Improved management practice and process hazard analysis techniques for minimizing likelihood of process safety incidents in Taiwan

In Taiwan, process safety accidents often occur despite the prior implementation of process hazard analysis (PHA). One of the main reasons for this is the poor quality of the PHA process; with the main hazards not being properly identified, or properly controlled. Accordingly, based on the findings of 86 process safety management (PSM) audits, dozens of post-accident site resumption review meetings, and hundreds of PSM review sessions, this study examines the main deficiencies of management practice and PHA implementation in Taiwan, and presents several recommendations for improved PHA assessment techniques and procedures. The study additionally examines the feasibility for using PSM-related information, such as process safety information and process incident information, as a tool for further enhancing the PHA quality. Overall, the study suggests that, in addition to following the basic rules of PHA and requirements of OSHA (1992),management in Taiwan should also provide training in the enhanced assessment techniques proposed herein and take active steps to incorporate PSM information into the PHA framework in order to improve the general quality of PHA and reduce the likelihood of process safety accidents accordingly.     

Ensuring emergency planning & response meet the minimum Process Safety Management (PSM) standards requirements

When incidents happen and the consequences are not mitigated effectively, one of the indicated failures consists of ineffective emergency planning and response (EPR). EPR is an important aspect of the Process Safety Management (PSM) Standards, and the guidelines are stated in CFR 1910.119 (n) which explains the minimum elements of emergency response and procedures in handling emergency or small releases. Despite its implementation in 1992, CSB finds ineffective EPR system in certain accidents such as the Missouri DPS Enterprise Chlorine Gas Release accident in 2002. DPS EPR failed in planning on location of emergency equipment and accessibility. Many other accidents have occurred throughout the decade and even though organizations have their own EPR system, there are issues in meeting minimum PSM requirements. There also exists the problem of self-regulatory policies practiced by organizations, which might not meet these requirements as well. To help organizations meet these minimum requirements, the purpose of this paper is to present a structured and easy technique to plan and implement EPR as per PSM requirements. A model has been developed based on this technique, and its application has been tested as a case study in a refinery in Malaysia and discussed throughout this report. The results reflected the feasibility of this model as it helped users to track and manage documents efficiently. This technique has the potential to help users to manage EPR better and to reduce adverse impacts to people, environment and assets.     

A comparative analysis of process safety management (PSM) systems in the process industry

The root cause of most accidents in the process industry has been attributed to process safety issues ranging from poor safety culture, lack of communication, asset integrity issues, lack of management leadership and human factors. These accidents could have been prevented with adequate implementation of a robust process safety management (PSM) system. Therefore, the aim of this research is to develop a comparative framework which could aid in selecting an appropriate and suitable PSM system for specific industry sectors within the process industry. A total of 21 PSM systems are selected for this study and their theoretical frameworks, industry of application and deficiencies are explored. Next, a comparative framework is developed using eleven key factors that are applicable to the process industry such as framework and room for continuous improvement, design specification, industry adaptability and applicability, human factors, scope of application, usability in complex systems, safety culture, primary or secondary mode of application, regulatory enforcement, competency level, as well as inductive or deductive approach. After conducting the comparative analysis using these factors, the Integrated Process Safety Management System (IPSMS) model seems to be the most robust PSM system as it addressed almost every key area regarding process safety. However, inferences drawn from study findings suggest that there is still no one-size-fits-all PSM system for all sectors of the process industry.     

The effectiveness of U.S. OSHA process safety management inspection – A preliminary quantitative evaluation

This study attempted to evaluate the inspection effectiveness of the U.S. OSHA process safety management (PSM) standard using statistical correlation test. A total of 6578 citations of past 1277 OSHA PSM inspections from 1992 to 2006 were quantitatively compared with the findings of the U.S. Chemical Safety and Hazard Investigation Board (CSB) investigations on root and contributing causes of 19 major chemical accidents. Nonparametric Spearman's coefficient of rank correlation tests showed a moderately strong agreement between OSHA PSM inspection citations and CSB findings at p < .01 significant level, and the degree of agreement increased with time. These results suggested that past OSHA PSM inspections had cited the problems that were the accident root causes, and the effectiveness of PSM citations has been improved as more inspections were conducted since the standard promulgation. However, factors such as standard coverage, inspection frequency, inspection resources allocation, and inspection strategy, were critical for effective PSM standard enforcement and implementation. Future studies should include more aspects of PSM citations and CSB accident investigation data for better evaluation of inspection effectiveness. The results may be valuable to the PSM enforcement policy makers.     

