or compressor). These two methods of adjusting flow rates are named “final control elements. ” These two methods of controlling the flow rate are very similar to two methods of controlling the speed of car we are driving. This analogy can be seen below. Table 15.9 summarizes some process reasons for using a control valve or a VFD.15.7.1.1.2 Minim um Flow Control The concept of minimum flow control is shown in Figure 15.34. Let’s assume that this pump has a capacity of 200 m3 h−1. The vendor specified that the minimum flow rate of the pump is 100 m3 h−1. We can provide a recirculation line from the outlet of the pump back into the inlet line. If the flow rate into the pump is 165 m3 h−1, the pump is happy, since its flow is higher than the minimum flow. In this case, the sensor on the pump outlet sends a signal to the control valve on the recirculation line and it remains closed. However, if the flow drops below 100 m3 h−1, for example to 80 m3 h−1, the flow sensor on the outlet will send a signal to the controller to say: “I am short of my minimum required flow by 20 m 3 h−1and I am worried about the pump. Please open the valve enough to recirculate 20 m 3 h−1, so we can fool the pump into thinking that the flow is 100 m3 h−1, and make it happy, ” The control valve on the recirculation line will be partially opened to provide a flow of 20 m3 h−1, which is sent back to the inlet to satisfy the minimum flow condition of 100 m3 h−1, and prevent damage to the pump. This is the concept of minimum flow control. It is important to recognize that this “trick” only increases the flow rate inside the recirculation loop to a number higher than 100 m3 h−1 to “fool” the pump. We are not able to increase the overall flow in the whole upstream and downstream piping system; the flow in those pipes is still 80 m3 hr−1. The point here is that the sensor should be placed as close as possible to the pump and within the recircula-tion loop. Now the question is whether we need a minimum flow control loop for all centrifugal pumps or not. The answer is no! We don’t need minimum flow control loop for all centrifugal pumps. The following examples of pumps may not need a min- imum flow control loop [1]: ●Small pumps of less than 5 hp; t hey need it, but they are inexpensive so we don’t bother to put an expensive minimum flow control loop on them.FCOption A Option BFC FC FC VSD Figure 15.33 Options for c entrifugal pump capacity control.Table 15.9 Options for c entrifugal pump capacity control. Control valve VFD ●Generates more shear on the stream. Not good for shear‐sensitive liquids like oily waters, biomaterial, water carrying flows etc. ●Works for all types of piping circuits ●Generates less shear on the stream ●Doesn’t work in systems where the majority of the pump head is used to overcome static pressure rather than pipe pressure loss
Ancillary Systems and Additional Considerations 391 In the text below we discuss the usage of each of these utilities. Steam: a steam that is used in USs is named utility steam. We need utility steam whenever we need to clean stubborn fouling and scales. Generally speaking, steam is the last resort for removing dirt from process equip-ment. If utility steam fails to clean fouled or scaled equip-ment, the next available option is cleaning with solvents or chemicals, which is a very expensive operation. Air: utility air or plant air is again used to clean dirty equipment. Utility air is more effective on dry dirt. The other usage of utility air is driving power tools. The quality of utility air is less than the quality of instrument air. However it should be clean and free of any dirt. Water: utility water is the water from the US. This water could have quality similar to potable water but in the majority of cases its quality is less than potable water. So it is important to know that utility water is not always drinkable. This water shouldn’t have any scaling or fouling tendency. Utility water again is used for washing and cleaning of dirty equipment. Nitrogen gas: nitrogen gas could be implemented in USs for different reasons. The main property of nitrogen gas is its inertness. Thus nitrogen gas can be used for purging and pushing toxic, aggressive, flammable gas from an enclosed space. This action could be taken before letting people enter inside a piece of equipment like a vessel or a tank, or nitrogen gas can be introduced in a process system before starting up. The type and number of utilities in each utility station may vary depending on the equipment in the vicinity. It is important to note that the hoses that could be used for a US have a standard length. Therefore each US can only cover a specific radius around itself. The designer needs to decide the location of the US and the utility in each US. The systematic way to do this is by preparing a list of equipment in the plant and then listing all the required utilities for each piece of equipment during maintenance. Then, based on a plot plan, the designer can decide upon the number of required USs in the plant in a way that covers all the equipment (Figure 18.11). Utility stations are not necessary located on the ground floor and they could be on the platforms around the equipment too. However, elevated USs generally have only gas or vapor utilities. If a utility like “plant water” is to be provided for an elevated utility station, provisions should be considered to prevent splashing plant water on the personnel who are unaware and passing by on the ground. In each plant, before developing US drawings, the plant owners should be consulted for the availability of different utility steams, their pressures, and the length of the standard hose for USs. The exact location of a US cannot be recognized from P&IDs. However, a US can be seen in utility distribution drawings (Figure 18.12). Product Tank Product TankSeparator Separator SeparatorSand Filter Catalyst BedsDemin Water CausticAcid O2 ScavengerArea 1: tank farm Area 2 Area 3Hx’s US 50 US 52US 53 US 54US 57US 55 US 59US 56 US 58 Figure 18.11 Positioning of utilit y stations in a plant based on the plot plan.AS WN ASW Figure 18.10 P&ID presen tation of utility stations.
