PSM

Process Safety
Management (PSM)
N. Sanei
October 2017
Lessons Learned from Major Accidents
 A series of major accidents on chemical process sites

across the world have occurred, even though many companies
are seeking continuous improvement of process safety;
 Both private and public organizations, including

government agencies, have become more and more concerned
with the issue of the safety of the industrial operations;
 Aggressive legislative and regulatory process safety

initiatives forcing a reduced public risk tolerance;
All these facts lead to the fact:

There is a need for a special management system based
on a clear strategy, i.e. a PSM;
Definitions
 Process
A process is a combination of the utilities, raw materials, and
human actions (direct actions and those actions involving
programming the process to accomplish automatic functions);
 Process Safety Management (PSM)

Process Safety Management (PSM) is a management system
that is focused on prevention of, preparedness for,
mitigation of, response to, and restoration from catastrophic
releases of chemicals or energy from a process associated
with a facility;
Significance of Process Safety Management
 A Safety Management System

is a constituent part of the overall management system of
the establishment, which may in turn be dependent on a
management system developed for a larger entity such as a
company or group of companies;
This is particularly important when it comes to detailed
implementation of the guidelines to be set out;
The approach to implementation will and should differ from
company to company, reflecting the overall management
philosophy, system, and culture as appropriate for the
workforce and the process technologies involved;
Significance of Process Safety Management
 A Safety Management System

may also involve integration with a management system which
addresses other matters, such as the health of workers, the
environment, quality, etc.;
It is possible to develop a Safety Management System by
extending the scope of an existing management system, but
it will be incumbent upon the operator to ensure, and
demonstrate where necessary, that the management system
has been fully developed to cover major-accident controls
and meets the requirements;
Meaning of a Management System
 What is a management system?

A management of any sizeable activity is based on the idea
of a “Management Loop”, which involves Agreeing on an
objective, Defining a plan to achieve that objective,
Formulating the detailed work required to implement the
plan, Carrying out the work, Checking the outcome against
the plan, and Planning and Taking appropriate corrective
action;
A Safety Management System is no exception to this
general principle;
Historical Approach
 Europe: Seveso Directive (Onshore)

The Flixborough accident was the spark starting discussion
about a European common approach to industrial major
accidents:
Some years after the Seveso accident and 8 years after the
Flixborough accident approval of the Major Accident
Hazard Directive EEC/501/82A (Seveso I) took place;
The Directive was amended twice in 1987 and in 1988 to
incorporate lessons from two accidents: Bhopal (1984) and
Basel (1986), in 1996 a new Directive (96/82/EC the so
called Seveso II) was introduced and put into force;
Finally the Seveso III Directive 2012/18/EU of the
European Parliament and Council on the control of Major
Accident Hazards involving dangerous substances entered
into force on 13 August 2012; accordingly the EU member
states are required to implement it into national legislation
from the 1st of June 2015;
Historical Approach
 USA: OSHA PSM / EPA-RMP (Onshore)

In 1992, the federal Occupational Safety and Health
Administration (OSHA) promulgated a standard for Process
Safety Management of Highly Hazardous Chemicals;
In the U.S., the OSHA PSM (OSHA 29 CFR Part 1910)
Regulation and EPA (Environmental protection agency) Risk
Management Program Rule (RMP), amended by the U.S.
congress, are the primary pieces of federal legislation and
are very extensive;
Any facility that stores or uses a defined "highly hazardous
chemical" must comply with OSHA's Process Safety
Management (PSM) and EPA-RMP regulations;
Historical Approach
 Center for Chemical Process Safety (CCPS)

In 1989, CCPS published its Guidelines for Technical
Management of chemical Process Safety, which outlined a
12-element strategy for organizations to consider when
adopting management systems to ensure process safety in
their facilities;
This strategy was up-dated in 2008 and expanded to reflect
an emphasis on a risk-based process safety management
comprising a 20-element strategy;
Historical Approach
 Chronology, North America

1985:
 The American Institute for Chemical Engineers (AIChE)

forms the Center for Chemical Process Safety (CCPS);
 The Chemical Manufacturers Association (CMA) creates
the Community Awareness Response Program (CAER) as a
result of Bhopal, also CAER was initiated by the Canadian
Chemical Producers' Association (CCPA);
1990:
 The American Petroleum Institute (API) - Recommended

