{"id":321,"date":"2009-11-01T15:47:10","date_gmt":"2009-11-01T15:47:10","guid":{"rendered":"http:\/\/www.jmcampbell.com\/tip-of-the-month\/?p=321"},"modified":"2011-06-02T11:52:03","modified_gmt":"2011-06-02T16:52:03","slug":"three-simple-things-to-improve-process-safety-management-2","status":"publish","type":"post","link":"http:\/\/www.jmcampbell.com\/tip-of-the-month\/2009\/11\/three-simple-things-to-improve-process-safety-management-2\/","title":{"rendered":"Three Simple Things to Improve Process Safety Management"},"content":{"rendered":"

In this Tip of the Month, we look at how to deal with some of the challenges of managing process safety.\u00a0 This TOTM is an excerpt of a paper presented by JMC Instructor\/Consultant, Clyde Young at the 2008\u00a0Mary K. O\u2019Connor Process Safety Symposium<\/a>.\u00a0 This TOTM continues where the February 2009, TOTM left off.<\/p>\n

Processes are designed to run in a \u201cnormal\u201d mode.\u00a0 No process is really stagnant and throughout the life cycle of a process, changes will be made.\u00a0 When defining \u201cnormal\u201d, some tolerance should be built in to allow a range of operating conditions for operators to work within.\u00a0 When changes to operating parameters, or the equipment in the process are required, these must be evaluated and approved. Any effective process safety management system will contain an element to deal with Management of Change (MOC).\u00a0 Experience conducting training, audits and process hazard analysis studies indicate that identifying what changes require evaluation using the MOC process can be confusing at times.\u00a0 Some organizations only evaluate technical changes to the process and equipment and ignore or forget about managing changes to the PSM system or personnel changes within the organization.<\/p>\n

Insuring that PHAs are consistent with the process through the revalidation process is less time consuming and more likely to yield effective results if the facility\u2019s MOC program is rigorously followed.\u00a0 If this cannot be assured, then the only choice may be a complete redo of the PHAs.\u00a0 This could be very expensive and resource intensive.<\/p>\n

To alleviate confusion and especially to insure that all personnel within an organization understand and will follow the MOC program requires practice.\u00a0 As more MOCs are developed and approved, all personnel become more competent at evaluating change and meeting the requirements of the program.\u00a0 Ever since the US Occupational Safety and Health Administration (OSHA) implemented the PSM standard in 1992, one of the hottest debate topics witnessed in plant offices is about replacement in kind.\u00a0 OSHA and CCPS define a replacement in kind as meeting the design specification of the original.\u00a0 This is a workable definition, but can cause some confusion when personnel are not well versed in PSM and risk management.<\/p>\n

The second simple thing which can be done to improve process safety management systems is to do away with the concept of replacement in kind.\u00a0 Again, this does not have to be and probably can\u2019t be accomplished throughout an organization; this can certainly be implemented at the process and plant level for a specified period of time.\u00a0 The purpose of this change would be to end the debates and more importantly allow personnel an opportunity to practice and become competent at all the issues associated with performing changes.<\/p>\n

A real life example illustrates this:<\/p>\n

A Waukesha 7042 engine is scheduled for overhaul.\u00a0 Three options are considered:<\/p>\n