Piping and Instrumentation Diagram Development 152 of process and instrument nozzles are related to instruments. They are nozzles that are installed on a container to attach sensors to a container. The sensors could be level sensors or temperature sensors. Nozzles can also be classified as operating nozzles and spare nozzles. Operating nozzles are the ones currently in use. Spare nozzles are implemented for future poten-tial use. Table 9.6 summarizes the name and purpose of several container nozzles. The size and the number of spare nozzles could be specified by the client. Otherwise the process engineer can use his judgment. For process spare nozzles he/she can use a rough number of 10–20% of operating process nozzles, with sizes in the mid‐range of existing process operating sizes. For instrument spare nozzles several 2″ and 3″ nozzles can be provided. 9.9.2 Nozzle L ocations It is important to know that the location of nozzles on containers in the P&ID never ever represent their real location on containers. The real location of nozzles on each container can be found in the container datasheet. The nozzle symbols are drawn on the container symbol just wherever there is enough room around the container. Table 9.6 Duties of no zzles. Nozzle name Explanation Process fluid nozzles Process nozzles are nozzles that process fluid goes through for entering the container fluid or exiting the container fluid Instrument nozzles Instrument nozzles are the nozzles for installation of different sensors to the containers Manway Manways are not only for quality control or maintenance personnel to enter. Manways are used for operator entrance and also entering or exiting container internals. They are generally used in large containers, ones with a diameter more than one meter Overflow nozzle Overflow nozzles provide a release route when the liquid level in a tank keeps increasing and is going to fill the container Thief hatch Thief hatches used to be called dip hatches. They are nozzles with easy‐to‐open lids and are installed on the top of liquid containers (for example on the tank roof) for the purpose of taking samples from the container liquid. This sampling is done by sending down (dipping) a small jar to the liquid. In older times, these nozzles were used by thieves to steal oil products from tanks. This is the reason their name gradually changed from dip hatch to thief hatch Pressure protection nozzleThis is a nozzle (or nozzles) that releases fluid out of the container to protect it against high pressure. Basically, this nozzle is for the installation of a PSV Vacuum protection nozzleThis is the nozzle (or nozzles) that provide contort release of fluid out of the container to protect it against high vacuum. Basically, this nozzle is for the installation of a VSV Free vent nozzle Free vent nozzles can be necessary for non‐flooded containers. They are installed mainly on atmospheric tanks. These are used to provide an opening for tank “breathing. ” “Breathing” will be discussed in Section 9.11 Clean‐out doors Clean‐out doors are generally larger nozzles of mainly rectangular shape that are placed on large containers (large tanks) to provide capability of sending machine to the tank. For a plenty of cases, these machines are for sludge removal from the bottom of the tank. Drain nozzles Drain nozzles are the nozzles used to drain liquid from a container for the purpose of taking out the container from normal operation. Hand holes Hand holes are nozzles on smaller containers that are too small for an operator to be able to enter into. Hand holes are used only for inserting a hand to check the inside of container. They are used for smaller containers instead of manways. Drain and vent size For draining and venting the container Sting nozzle For cleaning during the operation Steam‐out nozzle For off‐line cleaningPurge nozzle For off‐line cleaning and making safe the internal atmosphere View or inspection portFor monitoring by the operator Media adding/removal For adding or removing media such as sand or resin beads during rejuvenation Cathodic protection For corrosion protection