Practice # 750: Management of Process Hazards;
 US Environmental Protection Agency (EPA) - The Clean
Air Act (CAA);
Historical Approach
 Chronology, North America (cont’d)

1992:
 US Occupational Safety and Health Administration

(OSHA) - 29 CFR 1910.1 19: Process Safety Management
of Highly Hazardous Chemicals and Blasting Substances;
1996:
 EPA - 40 CFR Part 68: “Accidental Release Prevention

Requirements”: Risk Management Program under CAA,
Section 1 12(r)(7), i.e. the RMP;
2010:
 BOEMRE has issued its rule for the implementation of an

offshore "Safety and Environmental Management System
(SEMS)" as part of 30 CFR Part 250 (based on API 75);
Historical Approach
 Chronology, Europe (EU Member States)

Seveso I Directive (1982):
 Seveso I Directive (1982) was based on Article 174 of EC

Treaty;
 Identification of installation concerned (based on
substance and quantities handled);
 Operator provides safety report to authorities;
 Emergency Response Plan (ERP) must be established;
 Community Awareness of Risks and Emergency Response
Plan;
 Accident notification procedures;
Historical Approach
 Chronology, Europe (cont’d)

Seveso II Directive (1999):
 Seveso II Directive was proposed in December 1996 to

include an extended scope and introduction of:
- Safety management systems;
- Emergency planning;
- Land-use planning;
- Reinforcement of the provisions on inspections;
 Driven by the accident at Seveso, Italy, Seveso I was
amended twice, after accidents at Bhopal, India (1984)
and at Basel, Switzerland (1986);
 Seveso II has fully replaced the original Seveso Directive
as of February 1999;
Historical Approach
 Chronology, Europe (cont’d)

Seveso III Directive (2012):
 The Seveso III Directive 2012/18/EU was put into force

on 13 August 2012; the EU member states are required to
implement it into national legislation as per June 1st 2015;
 Linked directly to the Regulation (EC) No 1272/2008 of
the European Parliament and of the council of 16th
December 2008 on Classification, Labelling and Packaging
of substances and mixtures (CLP), amending and repealing
Directives 67/548/EEC and 1999/45/EC, and amending
Regulation No 1907/2006, aligned with the UN
international chemicals classification (Globally Harmonized
System - GHS);
Historical Approach
 Chronology, UK
Special case in Europe
 The Health and Safety at Work etc. Act 1974:

- Health and Safety Executive (HSE);
- Health and Safety Commission (HSC) - Advisory Committees:
Advisory Committee on Dangerous Substances (ACDS),
Advisory Committee on Toxic Substances (ACTS), Chemical
Industries Forum;
- HSC merged with HSE on April 1, 2008 (now HSE);
 HSE's Safety Policy Directorate: Control of Major
Accident Hazards (COMAH) regulations (1999, latest
revision 2015 to adapt to the new Directive SEVESO III);
 HSE's Health Directorate: Control of Substances
Hazardous to Health (COSHH) regulations (1999, latest
revision 2002);
Different Strategic Approaches
 Evolution of Process Safety and Accident

Prevention Strategies
What should I do? (API RP 750) What do I have to do?
Standards-based Compliance-based
Strategy Strategy
Continuous Risk-based
Improvement-
based Strategy Strategy
How can I improve based How can I better manage

on my exprience? the associated risk?
 Standards-Based Strategy
For a long time, companies were relying just on experienced-
based standards to define their process safety and accident
prevention efforts;
These standards included both internal company practices
and external codes and standards like ANSI, API, NFPA,
ASME, etc.;
Relying just on proven design, operating and maintenance
codes and practices, is good, but not enough, why?
Process Safety Accidents are typically rare, past
experiences give no guarantee for the future;
 Compliance-Based Strategy
In response to the ever increasingly public concerns about
the effects of major accidents in the process industry,
government agencies issued regulations to define minimum
requirements to protect workers, the public and the
environment;
OSHA’s PSM along with the EPA’s RMP rule in the U.S., and
the Seveso II directive are of this kind;
This approach establishes a minimum level, which may be
enough in some cases, but not always;
Regulations are experience-based, consider national resource
constraints, and are not applicable to the facilities lying
under their defined limits;
 SEVESO II Directive
The Seveso II Directive is implemented in the UK as the
COMAH Regulations, came into force in Feb. 1999 and it
improves Seveso I Directive by:
 Emphasizing management factors;
 Introducing a Major Accident Prevention Plan (MAPP);
 Emphasizing that Safety Reports should:
- Address potential hazards;
- Be submitted to credible authorities;
- Consider management and organizational issues;
 Applying provisions to individual installations/to the whole plants;
 Considering effects of an incident on surrounding plants;
 Publishing the reports (after removing confidential information);
 Having Emergency plans:
- With content defined explicitly in Directive;
- That are tested regularly;
 SEVESO II Directive (cont’d)