A rising tide raises all boats: Regional promotion of process safety through joint government/industry management

With the development of increasingly complex processes and technologies in chemical and manufacturing industries, Process Safety Management (PSM) has been globally recognized as the primary tool for operating companies to reduce process accidents on their industrial sites and the risks posed to their employees and surrounding communities. Yet, industrial facilities are often interdependent and collocated with others. Recognizing this, regional authorities are also applying PSM principles to reduce the cumulative incidents associated with high density industrial areas and the multiplicative risks posed to broader communities. This paper compares Strathcona County Emergency Service (SCES) in Alberta, Contra Costa County Health Service Hazard Material Programs (CCCHSHMP) in California, and Technical Standards & Safety Authority (TSSA) in Ontario and their PSM systems to provide practical recommendations to improve SCES's system. Four aspects of PSM are considered: regulation and guidance, auditing and inspection, annual performance indicators, and public participation. Based on the results of this comparison, we recommend that SCES develop comprehensive PSM regulations based on CSA Z767-17 PSM including clear instructions for assessing technologies and methodologies for consequence analysis. Both worst-case scenarios and alternative scenarios need to be considered as well as the domino effect of primary accidents. Furthermore, regular audits and inspections will ensure compliance with PSM regulations while helping the design of planning, performing, and following-up strategies to ensure effectiveness. In addition, we suggest the use of lagging and leading performance indicators to evaluate the performance of the PSM program. Finally, we recommend using advisory councils or commissions to increase public participation and ensure the representation of stakeholders' perspectives with the PSM system.     

Process Safety Management (PSM) for managing contractors in process plant

Accidents involving contractors continue to occur with regular frequency. By using the standard set within the PSM 29 CFR 1910.119(h) regulations, it has been identified that certain aspects of the way contractors do work are not up to the stipulated regulatory requirements especially regarding matters like not providing mandatory personal protective equipment (PPE) to the workers, not discussing hazards related to handling procedures with the workforce and improper control of non-routine activities during changes in shifts. The PSM 29 CFR 1910.119(h) regulations promulgated in 1992 provides standards that covered processes to obtain and evaluate data regarding contractors' health and safety programs as well as the contractors' performance evaluation. Many of the accidents involving contractors are direct result of poor training of contractors and/or poor control of the contracted work. Even though most organizations have their own contractor management systems, there are issues in meeting the requirements of PSM. The PSM standard only state “what to do” not “how to do it”. This is known as self-regulatory policy which depends on the industries understanding to interpret the standard that also contribute to this problem. This paper presents a structured and easy technique to plan and implement a practical and comprehensive contractors' management system in process industries that will comply with OSHA CFR 1910.119. A model has been developed based on this technique and its application has been tested in a pilot plant for compliance to PSM regulation. The model is beneficial to the process industries as any deficiencies in the PSM contractors' management program will be highlighted by the model which will then easily correct the identified deficiency so as to minimize and prevent catastrophic accidents.     

The effective control of major industrial accidents by the Major Industrial Accident Prevention Centers (MAPC) through the Process Safety Management (PSM) grading system in Korea

This paper examines effectiveness of a regulatory enforcement organization (Major industrial Accident Prevention Center, MAPC), and a grading system for implementation of the Process Safety Management (PSM) regulation in Korea. A lot of chemical installations have been built in Korea since the 1960s. The frequent occurrence of major industrial accidents had made people's concerns grow. The Korean government enacted PSM regulations in 1996 in order to curb these accidents.However, a key question is how to make sure companies comply with the PSM regulations. In order to improve company’ compliance with PSM regulations the Ministry of Employment and Labor (MOEL) responsible for the regulation introduced a grading management system in 2001 and then established special supervisory centers for enforcement of PSM regulations in 2005. This paper reviews the role and effectiveness of the system in term of PSM enforcement. The author found that the grade-based approach has encouraged employers to implement the requirements of the PSM regulations. MAPCs play an effective role in enhancing enforcement performance. Although the more chemical plants have been established in Korea, the fewer major industrial accidents have occurred since the introduction of the system. The results may be useful for the policy maker to build an effective and efficient enforcement system.     

