This article was printed in CONTROL's May 2009 edition.
Sorry for the bad news, but if you want a useful process safety solution for your application or plant, you still have to do it yourself. Sure, there are plenty of guidelines, suggestions recommendations, scolding and warnings. However, there are few willing to co-sign your loan application, so to speak. True partners and friends are hard to find.
I checked out a bunch of the latest rules and standards while researching this issue’s cover story on practical process safety, “Take Your Medicine,” and what I found was pretty depressing. Most government regulations on process safety, such as the U.S. Occupational Safety and Health Administration’s Process Safety Management (PSM) standard 29 CFR 1910.119 remain curiously un-prescriptive and seem to rely too much on enforcement after accidents occur. Likewise, many process safety standards, such as the International Electrotechnical Commission’s 61511 standard that mirrors the International Society of Automation’s S84, are growing increasingly detailed. However, I noticed almost every other word in them was “shall” or “should,” but there wasn’t much saying, “If you have this size distillation column, running at this temperature, then you ought to use this type of safety device.”
In short, everyone tells users what to do, but almost nobody tell them precisely how to do it. Sadly, making recommendations and washing your hands isn’t much help. And the other old method of leaving these dilemmas up to the litigators is even worse.
If I were a small refinery engineer or operator, I’d read all this stuff (in my loads of spare time), throw up my hands, and yell, “What the bleep am I supposed to do now!?” Or, more likely, just keep on keeping my head down, and hope no one notices that I haven’t updated my hazop, done a risk assessment lately, calculated SIL levels or retrained my staff.
I’ve heard more than once that many plants have e-stop buttons, but no one would ever press them because whoever does it gets fired. The old idea that process safety is a drag on production and short-term profits is alive and well, despite all the sunny assertions that, “Safety doesn’t cost. It pays.” This is true, too, but it’s hard to get operators to believe it, especially when their managers are excessively focused on satisfying company shareholders and Wall Street analysts.
So why would enlightened individuals and intelligent organizations leave the real teeth of process safety regulation out until after an incident happens? Many experts I’ve interviewed protest that they can’t be specific because all process industries and applications are unique. Admittedly, there is no one-size-fits-all process safety, but I’d bet there’s enough common equipment and devices being used in the same way for standards and regulatory experts to draft some more specific and helpful rules. In fact, some major oil and gas firms offer consulting services to smaller firms and facilities on how to implement process safety in their applications. Why not let everyone in on the secret?
The old knock against this is that speaking up in specific terms about process safety will give ammunition to any potential plaintiff. So the best news lately is that some users and their legal departments seem to be coming around to the idea that a thorough risk assessment that’s consistently applied is a more defensible position that the say-nothing strategy of the past. Likewise, online resources from the Center for Chemical Process Safety, U.S. Chemical Safety and Hazard Investigation Board, Mary Kay O’Conner Center for Process Safety Center, American Petroleum Institute, and the Voluntary Protection Programs Participants’ Association are growing steadily better as well. So, though the ultimate responsibility still rests on the user there’s no reason you can’t get help where you can find it. Good luck.