The directive sets out two levels of requirements
corresponding to ‘lower tier’ and ‘upper tier’ establishments;
There is a requirement for lower tier establishments to
draw up a Major Accident Prevention Policy (MAPP),
designed to guarantee a high level of protection for man and
the environment by appropriate means including appropriate
management systems, taking account of the principles
contained in Annex III of the directive;

The operator of an upper tier establishment (covered by
Article 9 of the directive and corresponding to a larger
inventory of hazardous substances) is required to
demonstrate in the ‘safety report’ that a MAPP and a
Safety Management System (SMS) for implementing it
have been put into effect in accordance with the information
set out in Annex III of the directive;
The major accident prevention policy (MAPP) shall be
established in writing and should include the operator’s
overall aims and principles of action with respect to the
control of major accident hazards;

The major accident prevention policy (MAPP) shall take into
account the following areas:
 Organization and personnel;

 Identification and evaluation of major hazards;
 Operational control;
 Management of change;
 Planning for emergencies;
 Monitoring performance;
 Audit and review;
Each of these areas has to be considered as an element
of the safety management system (SMS) as well;
 SEVESO III Directive

The main structure, especially the elements, are similar, the
main changes can be grouped as follows:
Scope: the categories of dangerous substances in annex 1 will
reflect the new CLP classifications with some new additions
to the named substances category, a mechanism has been
introduced for the assessment of major hazards for a
particular substance to determine, if it should be included or
excluded from scope;
Information to the public: a key aim of the Directive is to
improve the information provided to the public, including
information reported by operators to the competent
authorities ensuring that the public is generally aware of the
activities of an establishment and, more particularly, the
required actions to take in the event of an accident;
 SEVESO III Directive (cont’d)

Land-use planning: Land–use planning applies to both Upper-
and Lower-Tier establishments and to the protection of the
environment, as well as to human health;
Other general changes include:
 Clarification that underground gas storage sites fall within
the Directive's scope;
 Clear references to environmental aspects;
 Elimination of potential for delays in the completion of
external emergency plans;
 Safety management requirements for lower tier
establishments have been made more explicit, and stricter
inspections of all establishments (lower and upper);
 An explicit option to use safety performance indicators
when monitoring the performance of the SMS;
 OSHA/ PSM Guideline

This PSM focuses mainly on the regulative and legislative
aspects:
(1) Employee Participation; (2) Process Safety Information;

(3) Process Hazard Analysis;
(4) Operating Procedures; (5) Training;
(6) Contractors; (7) Pre-Startup Safety Review;
(8) Mechanical Integrity; (9) Hot Work Permit;
(10) Management of Change; (11) Incident Investigation;
(12) Emergency Planning and Response;
(13) Compliance Audits; (14) Trade Secrets
 Continuous Improvement-Based Strategy

Companies recognized just trying to maintain the status quo
in accident prevention was not enough for three reasons:
First, companies found “treading water” in process safety
leads to performance decline;
Second, global market demands higher quality at a lower
cost;
Finally, Companies have to cope with the ever increasingly
expectations of the societies;
 Continuous Improvement-Based Strategy (cont’d)

