Leading the Way to Process Safety

By Peter Montagna

“Leadership” is a hot topic in the process industries. So is process safety. The two really go together. With strong leadership, process safety programs will succeed and their benefits will spread like ripples in a pond. Productivity and morale will increase. Incidents will diminish. The plant will be welcome in the community.
With strong leadership, a process safety program can achieve many goals. It can satisfy shareholders and company management with improved productivity and profitability; satisfy the community with fewer incidents; and satisfy employees with a healthy and safe working environment.

So, just what is “strong leadership?”

Individuals put into  leadership positions in technical organizations generally have demonstrated strong technical knowledge or good managerial skills. Unfortunately, these are vastly different from the skills that make strong leaders. Managers and leaders have different perspectives. Good managers are those who do things right, while good leaders are those who do the right things. The good news is, leadership skills can be learned. For every “born leader” out there, there are many who work hard at sharpening their skills throughout their careers.

Warren G. and Warren Bennis in their book, On Becoming a Leader, say that for a process safety specialist or manager to be a good leader, he or she must do the following:

1. Engage others by creating shared meaning. The leader must be richly endowed with empathy.
2. Speak with a distinctive voice. Leaders have purpose, self-confidence and a strong sense of their own strengths and weaknesses.
3. Possess integrity. Leaders have unimpeachable ethics and a strong moral compass.
4. Be adaptable. Leaders act first, using a compass (not a map), then evaluate the results. They make corrections, if necessary, and then take action again.

Getting It Done

The cost of incidents alone should be enough to motivate company officials to mandate robust process safety systems. Incidents cause work stoppages, material loss, waste, equipment damage and, unfortunately, sometimes employee injuries or even fatalities. Beyond costs, companies that suffer safety incidents damage their public image and employee morale. Sometimes they’re subject to regulatory action. In some cases, however, robust process safety systems aren’t mandated and may not even be welcome!

The process safety specialist in charge of developing or improving a company’s process safety system has an impressive challenge. This individual may face resistance by the company’s upper management. Let’s face it—safety costs money. Safety slows down production and reduces productivity, since people will now be involved in what might be perceived as non-value added activities. And few of us like change.

Much has been written about how the safety professional must make the business case for safety and “sell” upper management on the ideas and associated requirements of a robust process safety system. But where does he or she start?

John Kotter, in What Leaders Really Do, says successful organizational change of any kind follows well-documented processes. First,  create a sense of urgency throughout the organization through a campaign of education and communication. Leaders engage people with compelling messages that are spoken with purpose and self-confidence. It’s that simple. Others will follow when the message is delivered with both empathy and strength.

Then the process safety specialist leader has to form a team and help it create a compelling vision that clearly states what the organization’s safety program must achieve to be successful. From this vision, the team then develops specific measurable and verifiable goals. Most important, the team must show how these goals will make a positive impact on the firm’s profitability—that is, how compliance with process safety programs will improve productivity, or how noncompliance will cost the company in the form of incidents and possible regulatory action.

Next, empower employees at all levels to act out the vision and broadly advertise short-term successes. This will lend credibility to the program, while disempowering critics and cynics. The process safety leader must facilitate and support these efforts, especially where fear or anxiety cause resistance.

For the cultural and organizational change to take root and grow, short-term successes must continue. Momentum builds, leading to the tackling of larger and more difficult challenges. As programs are developed and implemented, the organization will look toward the leader for assurance and continued direction. Consistency is important, but integrity is critical. As resistance to change becomes stronger, the leader may need to acquiesce to maintain cooperation. At all times, however, the process safety leader must maintain unimpeachable integrity. We all know the difference between what is right and what is a compromise. Admittedly, sometimes a compromise is needed, but this compromise must be a short-term concession to achieve the larger goal.

This process takes time—lots and lots of time—so the process safety leader must have patience. The leader must also be empathetic and supportive. People will want to see the value in their efforts. They may misunderstand the change and its implications or feel that the change is illogical or nonsensical. They will resist change just because it is change. Trust may decrease. Strong managers can force the change and impose their will, but results will be mixed. A good leader will attempt to understand this resistance and take appropriate actions to diffuse it. The strong leader will transform the organization by showing how good the change can be, and people will embrace it, and it will become permanent. 

For more on process safety programs and leadership, go to www.controlglobal.com/0803_ProcSaf.html.

Peter Montagna is the engineering manager at specialty chemicals manufacturer King Industries, Norwalk, Conn.

The Devilish Details

It’s not enough to show leadership. A good safety program requires specifics. The framework for a robust process safety program can be found in the Occupational Safety and Health Administration’s regulation, “Process Safety Management of Highly Hazardous Chemicals,” or PSM. The full regulation can be found in the Code of Federal Registry under 29 CFR 1910.119 and is available through OSHA website at www.osha.gov.

