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1-12 The CCPS 20 Elements of Risk-Based Process Safety

In 2007, the AICHE Center for Chemical Process Safety published Guidelines for Risk Based Process Safety.9 The risk-based process safety (RBPS) approach

recognizes that all hazards and risks in an operation or facility are not equal; consequently, apportioning resources in a manner that focuses effort on greater hazards and higher hazards is appropriate. … The RBPS system may encompass all process safety issues for all operations involving the manufacture, use, storage, or handling of hazardous substances or energy. However, each organization must determine which physical areas and phases of the process life cycle should be included in its formal management systems, based on its own risk tolerance considerations, available resources, and process safety culture. … The RBPS elements are meant to apply for the entire process life cycle.

The 20 elements of RBPS are listed in Table 1-18. These elements are organized in four major foundational blocks: (1) commit to process safety, (2) understand hazards and risks,(3) manage risk, and (4) learn from experience.

Table 1-18 The 20 Elements of Risk-Based Process Safety

Foundational Block: Commit to Process Safety

  1. Process safety culture

  2. Compliance with standards

  3. Process safety competency

  4. Workforce involvement

  5. Stakeholder outreach

Foundational Block: Understand Hazards and Risks

  1. Process knowledge management

  2. Hazard identification and risk analysis (HIRA)

Foundational Block: Manage Risk

  1. Operating procedures

  2. Safe work practices

  3. Asset integrity and reliability

  4. Contractor management

  5. Training and performance assurance

  6. Management of change

  7. Operational readiness

  8. Conduct of operations

  9. Emergency management

Foundational Block: Learn from Experience

  1. Incident investigation

  2. Measurements and metrics

  3. Auditing

  4. Management review and continuous improvement

Source: AICHE Center for Chemical Process Safety, Guidelines for Risk Based Process Safety (Hoboken, NJ: Wiley Interscience, 2007).

OSHA has a similar set of 14 elements that are included as part of 29 CFR 1910.119 on process safety management.10 The OSHA elements of this regulation are (1) employee participation, (2) process safety information, (3) process hazards analysis, (4) operating procedures,(5) training, (6) contractors, (7) pre-startup safety review, (8) mechanical integrity, (9) hot work permits, (10) management of change, (11) incident investigation, (12) emergency planning and response, (13) audits, and (14) trade secrets. While these 14 elements are contained within the CCPS 20 elements, the OSHA regulation has legal authority.

The 20 CCPS RBPS elements are described here:11

Element 1—Process Safety Culture: A positive environment in which employees at all levels are committed to process safety. This starts at the highest levels of the organization and is shared by all. Process safety leaders nurture this process. (See Section 1-3, “Safety Culture.”)

Element 2—Compliance with Standards: Applicable regulations, standards, codes, and other requirements issued by national, state/provincial, and local governments; consensus standards organizations; and the company itself. Interpretation and implementation of these requirements. Includes development activities for corporate, consensus, and governmental standards. (See Section 1-10, “Codes, Standards, and Regulations.”)

Element 3—Process Safety Competency: Skills and resources that the company needs to have in the right places to manage its process hazards. Verification that the company collectively has these skills and resources. Application of this information in succession planning and management of organizational change.

Element 4—Workforce Involvement: Broad involvement of operating and maintenance personnel in process safety activities, to make sure that lessons learned by the people closest to the process are considered and addressed.

Element 5—Stakeholder Outreach: A process for identifying, engaging, and maintaining good relationships with appropriate external stakeholder groups. This would include the surrounding community, suppliers of raw materials, customers, government agencies and regulators, professional societies, contractors, and more.

Element 6—Process Knowledge Management: The assembly and management of all information needed to perform process safety activities. Verification of the accuracy of this information. Confirmation that this information is correct and up-to-date. This information must be readily available to those who need it to safely perform their jobs.

Element 7—Hazard Identification and Risk Analysis: Identification of process safety hazards and their potential consequences. Definition of the risks posed by these hazard scenarios. Recommendations to reduce or eliminate hazards, reduce potential consequences, and reduce frequency of occurrence. Analysis may be qualitative or quantitative, depending on the level of risk.

Element 8—Operating Procedures: Written instructions for a manufacturing operation that describes how the operation is to be carried out safely, explaining the consequences of deviation from procedures, describing key safeguards, and addressing special situations and emergencies.

Element 9—Safe Work Practices: Procedures to safely maintain and repair equipment, such as permits to work, line breaking, and hot work permits. This applies to nonroutine operations.

Element 10—Asset Integrity and Reliability: Activities to ensure that important equipment remains suitable for its intended purpose throughout its service. Includes proper selection of materials of construction; inspection, testing, and preventive maintenance; and design for maintainability.

Element 11—Contractor Management: Practices to ensure that contract workers can perform their jobs safely, and that contracted services do not add to or increase facility operational risks.

Element 12—Training and Performance Assurance: Practical instruction in job and task requirements and methods for operation and maintenance workers, supervisors, engineers, leaders, and process safety professionals. Verification that the trained skills are being practiced proficiently.

Element 13—Management of Change: Process of reviewing and authorizing proposed changes to facility design, operations, organization, or activities prior to implementing them, and ensuring that the process safety information is updated accordingly.

Element 14—Operational Readiness: Evaluation of the process before startup or restart to ensure the process can be safely started. Applies to restart of facilities after being shut down or idled as well as after process changes and maintenance. Also applies to startup of new facilities.

Element 15—Conduct of Operations: Means by which the management and operational tasks required for process safety are carried out in a deliberate, faithful, and structured manner. Managers ensure workers carry out the required tasks and prevent deviations from expected performance.