The strategy utilizes “lagging indicators (learn from
experiences)” to define historical performance and provide
feedback for the management;
This strategy fails due to the fact that: absence of
accidents does not reliably mean that the PSM system is
working well, especially in case of major accidents (low
frequency, high severity);
 Risk-Based Strategy
By using a risk-based process safety management approach,
an organization complies with regulatory requirements,
applies lessons learned from past experiences in a proper way
and continues to use lagging indicators to improve his process
safety program while taking benefits of the proven
standards;
But risk information and leading indicators are studied for a
better assessment helping a more efficient prediction of the
system performance from every aspect independent of any
known loss-event;
Risk-Based Process Safety Management
 Structure of a Risk-Based PSM

Implementing of a risk-based PSM can help organizations
manage the risk of a facility throughout its lifetime;
According to CCPS, such a PSM is based on 4 pillars:
- Commitment to process safety;

- Understanding of hazards and risk;
- Managing risk;
- Learning from experience;
These 4 pillars consist of totally 20 elements;

Risk-Based PSM, Pillars
 Commitment to Process Safety

This pillar comprises of the following elements:
- Process safety culture;

- Compliance with standards, directives
and regulations;
- Process safety competency;
- Workforce involvement;
- Stakeholder outreach;
 Understanding Hazards and Risk

This pillar comprises of the following elements:
- Process knowledge management;

- Hazard identification and risk analysis;
The above-mentioned elements build the structure
of what is called “Process Hazard Analysis (PHA)”;
 Managing Risk
This pillar consists of the following elements:
- Operating procedures;
- Safe work practices;
- Asset integrity and reliability;
- Contractor management;
- Training and performance assurance;
- Management of change (MOC);
- Operational readiness;
- Conduct of operations;
- Emergency management;
 Learning from Experience

And this pillar is made of the following elements:
- Incident investigation;
- Measurement and metrics;
- Auditing;
- Management review and continuous improvement;
Important Terms
 Hazard
A physical, chemical or nuclear condition having potential for
causing harm to people, property or the environment;
Hazard evaluation is the heart of a PSM program, and shall
be performed throughout the life of the facility to help
managing the risk of a process from the earliest stages of
the research and development, in the detailed design stage,
during the construction phase, before commissioning and
periodically throughout the operating life;
Important Terms
 Hazard (cont’d)
Hazard evaluation techniques can also be used:
 To investigate the possible causes of an incident that has

occurred,
 As a part of facility’s management of change program,
 To identify critical safety equipment for special
maintenance, testing, or inspection as a part of the
facility mechanical integrity program;
Important Terms
 Risk
A measure of human injury, environmental damage, or
economic loss in terms of the incident likelihood and the
magnitude of the loss or injury;
Understanding of risk deals with addressing three specific
questions:
 What can go wrong?

 What is the potential impact (i.e. how severe are the
potential consequences)?
 How likely is the loss event to occur?
Process Safety Management, Offshore
 Europe: Offshore Safety Directive (OSD)

In response to the loss of life and environmental damage
caused by the Macondo blowout (Deepwater Horizon Rig) in
the Gulf of Mexico in 2010, the European Commission issued
the Directive 2013/30/EU on the Safety of Offshore Oil
and Gas Operations in June 2013;
Implementation of the Directive (OSD):
 Member states of the European Union were required to

develop a national implementation framework for the
Directive by July 2015;
 Owners and operators will need to comply with the
requirements for new builds from 19 July 2016;
 Existing assets must be brought into line with the new
regulations by 19 July 2018;
 Europe: OSD (cont’d)

The new Directive requires owners and operators to prevent
and mitigate the impact of major accident hazards through
the implementation of a systematic and effective approach
to risk management, in particular:
 Before exploration or production begins, companies
must prepare major hazard reports for offshore
installations, which has to include a risk assessment and
an emergency response plan;
 Operators should reduce the risk of a major accident
as low as reasonably practicable (i.e. ALARP
demonstration), to the point where the cost of further
risk reduction would be grossly disproportionate to the
benefits of such reduction, the reasonable
practicability of risk reduction measures should be
kept under review in the light of new knowledge and
technology developments;
 Europe: OSD (cont’d)

Further:
 Independent verification of technical solutions which
are critical for the safety of operators’ installations
must be conducted including independent verification
pertaining to the safety and environmentally critical
elements (SECEs) identified in the risk assessment for
the installations, i.e. demonstration of adequacy and
effectiveness in view of MAH’s ahead of the CSU;
 A schedule of examination and testing for SECEs shall
be implemented, including independent verification that
this schedule is suitable, up-to-date and operating as
intended;
 National authorities must verify safety provisions,
environmental protection measures, and the emergency
preparedness of rigs and platforms;
 USA: The Workplace Safety Rule