297 11.13 INCIDENT INVESTIGATION As with PHA and MOC, the use of IS checklists and guidewords based on the four IS strategies can be used in investigation activities, root cause analysis, and in the formulation of recommendations. The overall incident investigation process and where IS guidewords and checklists can be used in it is shown in Figure 11.4 (Ref 11.16 Kletz 2010). The formal investigation of in cidents and near misses also represents an opportunity to ch allenge and possibly eliminate the hazards that caused the events in the fi rst place. This is the goal of root cause analysis, which is a common prac tice during an incident/near miss investigation. The elimination or reduction of ignition sources or potential leak points as a result of an investigation, as described for emergency response plans is an example of the use of the IS strategy of Minimization. Another example of this IS strategy is as follows: if an investigation is conducted pursuant t o a n i n j u r y c a u s e d d u r i n g a sampling operation, this is an opport unity to question why the sample is required in the first place. 11.14 MEASUREMENTS AND ME TRICS/AUDITING/MANAGEMENT REVIEW AND CONTINUOUS IMPROVEMENT The three elements of PSM/RBPS wh ere the process safety program are measured and formally evaluated represent opportunities to use IS strategies. Minimization of a large list of process safety metrics to a small and more manageable list that is easier to collect and analyze is a preferred practice. This will allow a focus on the key issues that affect the process safety risk rather than diluting a ttention and time with a large number of KPIs. Also, a metric could be crea ted that provides a measure of how many times (divided by the number of opportunities) that IS strategies were used in both the design and op eration of the facility (including its equipment and its chemicals), and in the modification of the PSM/RBPS program policies, practices, and proced ures. It is not probably necessary to report this KPI at the same fr equency as other PSM/RBPS program metrics, but having the PSM Manager keep track of these IS uses and opportunities will provide some useful data on how the facility and its PSM/RBPS program reflect the state-of-the-art.
•Mansfield, D.P. and Cassidy, K. (1994). Inherently safer approaches to plant design: The be nefits of an inherently safer approach and how this can be bu ilt into the design process. Presentation at IChemE Hazards XII—European Advances in Process Safety, April 19-21, 1994, UMIST, Manchester, UK. AEA/CS/HSE/R1016, HSE Books/HMSO, August 1994, ISBN 0853564159. •Sanders, R.E. (2003). “Designs that lacked inherent safety: case histories.” Journal of Hazardou s Materials, 104, 1-3, 149-161. 15.10 REFERENCES 15.1 American Industrial Hygiene Association, Emergency Response Planning Guidelines: Chlorine . Akron, OH: American Industrial Hygiene Association, April 20, 1988. 15.2 Carrithers, G.W., Dowell, A.M., and Hendershot, D.C., It’s never too late for inherent safety. In International Conference and Workshop on Process Safety Ma nagement and Inherently Safer Processes, October 8-11, 1996, Orlando, FL (pp. 227-241). New York: American Institute of Chemical Engineers, 1996. 15.3 Center for Chemical Process Safety (CCPS), Guidelines for Engineering Design for Process Safety . New York: American Institute of Chemical Engineers, 1993. 15.4 Crowl, D.A., and Louvar, J.F., Chemical Process Safety Fundamentals With Applications (pp. 14-15). Englewood Cliffs, NJ: Prentice Hall, 1990 and 2002. 15.5 Det Norske Veritas (DNV) - PHAST® (Process Hazard Analysis Software Tool) is a compreh ensive hazard analysis software tool broadly used in the chemical and petroleum industries developed and marketed by DNV Software, th e commercial software house of DNV. 15.6 Dow Chemical Company, Dow's Chemical Exposure Index Guide, 1st Edition . New York: American Institute of Chemical Engineers, 1994a. 431