Recently PSM has come under scrutiny from the U.S. Chemical Safety Board for its lack of application and inadequate coverage of reactive chemical hazards. (See Item 2 in the “Leadership and Process Safety Resources” sidebar.) It’s true that the applicability section of the regulation gives very specific details on where PSM applies in a plant. As a result, companies can avoid these requirements by reducing the use of hazardous materials. However, companies can also use the regulation, without regard to applicability, to develop and implement a comprehensive process safety program—and they should. These requirements, when implemented effectively, will prevent process safety incidents, even reactive chemical hazards.

Reactive chemical hazards are an integral part of the PSM section on process safety information. If a company is serious about process safety, it will evaluate reactive chemical hazards. Accredited laboratories will perform tests, such as accelerated rate calorimetry (for evaluating heats of reaction) and differential scanning calorimetry (for evaluating thermal stability), at a reasonable price. Instructions and controls can then be put in place to prevent incidents.

A significant and often overlooked area of process safety includes equipment reliability. The requirements of the PSM section on mechanical integrity are extensive especially due to the following requirement: “1910.119(j)(4)(ii), Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.”

This simple statement means that several “recognized and generally accepted good engineering practices” (RAGAGEP) apply to chemical processing. These practices are developed by agencies such as the American Petroleum Institute, the American Society of Mechanical Engineers, ISA, the American National Standards Institute and others. ( Table 1 online at www.controlglobal.com/0803_ProcSaf.html has a list of some of the more significant RAGAGEPs.)

Leadership and Process Safety Resources

• Bennis, W. G. and Bennis, W., On Becoming a Leader: The Leadership Classic—Updated and Expanded, New York, N.Y., Basic Books, 2003.
• Goleman, Daniel, Annie McKee and Richard E. Boyatzis., Primal Leadership: Realizing the Power of Emotional Intelligence, Harvard Business School Press, Boston, 2002. 
• Incident Data. Reactive Hazard Investigation,” U.S.Chemical Safety Board. www.csb.gov/completed_investigations/docs/ReactiveIncidentDataReport.pdf
• Kotter, John, What Leaders Really Do, Harvard Business School Press, Boston, 1999.

29CFR1910.119 Process Safety Management of Highly Hazardous Chemicals

1. Application – A process is covered if it contains one of the materials listed in Appendix A of 1910.119 above the threshold quantity, or if it contains at least 10,000 lbs of flammable materials. A detailed definition of “process” is provided in 1910.119(a) and in written clarifications available through OSHA’s web site.
2. Employee Participation – Hourly employees must be involved in many areas of the program, such as development of operating procedures, process hazards analyses and incident investigations.
3. Process Safety Information – The chemicals involved in the process, how those chemicals are processed and the equipment used must be thoroughly documented.
4. Process Hazards Analysis – A detailed analysis of the process often accomplished through the Hazards and Operability methodology (other methodologies can be used; see 1910.119(e)). This is a proactive review of process hazards.
5. Operating Procedures – Detailed instructions on how to operate process equipment. This section also requires safe work practices such as lockout/tagout, confined space entry and other maintenance-related tasks.
6. Training – Specific requirements for operators are detailed, along with implied training requirements for mechanics servicing process equipment.
7. Contractors – The activities of contractors working in process areas must be thoroughly reviewed and controlled to prevent them from creating a process incident and to ensure their safety should an incident take place.
8. Pre-startup Safety Review – A new or significantly modified system must be thoroughly reviewed prior to the introduction of chemicals to prevent an incident during startup.
9. Mechanical Integrity – A comprehensive program must be developed to ensure the ongoing integrity of process equipment. This section of PSM is highly comprehensive and requires familiarity with many different “recognized and generally accepted good engineering practices” (RAGAGEP). Mechanical integrity includes requirements for:
    • Engineering standards or equipment design guidelines,
    • Maintenance procedures detailing equipment installation and ongoing maintenance guidelines,
    • Maintenance technician qualifications,
    • Inspection, testing and preventive maintenance of plant equipment, 
    • Quality assurance (ensuring maintenance materials used in the process area are adequate for the process demand).
10. Hot Work Permits – A system must be developed and implemented to control any maintenance work in the process areas that involves a source of ignition.
11. Management of Change – Any changes to materials, how those materials are processed or the equipment used in the process must be reviewed prior to the change taking effect to ensure the change will be safe.
12. Incident Investigation – After an incident, a thorough review of that incident must take place that identifies root causes and recommendations to prevent that incident from occurring again (within the process area affected by the incident AND throughout the facility or company).
13. Emergency Response – Procedures must be developed to ensure the health and safety of those personnel responsible for responding to any process safety incident.
14. Compliance Audits – The PSM system must be thoroughly reviewed at least once every three years.
15. Trade Secrets – The hazards of materials involved in a process must be communicated to all affected employees even if the specific identity of the material is kept from the employees. Visit http://www.osha.gov/ for details.