The Bureau of Ocean Energy Management, Regulation and
Enforcement (BOEMRE) has issued its rule for the
implementation of an offshore "Safety and Environmental
Management System (SEMS)" as part of 30 CFR Part 250;
A SEMS is a comprehensive management program for

identifying, addressing and managing operational safety
hazards and impacts, with the goal of promoting both human
safety and environmental protection;
 USA: The Workplace Safety Rule (cont’d)

The Workplace Safety Rule covers all offshore oil and gas
operations in Federal waters (US) and makes mandatory the
currently voluntary practices in the American Petroleum
Institute’s (API) Recommended Practice 75 (RP 75);
A mandatory oil and gas SEMS program will enhance the

safety and environmental protection of oil and gas drilling
operations on the Outer Continental Shelf (OCS),
particularly in light of the Deepwater Horizon explosion;

BOEMRE believes finalizing this Workplace Safety Rule has
the following benefits:
- It will provide oversight and enforcement of SEMS

provisions. Although many large operators on the OCS
currently have a SEMS program, the voluntary nature of
the programs limits their effectiveness;
- It will impose the requirement for a SEMS program on all
OCS operators;
- It will address human factors behind accidents not
reached by current regulations;

And further:
- It will provide a flexible approach to systematic safety

that can keep up with evolving technologies;
- It covers all phases:
o Drilling;
o Production;
o Construction;
o Well work-over;
o Well completion;
o Well servicing;
o Pipeline activities;
 Elements of a SEMS
The rule is based on the well-established Safety and
Environmental Program (SEMP) as defined by API
Recommended Practice 75, first issued 1994, has become
effective since November 2010 and is built of 13 elements
as follows:
 General provisions: for implementation, planning and

management review and approval of the SEMS program;
 Safety and environmental information: safety and
environmental information needed for any facility, e.g.
design data, facility process such as flow diagrams,
mechanical components such as piping and instrument
diagrams, etc.
 Elements of a SEMS (cont’d)

Further:
 Hazards analysis: a facility-level risk assessment;

 Management of change: program for addressing any
facility or operational changes including management
changes, shift changes, contractor changes, etc.;
 Operating procedures: evaluation of operations and
written procedures;
 Safe work practices: manuals, standards, rules of
conduct, etc.;
 Training: safe work practices, technical training – includes
contractors;
 Pre-startup review: review of all systems
 Elements of a SEMS (cont’d)

And finally:
 Mechanical integrity: preventive maintenance programs,

quality control;
 Emergency response and control: emergency evacuation
plans, oil spill contingency plans, etc.; in place and
validated by drills;
 Investigation of Incidents: procedures for investigating
incidents, corrective action and follow-up;
 Audits: rule strengthens RP 75 provisions by requiring an
audit every 4 years, to an initial 2–year re-evaluation; and
then subsequent 3-year audit intervals.;
 Records and documentation: documentation required that
describes all elements of SEMS program;
PSM System Performance
 Process Safety Performance Indicators

In April 2010, API published Recommended Practice (RP) 754
on Process Safety Performance Indicators for the Refining
and Petrochemical Industries;
This recommended practice (RP) identifies leading and

lagging process safety indicators useful for driving
performance improvement;
API (RP) 754 suggests a process safety pyramid with four
classifications or tiers, the tiers of the pyramid represent a
continuum of leading and lagging process safety indicators:
Tier 1 is the most lagging and Tier 4 is the most leading;
 Process Safety Performance Indicators (cont’d)

API (RP) 754 Process Safety Pyramid:

A Tier 1 Process Safety Event (T-1 PSE) is a loss of primary
containment (LOPC) with the greatest consequence as
defined by API RP 754, a T-1 PSE is an unplanned or
uncontrolled release of any material, including non-toxic and
nonflammable materials (e.g. steam, hot condensate,
nitrogen, compressed CO2 or compressed air), from a
process that results in one or more of the consequences
listed below:
 An employee, contractor or subcontractor “days away from
work” injury and/or fatality;
 A hospital admission and/or fatality of a third-party;
 An officially declared community evacuation or community
shelter-in-place;