B Major accident case studies B.1 Texas City Refinery explosion, 2005 The 2005 Texas City refinery explosion, shown in Figure B-1, occurred during the start-up of the isomerization (ISOM) unit, killing 15 people and injuring 180 [16]. The unit was being restarted after main tenance. The raffinate splitter tower was overfilled. The raffinate flowed from th e tower through a set of pressure safety relief valves to a blowdown drum and stac k, from which it was released into the atmosphere and likely ignited by a nearby truck engine. The CSB produced a video of this incident [14]. Figure B-1 Texas City Refinery Explosion (from www.csb.gov) The steps leading to this accident are as follows: • The ISOM raffinate section start-up began during the night shift and stopped with the tower level control valve closed (this was unusual). The operator did not use the start-up checklist and did not log his actions. When the day shift started work, they had no record of the start-up. • The bottom of the tower had been filled to 99%, which was not unusual but was not consistent with the start- up procedures. Over time, this had become an accepted deviation to the procedures. A high-level alarm set at 72% activated and alarmed throughout the incident. A 78% high-high level alarm did not activate. • A poor shift handover meant the day shift was unaware that heat exchangers, piping and other equipment had been filled in addition to Human Factors Handbook For Process Plant Operations: Improving Process Safety and System Performance CCPS. © 2022 CCPS. Published 2022 The American Institute of Chemical Engineers.
232 Human Factors Handbook • Implementation of error prevention techniques may increase the duration of tasks completion, until the individuals had developed the required skills. Pressuring a team for faster performance during the initial stages of skills development, may have the opposite effect and increases likelihood of error. • Effective strategies to detect, manage, and recover from error include: o Error Management Training and coaching. o Building resilience from error recovery. o Creating a psychologically safe environment. o Task verification, such as Human Based Checking.
5.2 Learning Models for Individuals | 59 5.2.3. Dynamic Learning In the digital age, classroom-based training and online slide decks are a thing of the past. New cloud-based digital learning experiences are flexible, personalizable, effective, and good for the bottom line (Willyard 2016). As with the Career Architect model, employees and their managers work together to identify learning and development needs. Then, development is supplemented with dynamic novel online tools, including: • micro-learning. Short lessons, typically three minutes or less, reflect the trend in today’s society toward consuming information as short videos or social media posts. Micro-learning is best when applied to very concise learning opportunities, for example to tackle an unfamiliar task in a new assignment, or as a periodic refresher. It may also be used to segment longer courses into manageable bites. • self-serve learning. E-learning is available on demand when the employee needs it. • learning as entertainment. Digital games, virtual reality, interactive presentations, and competitions are effective learning tools—and have special appeal for younger workers. • social learning. Online collaboration platforms make it easy for employees to share and collaborate. • user-generated content. Content doesn’t have to be polished to be effective. Students today are eager to develop their own content—presentations, videos, signs, and more—and to learn from other students. Like Gardner’s Multiple Intelligences Model, the Dynamic Learning Model fits primarily in box III (Check) of Figure 5.1 but should be extremely useful in box IV (Act). Dynamic Learning serves as a reminder that our toolbox for communicating learning experiences is larger than the classroom—and likely to keep expanding. When we review internal and external incidents, we should look beyond reports and videos, and when institutionalizing the learning, we should not limit the way we communicate. 5.2.4 Ancient Sanskrit An ancient Sanskrit shloka states (Surya Rao 2019; Joshi 2009): One gains ¼ of the knowledge from the Acharya (the teacher), ¼ from his own self-study and intellect, ¼ from co-learners and the balance out of experience.
