I recently assisted a customer in conducting risk analysis to develop a Safety Instrumented System (SIS) design. The chemical process involved storage and handling of Methyl Isocyanate (MIC), and I was reminded that this coming December will be the 30th anniversary of the Bhopal tragedy, which involved the same chemical. Bhopal was one of the major turning points in the movement toward a series of safety principals that would later become known as “Process Safety”. My professional opinion is that the severity of the Bhopal event could not occur in the US due to several fundamental differences; but, I also advocate that we should never be complacent. My recent experience prompted some introspection on the progress made in 30 years toward improving process safety. I started my career as a process engineer in 1992; coincidentally, this was the same year as the advent of the OSHA Process Safety Management standard. Throughout 20+ years I have seen many changes for the better. Some prompted by government regulations, but most from industry initiatives. Sadly, there have also been numerous serious process accidents since that time. While each is a tragedy, industry should respond to the learnings from these accidents.
In retrospect, here are just a few important process safety improvements, many of which didn’t exist or were not widely practiced in 1992.
- Process Hazards Analysis to identify hazards and qualitatively assess their significance
- Change Management to assess the safety impacts of proposed changes before they are implemented
- Mechanical integrity programs and risk based inspection instead of breakdown maintenance
- Layer of Protection Analysis (LOPA) to provide consistent semi-quantitative risk analysis and use as the design basis for critical instrumentation and control
- An independent agency charged with investigating chemical process incidents and communicating lessons learned
- Facility siting analyses resulting in blast resistant control buildings and relocating personnel out of process areas.
- Industry consortia for sharing process safety information such as component failures and lessons learned
- Discipline to define safe operating limits and ensure those limits are not violated, even if it means downtime and lost production
As we look ahead, some challenges remain. Currently, the US Environmental Protection Agency (EPA) is considering additional regulatory action under 40 CFR Part 68 Risk Management Program (RMP). In a “request for information”, EPA has asked for input on several aspects of process safety. EPA will review responses received by 29 October 2014, and decide what action, if any, to pursue.
Just some of the topics of interest to regulators, include:
- Application of Process Safety regulations to reactive chemicals such as ammonium nitrate.
- Formalizing requirements for considering “Inherent Safety” in process design and operation
- Automated release detection measures such as gas detection and fire detection
- Third Party Compliance Audits of Process Safety Management programs
- Integrating Safety & Security practices as part of the President’s directive on Improving Chemical Facility Safety and Security
- Managing organizational change in addition to managing process change
- The “Safety Case Model”, which is a European requirement for facilities to document and submit a technical justification for safe design and operation, as a condition of permit to operate
While I don’t advocate more government regulation, I do believe that several of these concepts would indeed reduce the frequency and severity of process safety incidents. We should strive for a balance of increasing rigor of existing good practices with stretching to reach new initiatives with new goals. I’m reminded of the philosophy of DuPont, which was once described to me simply as “zero”. The goal is zero incidents, zero harm to people, and zero impact on the environment. It’s an ambitious target that helps keep our eyes looking forward and focusing always on continual improvement.