Implementation of a Risk-Based

Process Safety Management System

A Resource for AGA Members

AGA Process Safety Sub-Committee

Process Safety Framework Initiative
December, 2016

CCPS, Guidelines for Risk-Based Process Safety

Copyright © 2007 AIChE and used with permission
PSM implementation at PG&E and used with permission
 Notice
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Copyright © 2016 American Gas Association. All rights reserved. www.aga.org
 Process Safety Compared to Personal Safety

Process safety is the prevention and mitigation of unintentional releases of

potentially dangerous materials or energy through the use of robust processes
and equipment reliability.

• Identifying and understanding potential hazards

• Evaluating consequences, safeguards, and risks
Process Safety • Adding layers of protection (safeguards) to prevent
is about: and/or mitigate incidents
• Protecting employees, the public, the environment
and assets through these safeguards

Process Safety • Slips, trips and falls, or what is commonly referred

is not about: to as “personal safety”
 Process Safety Framework Objective

• The objective of this resource is to help a company

develop a comprehensive framework which captures
industry best practices in Process Safety Management.
• The framework is intended to be simple so that it can
easily be understood and applied.
• The framework focuses on defining what good Process
Safety looks like.
• The framework is not a ‘one size fits all’ model but rather
a set of requirements that can be customized to meet the
needs of individual companies based on their safety
culture and safety maturity.
 Various Safety Management Systems

• OSHA Process Safety Management (PSM) 29 CFR

1910.119 (published in 1992; 14 elements)
• EPA Risk Management Plan (RMP) (per the Clean Air Act;
16 elements)
• American Chemistry Council (ACC) Responsible Care (18
elements)
• CCPS Risk-Based Process Safety (RBPS) (introduced in
2007; 20 elements) – the most comprehensive and
rigorous system
• API Recommended Practice 1173 Pipeline Safety
Management System (API 1173) (introduced in 2015; 11
elements)
 OSHA Process Safety Management
Elements
OSHA 29 CFR 1910.119, effective 1992
1. Employee Participation 8. Mechanical Integrity
2. Process Safety 9. Hot Work Permits
Information (PSI) 10. Management of Change
3. Process Hazards Analysis (MOC)
(PHA) 11. Incident Investigation
4. Operating Procedures 12. Emergency Planning and
5. Training Response
6. Contractors 13. Compliance Audits
7. Pre-Startup Safety Review 14. Trade Secrets
(PSSR)
 CCPS Risk-Based Process Safety Elements

PG&E representation of the 20 elements of Risk Based Process Safety from CCPS
“Guidelines for Risk-Based Process Safety “, 2007, AIChE, NY
 API RP 1173 Pipeline Safety
Management System Elements

1. Leadership & Management 8. Emergency Preparedness

Commitment and Response
2. Stakeholder Engagement 9. Competence, Awareness
3. Risk Management and Training

4. Operational Controls 10. Documentation and

Record Keeping
5. Management of Change
(MOC) 11. Management Review and
Continuous Improvement
6. Incident Investigation
7. Safety Assurance
 Apply Process Safety Management
to These Assets
• Gas Transmission Pipelines
• Gas Distribution Services and Distribution Mains
• Regulator Stations
• Compressor Stations
• Gas Terminals
• Gas Storage Facilities
• LNG/CNG Facilities
• Measurement and Control
• Customer Connected Equipment
 Where to Start?

Ultimate Goal - reduce risk to a level that

can be tolerated by all concerned
• Multiple Frameworks to select from
• Honing in on RBPS
• Why RBPS?
• What is RBPS?
 Reasons to Implement an RBPS
Management System

• Reduce risk associated with incidents involving

uncontrolled releases of hazardous material and energy.
• Improve efficiency by consolidating a range of discrete
safety-related activities to protect employees, the public,
the environment and property.
• Cost savings by identifying safety enhancements early in
the design process.
• Reduced downtime and maintenance cost.
• Improved operations, customer satisfaction, reputation,
employee relations, recruitment and retention.
 Attributes of an RBPS Management
System
• Incorporates state-of-the-art and experience-tested features in a holistic
process safety management system.
 Includes novel elements such as culture, outreach, conduct of operations, metrics
and management review addressing gaps in process safety management widely
observed over 15 years.
• Holistic application will tend to minimize aggregate risk.
 Intensity of work activities for each element will be better tuned to the residual risk
they are designed to manage.
• Optimizes the use of resources.
 Description of each element includes lists of several ideas for improving
effectiveness either through efficiency improvements (make do with less) or
performance improvements (maximize benefits from existing efforts).
• Provides a management system that is better tuned to hazards and risks.
 Help decide whether the level of effort applied to work activities for each element
is inadequate, excessive, or optimal.
 Scope of the work activities at a required level of reliability helps focusing the effort
and promote risk management practices.
 RBPS: Four Accident Prevention
Pillars