187 Although it is usually difficult to modify the process chemistry and operating conditions during the op erations and maintenance stage of process life, there may be opportuniti es to make partial changes that have profound process safety impa cts. It may not be possible to substitute chemicals, but it may be possible to use them in more moderate conditions. Examples: even a small adjustment in pH may have a significant effect on the rate of corrosion; small adjustments in flow may reduce erosion problems in certain components. Larger scale projects later in life, such as debo ttlenecking, may offer the opportunity to change heat and mass transfer equipment to simpler, more inherently robust, and more IS friend ly designs (see Chapters 6 and 7). 8.7.2 Inherent Safety - Continuous Improvement At a minimum, a facility with a proc ess safety program will perform PHAs or similar studies at least once ev ery five years. Many companies and facilities also perform PHAs as part of projects. During these studies, each safety device or procedure should be evaluated to see if it can be eliminated or modified by applying inherently safer principles of Simplification . These include the use of: Valve designs that offer a visual in dication of actual position and not the commanded position. Mechanical connections (or disconnections) for blanking, draining, cleaning, and purging connections so that maintenance activities cannot be started without first disconnecting lines that might add hazardous materials to the equipment. One example is to route a nitrogen line across or through a manway, so the vessel cannot be entered withou t disconnecting the nitrogen line. Accessible valves and piping to minimize errors. Adequate spacing to avoi d crowded vessel access. For operability and maintainability, minimize the complexity of any instrumented protection layers, where possible (Ref 8.23 CCPS 2016b). Logical numbering of a group of equipment. Figure 8.5 is an example of poor assignment of equipment numbers for pumps. Logical control panel arrangements. Figure 8.6 is an illogical arrangement of burner controls on a kitchen stove.
292 INVESTIGATING PROCESS SAFETY INCIDENTS Figure 12.4 Example Recommendatio ns and Assessment Strategies (ABS, 2001)
170 INVESTIGATING PROCESS SAFETY INCIDENTS On the other extreme, a field operat or’s observations and actions may be less precise. “Sometime around noon,” or “right after the 10:00 AM morning break,” may expre ss these approximations. Figure 8.6 is an example of a simple timeline using imprecise data from the field operator. This timeline uses a portion of the approximate data from the incident example discussed in detail in Appendix D. Figure 8.6 Timeline Example Based on Approximate Data Normally the investigator is pres ented with a combination of both precise and imprecise data. Mixing th ese significantly different data often proves to be a challenge—a challeng e, however, that can be overcome simply by understanding the source an d precision of the data and the use of appropriate graphing techniques. On e such technique involves using a line with timing marks as th e common boundary between the two different types of data. On one side of the line, the known precise data is logged against the
188 Organized and complete technical information (i.e., the process safety information) for the process equipment that includes not only the basic design informatio n, data, and specifications, but also additional information that will thoroughly support operations and maintenance activities, such as maintenance materials, vulnerabilities of the materials of construction to corrosion and damage mechanisms (often referred to as Corrosion Control Documents or CCDs), lubricants, packing materials, etc. During PHAs and at other opportunities when operating procedures undergo review, they should be reviewed using inherently safer principles for the following safer provisions: Using checklists in operator rounds. Using a second person to doub le-check certain log entries. Scheduling to minimize cross-contamination and clean-ups. Recording a value for a process variable rather than just a check mark. Reformatting procedures to make them more user-friendly. For example, placing an easily recognized tab at the page containing the emergency procedures. See Chapter 6 for further discussion of human factors.