Guidance to improve the effectiveness of process safety management systems in operating facilities

The Process Safety Management (PSM) systems at the operating facilities in the Oil & Gas and in Chemical manufacturing industries have matured over the years and have become, at most facilities, very robust and sophisticated. These programs are administrated by Process Safety (PS) teams at both the corporate business units and plant levels and have been effective in reducing the number and severity of PS events across the industries over the past 25 years or so. Incidents however are occurring at a regular interval and in recent times several noteworthy PS events have occurred in the United States which have brought into question the effectiveness of the PSM programs at play. These facilities have been applying their PSM programs with the expectation that the number and severity of PS events would decrease over time. The expected result has not been realized, especially in context to those facilities that have undergone the recent incidents. Current paper reviews a few publicly available PS performance reports of Oil & Gas and Chemical manufacturing industries. The authors identified a few factors at play that have led to these PS events based on their experience, literature review, and incident investigation reports. Most of the factors are intertwined with multiple PSM elements and it requires a holistic approach to address them. Each of the factors is described and the path forward is proposed to improve the effectiveness of PSM programs.     

Factors contributing to US chemical plant process safety incidents from 2010 to 2020

Process safety incidents can result in injuries, fatalities, environmental impacts, facility damage, downtime & lost production, as well as impacts on a company's and industry's reputation. This study is focused on an analysis of the most commonly reported contributing factors to process safety incidents in the US chemical manufacturing industry. The database for the study contained 79 incidents from 2010 to 2019, partly investigated by the Chemical Safety Board (CSB). To be included in the study, the CSB archive of incident investigations were parsed to include only incidents which occurred at a company classified as 325 in the North American Industry Classification System (NAICS), assigned to businesses that participate in chemical manufacturing. For each incident, all of the identified contributing factors were catalogued in the database. From this list of identified contributing factors, it was possible to name the ‘top three’ contributing factors. The top three contributing factors cited for the chemical manufacturing industry were found to be: design; preventive maintenance; and safeguards, controls & layers of protection. The relationship between these top contributing factors and the most common OSHA citations was investigated as well. The investigation and citation history for NAICS 325 companies in the Occupational Safety & Health Administration (OSHA) citations database was then analysed to assess whether there was any overlap between the top reported contributing factors to process safety events and the top OSHA citations recorded for the industry. A database consisting of the inspection and citation history for the chemical manufacturing industry identified by NAICS code 325 was assembled for inspections occurring between 2010 and 2020 (August). The analysis of the citation history for the chemical manufacturing industry specifically, identified that the list of the top contributing factors to process safety incidents overlapped with the most common OSHA violations. This finding is relevant to industry stakeholders who are considering how to strategically invest resources for achieving maximum benefit – reducing process safety risk and simultaneously improving OSHA citation history.     

Enhancing regional process safety management

As industrial operations expand, major incidents continue to affect people, damage facilities, and impact the environment. In the last 20 years, about 50% of these incidents occurred in facilities that had implemented some form of Process Safety Management (PSM) and 50% came about in smaller facilities that did not include such planning (Demichela et al., 2004). The objective of this article is to use PSM principles to create practical recommendations at the regional level, to complement those previously developed for singular facilities. This article compares Strathcona County Emergency Service (SCES) in Alberta with Technical Standards & Safety Authority (TSSA) in Ontario, with respect to safety, facility licensing, permit requirements, risk assessment procedures and land use planning aspects to determine PSM enhancements for SCES. Furthermore, for a better overview, two supplemental provincial organisations in Alberta, namely Alberta Boiler Safety Association (ABSA) and Safety Codes Council (SCC), were also considered. We proposed that SCES could develop more detailed facility-specific licensing procedures, auditing, and inspection. SCES could also provide details of accredited organisations that carry out inspections and audits on their behalf. When reviewing the quantitative risk assessment processes for SCES and TSSA, we recommend that SCES should update their probability data sources used in their cumulative risk assessment study. Based on the authors’ experience and gathered data, the use of additional facility practices such as safety management system, internal audits, and checklists can enhance incident prevention.     