A Tier 1 Process Safety Event (T-1 PSE):
 A fire or explosion resulting in greater than or equal to
$25000 of direct cost to the Company;
 A pressure relief device (PRD) discharge to atmosphere
whether directly or via a downstream destructive device
that results in one or more of the following four
consequences:
o Liquid carryover;
o Discharge to a potentially unsafe location;
o An on-site shelter-in-place;
o Public protective measures (e.g. road closure);
 A PRD discharge quantity greater than the threshold quantities
in Table 1 (given in API RP 754), or a release of material greater
than the threshold quantities described in table 1 in any one hour
period;

A Tier 2 Process Safety Event (T-2 PSE) is a LOPC with
lesser consequence, a T-2 PSE is an unplanned or
uncontrolled release of any material, including non-toxic and
non-flammable materials (e.g. steam, hot condensate,
nitrogen, compressed CO2 or compressed air), from a
process that results in one or more of the consequences
listed below and is not reported in Tier 1:
 An employee, contractor or subcontractor recordable injury;
 A fire or explosion resulting in greater than or equal to $2500 of
direct cost to the Company;
 A PRD discharge quantity greater than the threshold quantity in
Table 2 (given in API RP 754), or a release of material greater
than the threshold quantities described in Table 2 in any one-
hour period;

A Tier 2 Process Safety Event (T-2 PSE):
 A pressure relief device (PRD) discharge to atmosphere
whether directly or via a downstream destructive device
that results in one or more of the following four
consequences (as per table 2, API RP 754):
o Liquid carryover;
o Discharge to a potentially unsafe location;
o An on-site shelter-in-place;
o Public protective measures (e.g. road closure);

A Tier 3 PSE typically represents a challenge to the barrier
system that progressed along the path to harm, but is
stopped short of a Tier 1 or Tier 2 LOPC consequence;
Indicators at this level provide an additional opportunity to
identify and correct weaknesses within the barrier system;
Tier 3 indicators are intended for internal Company use and
can be used for local (site) public reporting:
 Safe operating limit excursions;

 Primary containment inspection or testing results outside
acceptable limits;
 Demands on safety systems;
 Other LOPCs;

Tier 4 indicators typically represent performance of
individual components of the barrier system and are
comprised of operating discipline and management system
performance;
Tier 4 indicators are indicative of process safety system
weaknesses that may contribute to future Tier 1 or Tier 2
PSEs, in that sense, Tier 4 indicators may identify
opportunities for both learning and systems improvement;

The Tier 4 indicators should be those with the highest
predictive ability and those that provide actionable
information such as:
 Process Hazard Analysis (completion, revalidation, etc.);
 Process Safety & other safety related assessment Action Item
Close-out (e.g. HAZOP, Incident Survey items, compliance audits);
 Training completed on schedule & adequate;
 Procedures are current and accurate;
 Work Permit Compliance;
 Safety Critical Equipment Inspection;
 Safety Critical Equipment Deficiency/ Defeat Management;
 Management of Change (MOC) and Pre Start-up Safety Review
(PSSR) Compliance;
 Completion of Emergency Response Drills;
 Other required management systems in place (CMS, EMS, OR&A);
 Control of Process Safety Management Systems

To control the main critical features of a process safety
management system, check lists may be useful instruments
both for external inspections and self-evaluation as well:
 Is safety management supported by the higher levels of

the organization?
 Who is responsible of its implementation?
 Are the performances or the activities of the company
monitored through the use of some specific mechanisms
for qualitative and quantitative evaluation?

(cont’d)
 Is the risk analysis and the risk assessment carried out by

the use of an appropriate methodology, such as HAZOP or
similar methods, that enables to design or to modify
equipment and procedures with a systematic criterion?
 Is the risk analysis carried out in relation of all the most
critical parts and the most critical operation of the plant?

(cont’d)
 Is the population around the establishment adequately

informed of possible hazards and of the consequent
emergency plan that regard them?
 Is the management system documented with the
appropriate standards?
 Does the organization assign clearly, roles and
responsibilities at every level, in relation to the required
competencies?
 Does the organization have internal committees for
safety? If yes, what are their functions?