EQUIPMENT FAILURE 197 Table 11.2. Common failure modes and design considerations for heat exchangers Failure Mode Causes Consequences Design Considerations Leak from heat transfer surface Corrosion from contaminants in the process fluids, and cooling fluids, and/or loss of treatment chemicals. Anaerobic attack under sediments and scale. Thermal stress (e.g. extreme heat/cold) Loss of containment Inadvertent mixing and contamination of low pressure side, potential reactions, (HIRA needed) Periodic inspection Choice of materials of construction Choice of heat transfer fluid Shell expansion joints Non shell and tube design Control of introduction of process fluids during startup and shutdown Monitoring of low pressure side fluid Toxic fluids in tubes, monitor shell side. Treatment chemicals Rupture from heat transfer surface Corrosion Thermal stress (e.g. extreme heat/cold) Operation out of design temperature range resulting in stress cracking, improvement, weakening of tubes or tubesheet (see loss of cooling or heating load) Blocking in one fluid side during operation Potential rupture of heat exchanger Loss of containment Emergency relief device Control of introduction of process fluids during startup and shutdown Loss of cooling or heating fluid Loss from supply Control system malfunction Pluggage or Misalignment of valves Loss of process control (HIRA needed) High pressure Alarms / interlocks on low flow or pressure of heat transfer medium High or low temperature alarms on process side Inadequate heat transfer Fouling Accumulation of non- condensable gases (mostly condensers) Loss of process control (HIRA needed) High pressure Ability to clean High or low temperature alarms on process side Mass Transfer: Distillation, Leachi ng and Extraction, Absorption Overview. Mass transfer operations are used to se parate materials, purify products, and detoxify waste streams. Knowledge of the properties of the materials being handled is necessary to assess the hazards of the potential failures of mass transfer equipment.
HUMAN FACTORS 363 Figure 16.6. Human failure types (HSE a) Figure 16.6 identifies the types of human error and violations. Skill-based errors include slips such as cond ucting an action too soon in a sequence or lapses such as forgetting to perform a task. Mistakes occur when someone does the wrong thing, believing it to be appropriate. This includes rule-based mistakes such as conducting a procedure differently than written or knowledge-based mistakes su ch as responding based on knowledge which is incomplete in this instance. Violations are intentional. These failures can be routine in that it is the way a task is conducted (despite what the procedure says); situational or exceptional in that the operator, in that situation, thought it was appropriate to perform the task that way. Workload challenges. Workload is the amount of mental effort used to process information. Problem solving, decision maki ng, and thinking cause workload. The more attention required, the higher the workload. Su stained high workload is associated with increased errors, fatigue, and stress. Multi-tasking causes competition between task s for mental attention. Communicating and conducting a manual operation at the same time is an example. Although this sounds easy, the two tasks compete for the same brain space and this can result in poor performance of one or both tasks. Reducing the difficulty of the task, the number of tasks running in parallel, the number of tasks in a series, and time constraints all serve to minimize workload challenge. Surprise and startle. This is related to the hum an fight or flight response. In this situation all mental capacity becomes focused on the threat and/or the escape from it. In a fight or flight state, time is key to survival. Today, that is seen in an urge to be engaged in the active solution. To act fast, the brain requires a quick underst anding of the problem that doesn’t require problem solving. Providing very clear instruction on what to do and when to do it is helpful in this situation.
REACTIVE CHEMICAL HAZARDS 91 The CSB identified three reactive hazard type s: chemical incompatibility, runaway reaction, and impact or thermally sensitive materials. (CBS 2002) Chemical reactivity can occur by design (e.g. in a chemical reactor) or accidentally (e.g. inadvertent mixing of incompatible materials, storage or handling). Reactive chemical incidents typically involve: inadequate hazard identification & evaluation, inadequate procedures and training for storage and handling of reactive chemicals, and inadequate process design for reactive hazards. Important definitions and terminology related to reactive chemistry include Endothermic and exothermic reactions can gene rate gaseous or highly volatile products. Exothermic reactions have the potential for a runaway reaction leading to a dramatic increase in temperature, pressure (if the reaction is contained) and reaction rate. Chemical reactions can occur throughout a proc ess facility including in the storage of raw materials, in process streams, as the products , or in the process waste streams. Particular attention should be paid to waste streams wher e many chemicals can come together in ways that may not be identified unless specifically an alyzed. Chemical reactivity types are listed in Table 5.1 and several reactive function al groups are listed in Table 5.2. Chemical Reactivity - The tendency of substances to undergo chemical change. (CCPS Glossary) Exothermic Chemical Reaction - A reaction involving one or more chemicals resulting in one or more new chemical species and the evolution of heat. (CCPS Glossary) Endothermic Chemical Reaction - A reaction involving one or more chemicals resulting in one or more new chemical species and the absorption of heat. (CCPS Glossary)