Korean experience of process safety management (PSM) regulation for chemical industry

From the 1960s, Korean industries have been encouraged by the government to nurture heavy and chemical industry and to modernize the economics and industrial structures. The development of chemical industry particularly became the turning point in industrial development, and played a major role in the construction of a new industrialized country. However, the process systems in the chemical industry have become more complex and larger, and the inventories of dangerous chemicals that are produced or consumed have continuously increased. Therefore, the hazards from potential accidents such as fire and explosion or release of toxic chemicals have also increased. In fact, from the end of 1980s to the beginning of 1990s in Korea, a number of major industrial accidents such as ABS extruder explosion, TDI release and dryer explosion, etc. Occurred and caused many fatalities. As the chemical companies recognized the importance of preventing major hazards, PSM system, the prevention of major industrial accidents, was introduced in January 1995 by amending Industrial Safety and Health Act, and it has been enforced from January 1, 1996. According to the law, the business owner of a workplace with hazardous or dangerous equipment shall submit a process safety report to the Government to prevent any accidents, which could inflict an immediate damage on workers or on areas in the vicinity of the workplaces. As a result of PSM implementation for 19 years, chemical accident prevention system has been stabilized and various kinds of effectiveness and desirable customer satisfaction have been made.     

Migrating an incident reporting system to a CCPS process safety metrics model

A major chemical company established a formal incident investigation and reporting system several years ago. The original system focused heavily on worker-related injuries, illnesses, and near-misses and was used primarily to track statistics reportable to the Occupational Safety and Health Administration (OSHA). This Occupational Injury and Illness (OII) approach has been recognized to be an ineffective tool for measuring, predicting, and preventing process safety incidents. The Center for Chemical Process Safety (CCPS) recently published guidelines on how to establish safety metrics for the measurement and reduction of process safety incidents. The process safety metrics approach relies upon leading and lagging metrics to improve organization process safety. This paper is a case study of the analysis of one organization’s incident database, which represents approximately five years of data from over a dozen facilities. The aim of this investigation was to extract useful process safety metrics from the incident investigation and reporting system, which would be pertinent to the types of process units and process functions at these facilities. This paper will discuss the approach taken to extract process incident information from an OII-based database and present the difficulties of performing an analysis on such a database. This paper provides guidance on how to migrate an existing OII-based reporting system to a program that includes process safety metrics in accordance with industry best practices.     

Risk assessment and risk reduction of an acrylonitrile production plant

Reducing accident occurrence in petrochemical plants is crucial, thus appropriately allocating management resources to safety investment is a vital issue for corporate management as international competition intensifies. Understanding the priority of safety investment in a rational way helps achieve this objective.In this study, we targeted an acrylonitrile plant. First, Dow Chemical's Fire and Explosion Index (F&EI) identified the reaction process as having the greatest physical risk. We evaluated the severity of accidents in the reaction process using the Process Safety Metrics advocated by the Center for Chemical Process Safety (CCPS); however, this index does not express damages a company actually experience. To solve this problem, we proposed a new metric that adds indirect cost to CCPS metrics. We adopted fault tree analysis (FTA) as a risk assessment method. In identifying top events and basic events, we attempted to improve the completeness of risk identification by considering accidents from the past, actual plant operation and equipment characteristics, natural disasters, and cyber-attacks and terrorist attacks. Consequently, we identified the top events with high priority in handling because of serious accidents as fire/explosion outside the reactor, fire/explosion inside the reactor, and reactor destruction. The new CCPS evaluation index proposed in this study found that fire and explosion outside the reactor has the highest severity. We considered the creation of the fault tree (FT) diagram of the top event, estimating the occurrence probability, and identifying the risk reduction part and capital investment aimed at risk reduction. As an economically feasible selection method for risk reduction investment, using the difference in loss amounts before and after safety investments indicated investment priority.     