(cont’d)
 Is the organization able to manage changes so that every

change is adequately evaluated and integrated with the
rest of the operational assess?
 Does the organization have an internal audit system? Is
the audit frequency planned in relation to the particular
features of the object that has to be checked?
 Does the organization have a procedure for reporting and
investigate past accidents or non-conformities? Does the
organization have a procedure for the follow up actions in
relation to past accidents and non-conformities?
PSM System Performance Indicators
 Control of a Process Safety Management system

(cont’d)
Human factors considerations are a vital element of process
safety management that can easily be incorporated into
popular hazard evaluation methodologies;
Regardless of what hazard evaluation technique is employed,
it is imperative for PHA teams to ask, "Why would someone
make this mistake?" whenever a human error is identified as
a cause of a hazard;
The two-step combination of qualitative analyses, possibly
followed by a management system evaluation and/or a
detailed human reliability analysis (either qualitative or
quantitative) is an extremely powerful set of tools for
uncovering deficiencies that can lead to human errors;
Final Statement
 To Err Is Human
May be a true statement, but the frequency and
consequences of such errors can be effectively reduced with
a well-designed strategy for addressing human factors
during suited-for-purpose process hazard analyses (PHA);
No job is so important and No service is so urgent that we

cannot take time to perform our work in a safe manner;
There’s no substitute for: “Knowing What You Are Doing”

Final Statement
 From Process Safety to Operational Integrity

PSM programs shall be used as a part of Operational
Integrity and Excellence programs:

PSM

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PSM

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Process Safety

 A series of major accidents on chemical process sites

 Both private and public organizations, including

 Aggressive legislative and regulatory process safety

All these facts lead to the fact:

 Process Safety Management (PSM)

 A Safety Management System

 A Safety Management System

 What is a management system?

 Europe: Seveso Directive (Onshore)

 USA: OSHA PSM / EPA-RMP (Onshore)

 Center for Chemical Process Safety (CCPS)

 Chronology, North America

 The American Institute for Chemical Engineers (AIChE)

 The American Petroleum Institute (API) - Recommended

 Chronology, North America (cont’d)

 US Occupational Safety and Health Administration

 EPA - 40 CFR Part 68: “Accidental Release Prevention

 BOEMRE has issued its rule for the implementation of an

 Chronology, Europe (EU Member States)

 Seveso I Directive (1982) was based on Article 174 of EC

 Chronology, Europe (cont’d)

 Seveso II Directive was proposed in December 1996 to

 Chronology, Europe (cont’d)

 The Seveso III Directive 2012/18/EU was put into force

 The Health and Safety at Work etc. Act 1974:

 Evolution of Process Safety and Accident

How can I improve based How can I better manage

 SEVESO II Directive (cont’d)

 SEVESO II Directive (cont’d)

 SEVESO II Directive (cont’d)

 Organization and personnel;

 SEVESO III Directive

 SEVESO III Directive (cont’d)

 OSHA/ PSM Guideline

(1) Employee Participation; (2) Process Safety Information;

 Continuous Improvement-Based Strategy

 Continuous Improvement-Based Strategy (cont’d)

 Structure of a Risk-Based PSM

- Commitment to process safety;

These 4 pillars consist of totally 20 elements;

 Commitment to Process Safety

- Process safety culture;

 Understanding Hazards and Risk

- Process knowledge management;

 Learning from Experience

 To investigate the possible causes of an incident that has

 What can go wrong?

 Europe: Offshore Safety Directive (OSD)

Implementation of the Directive (OSD):

 Member states of the European Union were required to

 Europe: OSD (cont’d)

 Europe: OSD (cont’d)

 USA: The Workplace Safety Rule

A SEMS is a comprehensive management program for

 USA: The Workplace Safety Rule (cont’d)

A mandatory oil and gas SEMS program will enhance the

 USA: The Workplace Safety Rule (cont’d)

- It will provide oversight and enforcement of SEMS

 USA: The Workplace Safety Rule (cont’d)

- It will provide a flexible approach to systematic safety

 General provisions: for implementation, planning and

 Elements of a SEMS (cont’d)

 Hazards analysis: a facility-level risk assessment;