Element 16—Emergency Management: Plans for possible emergencies that define actions in an emergency; resources to execute those actions; practice drills; continuous improvement; training or informing employees, contractors, neighbors, and local authorities; and communications with stakeholders in the event that an incident does occur.

Element 17—Incident Investigation: Process of reporting, tracking, and investigating incidents and near misses to identify root causes; taking corrective actions; evaluating incident trends; and communicating lessons learned.

Element 18—Measurement and Metrics: Leading and lagging indicators of process safety performance, including incident and near-miss rates as well as metrics that show how well key process safety elements are being performed. This information is used to drive improvement in process safety. (See Section 1-6, “Safety Metrics.”)

Element 19—Auditing: Periodic critical review of process safety management system performance by auditors not assigned to the site to identify gaps in performance and identify improvement opportunities, and track closure of these gaps to completion.

Element 20—Management Review and Continuous Improvement: The practice of managers at all levels of setting process safety expectations and goals with their staff and reviewing performance and progress toward those goals. May take place in a staff or “leadership team” meeting or on a one-on-one basis. May be facilitated by process safety leader but is owned by the line manager.

Table 1-19 presents common chemical plant activities associated with each of the 20 elements. When a chemical plant incident occurs, the incident investigation usually finds deficiencies in many of the elements. The 20 elements provide a comprehensive management system to handle risks|in chemical plants and other facilities. All of the elements are important, and all must be given adequate consideration. Chemical engineers are involved in all aspects of the 20 elements.

Table 1-19 Typical Activities Associated with the 20 Risk Based Process Safety (RBPS) Elements

  1. Process safety culture

    Develop or deploy corporate process safety culture programs.

    Identify process safety culture issues and influence corporate changes.

    Maintain a strong process safety culture among team members.

    Conduct formal assessments to identify gaps and recommend improvements in the process safety culture.

  2. Compliance with standards

    Interpret or apply standards for internal use.

    Participate in standards development.

    Develop a system to identify standards and uniformly administer and maintain the information.

  3. Process safety competency

    Develop a training program to increase workers’ level of competency.

    Develop competency profiles for critical process safety positions.

    Evaluate a unit to determine gaps in competency.

  4. Workforce involvement

    Develop, lead, or participate in organizing workforce involvement efforts at the corporate, business, plant, or unit level.

    As a supervisor, regularly lead discussions around process safety concerns or issues with operating personnel.

    As a worker, provide constructive feedback aimed at improving process safety and track feedback to resolution.

  5. Stakeholder outreach

    Lead community action panel (CAP) meetings.

    Work with the local community to create an area CAP and facilitate meetings.

    Develop site or corporate practices or standards to coordinate and manage major off-site accident risks, to include communications with stakeholders.

    Coordinate an emergency response simulation or drill in the community.

  6. Process knowledge management

    Validate existing Process and Instrument Diagrams (P&IDs) with actual plant configuration.

    Develop safe operating limits and consequences of deviations for a process unit.

    Update process safety knowledge following management of change (MOC).

    Write internal standards for the company.

    Develop a database of relief devices.

  7. Hazard identification and risk analysis

    Develop and/or implement corporate methods and procedures for hazards analysis and risk assessment.

    Develop consequence assessment simulations.

    Lead or participate in process hazards analysis (PHA).

  8. Operating procedures

    Write or revise operating procedures to make them clearer and more usable.

    Review and update operational procedures for a site.

    Identify safe operating limits for a process.

  9. Safe work practices

    Participate in confined-space operations.

    Certify confined-space operations attendants.

    Participate in or develop and audit line breaking and/or lock-out/tag-out (LOTO) procedures.

    Develop a corporate work permit policy.

    Audit and/or improve safe work practices.

  10. Asset integrity and reliability

    Review and assess data from inspections; draw conclusions and make recommendations.

    Develop or implement practices, procedures, and strategies to manage the integrity in a facility, site, or company.

    Research published corrosion rates to provide general guidance for developing specifications.

  11. Contractor management

    Audit contractors for safety.

    Develop recommendations and actions to improve contractor performance.

    Develop process safety requirements for hiring new site contractors.

  12. Training and performance assurance

    Develop process safety training programs.

    Provide oversight of corporate or site process safety training program.

    Give or receive process safety training.

  13. Management of change (MOC)

    Develop corporate procedures for change management.

    Participate in management of change reviews.

    Author MOC documentation.

    Identify a site MOC coordinator.

  14. Operational readiness

    Lead and/or participate in pre-startup safety reviews (PSSR).

    Develop commissioning and startup plans.

    Identify critical process safety information (PSI) required to operate safely.

    Start up a process that is ready to operate.

  15. Conduct of operations

    Implement practices intended to maintain the operational discipline at a facility.

    As a front-line worker, cooperate with peers to ensure that performed tasks are done exactly as prescribed over a long period of time.

    Actively monitor and make corrective action plans related to the performance of process safety operating tasks.

  16. Emergency management

    Set up or participate in emergency response drills with community responders.

    Work with corporate officials to perform emergency drills or table-top drills.

    Participate in planning and addressing potential plant emergencies.

  17. Incident investigation

    Participate in an accident investigation.

    Manage accident investigation action items.

    Develop and implement corporate procedures for incident investigation.

  18. Measurements and metrics

    Act as the site lead for or participate in collecting and reporting metrics.

    Prepare reports on process safety metrics.

    Develop and implement site or company metrics.

  19. Auditing

    Participate in process safety audits, either as an auditor or an audited party.

    Develop process safety audit methods.

    Manage audit recommendations to ensure they are implemented.

  20. Management review and continuous improvement

    Participate in management reviews.

    Evaluate results from management reviews and proposed/reviewed recommendations for improvement.

    Engage management to follow up and close out actions derived from management reviews.

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