Lessons learned for process safety management in China

A number of chemical accidents have occurred in China over the past two decades with significant impact on humans and the environment. It is expected that lessons will have been learned from these accidents that will help industries to reduce the risk that catastrophic chemical accidents occur in future. In fact, to some extent there is evidence that lessons have been learned, to the extent that the Chinese government has substantially strengthened legislation and regulatory standards. Nonetheless, there remains a concern that much more still needs to be done to reduce chemical accidents risks in China. Important progress in this area requires not only government support but a commitment across all hazardous industries to learn from past accidents that may in many cases require establishment or considerable improvement of their safety management systems. To assist small and medium-sized enterprises (SMEs), in this effort, results of an analysis of common causes of the chemical accidents reported in the Major Accident Information (MAI) website of Chinese State Administration of Work Safety (SAWS) are presented in this paper In particular, inadequate process hazard analysis (PHA), training and emergency response planning (ERP) were identified as the top three process safety management (PSM) elements that contribute to most of the SMEs accidents in China. Seven recommendations are proposed in order to improve the effectiveness of lesson learning for government agencies and SMEs.     

Process safety challenges for SMEs in China

While process safety regulations and standards have been in place in western countries for more than two decades, China has only recently started to officially embrace these issues with the adoption of its Process Safety Management (PSM) regulation AQ/T 3034-2010 (SAWS, 2010). However, compliance with this regulatory framework requires substantial resources and may therefore appear too complex to be efficiently implemented by small and medium sized enterprises (SMEs) in the chemical sector. This is of particular relevance as about 99% of chemical companies in China are SMEs, accounting for more than 80% of all chemical accidents. To address this issue, additional local regulations and planning activities related to process safety have been implemented in China, including the establishment of hundreds of chemical industry parks. Some of the process safety problems faced by chemical industry parks are identified and discussed in this paper. To help solve these problems, UNEP's “Responsible Production approach for Chemical Hazards Management along the Value-Chain” is introduced in this paper and suggested as a simplified PSM approach targeted specifically at SMEs which, regardless of handling hazardous chemicals in their daily operations, may not have the knowledge or capacity to efficiently implement PSM and may not fall in the scope of the PSM regulation AQ/T 3034-2010. By introducing PSM to SMEs in a more manageable way, relevant steps can be progressively implemented by companies towards full compliance with the current regulatory framework, contributing to increased safety in chemical industry parks in China.     

Ergonomic Program Effectiveness: Ergonomic and Medical Intervention

The implementation of a successful ergonomic and medical intervention program designed to reduce the number and severity of injuries and illnesses and the associated levels of discomfort in the workplace is presented. Because of the recent activity concerning the on-again-off-again Occupational Safety and Health Administration (OSHA) Ergonomic Program Standard questions have been raised as to the value and effectiveness of an organization’s ergonomics program. In light of these concerns, the immense cost associated with work-related injury and illness, and the related pain and suffering associated with such injuries and illnesses, it is important to present a workable and effective ergonomic and medical intervention program. The results of this applied study demonstrate that through the application of an ergonomic and medical intervention program, workplace-related injuries and illnesses can be reduced or eliminated.     

The effectiveness of process safety management (PSM) regulation for chemical industry in Korea

From the 1960s, Korean industries have been encouraged by the government to nurture heavy and chemical industry and to modernize the economics and industrial structures. The development of chemical industry particularly became the turning point in industrial development, and played a major role in the construction of a new industrialized country. However, the process systems in the chemical industry have become more complex and larger, and the inventories of dangerous chemicals that are produced or consumed have continuously increased. Therefore, the hazards from potential accidents such as fire and explosion or release of toxic chemicals have also increased. In fact, from the end of 1980s to the beginning of 1990s in Korea, a number of major industrial accidents such as ABS extruder explosion, TDI release and dryer explosion, etc. occurred and caused many fatalities. As the chemical companies recognized the importance of preventing major hazards, PSM system, the prevention of major industrial accidents, was introduced in January 1995 by amending Industrial Safety and Health Act, and it has been enforced from January 1, 1996. According to the law, the business owner of a workplace with hazardous or dangerous equipment shall submit a process safety report to the Government to prevent any accidents, which could inflict an immediate damage on workers or on areas in the vicinity of the workplaces. As a result of PSM implementation for 7 years, various kinds of effectiveness have been made. Accident rate including number of fatalities has been decreased, and productivity has been increased as well as product quality.     

Leadership skills for strengthening jobsite safety climate

Introduction: Construction foremen may lack the leadership skills needed to create a strong jobsite safety climate. Many construction companies address this by sending their lead workers to the OSHA 30-h course; however the course does not include a leadership training module. This article describes the development and pilot testing of such a module and evaluation surveys designed to address this training gap. Methods: A 17-member curriculum development team, numerous subject matter experts, and an instructional design company helped us develop a comprehensive set of teaching resources and a set of survey instruments for evaluating the materials' effectiveness on improving safety leadership and safety climate. All materials and surveys were pilot tested with representative members of the target population. Results: Pilot surveys showed high reliability and data collected on the resulting Foundations for Safety Leadership (FSL) module indicated that the majority of foremen thought the training was helpful or valuable, particularly the discussion questions. The majority said they intended to use the skills on the jobsite. With the exception of the role-play activities, the trainers rated highly all other components, especially the videos and discussion questions. Modifications were made to the training materials and surveys based on pilot test findings. The most important result of the development and pilot testing efforts is that the OSHA Training Institute (OTI) included the FSL as an elective in the OSHA 30-h course. Conclusions: The FSL module fills a needed skills gap by providing safety leadership training to all foremen who might otherwise not have access to it through their company or union. The continued success of the FSL training will be ensured by dissemination via the OSHA 30-h course, an established nationwide safety training program. Practical applications: The FSL training module has already been widely accepted by the construction industry as a useful approach for providing construction foremen/See new abstract lead workers with the knowledge and skills they need to become more effective jobsite safety leaders.     

Under-recording of work-related injuries and illnesses: An OSHA priority

IntroductionA 2009 Government Accounting Office (GAO) report, along with numerous published studies, documented that many workplace injuries are not recorded on employers' recordkeeping logs required by the Occupational Safety and Health Administration (OSHA) and consequently are under-reported to the Bureau of Labor Statistics (BLS), resulting in a substantial undercount of occupational injuries in the United States.MethodsOSHA conducted a Recordkeeping National Emphasis Program (NEP) from 2009 to 2012 to identify the extent and causes of unrecorded and incorrectly recorded occupational injuries and illnesses.ResultsOSHA found recordkeeping violations in close to half of all facilities inspected. Employee interviews identified workers' fear of reprisal and employer disciplinary programs as the most important causes of under-reporting. Subsequent inspections in the poultry industry identified employer medical management policies that fostered both under-reporting and under-recording of workplace injuries and illnesses.ConclusionsOSHA corroborated previous research findings and identified onsite medical units as a potential new cause of both under-reporting and under-recording. Research is needed to better characterize and eliminate obstacles to the compilation of accurate occupational injury and illness data.Practical applicationsOccupational health professionals who work with high hazard industries where low injury rates are being recorded may wish to scrutinize recordkeeping practices carefully. This work suggests that, although many high-risk establishments manage recordkeeping with integrity, the lower the reported injury rate, the greater the likelihood of under-recording and under-reporting of work-related injuries and illnesses.     

Process safety management lessons learned from a fire and explosion accident caused by a liquefied petroleum gas leak in an aromatics reforming unit in Taiwan

A severe fire and explosion accident was caused by a liquefied petroleum gas leak in Taiwan in 2019. This accident resulted in the loss of approximately US$3.5 billion in output value due to a one-and-a-half-year shutdown after the accident; however, no casualties were recorded at the accident scene. An analysis of the accident pipelines demonstrated that the pipeline leak had been caused by hydrochloric acid corrosion. Cause analysis based on the accident timeline, fault tree analysis, and causal factor charting indicated inadequacies in five elements of process safety management (PSM) namely mechanical integrity (MI), management of change, emergency planning and response, process hazard analysis (PHA), and process safety information (PSI) as the root causes of the accident. Furthermore, insufficient PSI (i.e., a lack of comprehensive understanding regarding corrosion mechanisms) was deemed to have been the core problem leading to the accident. This accident revealed common shortcomings that are often overlooked in PSM implementation in Taiwan; thus, the present research can serve as a vital reference for improving PSM programs in Taiwan.