To be implemented at a risk-appropriate level of rigor.

1. Commit to process safety — the cornerstone of process
safety excellence
2. Understand hazards and evaluate risks — the foundation
of a risk-based approach
3. Manage risk — the ongoing execution of RBPS tasks
4. Learn from experience — the opportunities for
improvement
 The RBPS Approach
• The RBPS approach recognizes that all hazards and risks
are not equal.
• It focuses more resources on greater hazards and higher
risks.
• It puts just enough energy into each activity to meet the
anticipated needs for that activity.
• Limited company resources can be optimally apportioned
to improve both facility safety performance and overall
business performance.
 First Steps - Implementation of an
RBPS Management System
• Obtain management commitment • Keep it simple.
and support.
• Obtain widespread commitment.
• Solicit assistance.
• Provide adequate training.
• Ensure adequate resource
allocation. • Field-test the system prior to official
implementation.
• Define scope and objectives.
• Develop tools to streamline future
• Define roles and responsibilities. implementation activities.
• Manage expectations. • Apply proven project management
tools and methods.
• Communicate.
• Be flexible and be aware.
• Advance in discrete, manageable
and well defined steps. • Continually reinforce the
commitment.
 Select RBPS Elements that Provide
Greatest Risk Benefit to the Facility
Three RBPS criteria should be considered for improving a
PSM system:
1. Understanding of the hazards and risks of the facilities
and operations.
2. Understanding of the demand for (and resources used in)
process safety activities.
3. Understanding of how process safety activities are
influenced by the process safety culture within the
organization.
 Select RBPS Elements that Provide
Greatest Risk Benefit to the Facility (continued)

CCPS, Guidelines for Risk-Based Process Safety

Copyright © 2007 AIChE and used with permission
 Successful Deployment of an RBPS
Management System
• Develop and deploy a strategy to implement a process safety management
system.
• Determine current state by performing a self assessment or benchmarking
study for elements of interest. If you are unable to include all 20 RBPS
elements, consider including the 10 listed on slide 22 in combination with the
self assessment tool described in slides 20 and 21.
• Develop multi-year roadmaps to close gaps and achieve desired level of process
safety maturity. Track progress on maturity curves.
• Develop and deploy a Process Safety Communication Plan.
• Establish interdependencies and integration of process safety management
with other initiatives underway and add process safety rigor.
• Establish leading and lagging metrics relevant to the organization or to the
current maturity level. Over time more metrics can be evaluated.
• Consider implementing a management review and continuous improvement
process.
• Review implementation effectiveness.
 RBPS Systems Implementation
Examples
RBPS Implementation Examples
Key Principles and essential Features -
ExKey
1: Principles
Upgradingand essential
Operating Features -
Procedures ExKey Principles and
2: Upgrading essential
Conduct Features -
of Operations Ex 3: Upgrading MoC Element
Upgrading Operating procedures. Upgrading Conduct of Operations Key Principles and essential Features - Upgrading MoC Element.
Maintain a Dependable Practice: Maintain a Dependable Practice: Maintain a Dependable Practice:
- Establish Management Controls - Define roles and responsabilities - Establish Consistent Implementation
- Control Procedure Format and Content -Establish standards for performance - Involve Competent Personnel
- Control documents. - Validate program effectiveness - Keep MoC practices effective.
Identify what Operation Procedures are Control Operations Activities: Identify Potential Change Situations:
needed: - Follow written procedures - Define the scope of the MoC system
- Conduct a Task Analysis - Follow safe work practices - Manage all sources of change
- Determine the level of detail. - Use qualified workers Evaluate possible impacts:
- Address all Operating Modes. - Assign adequate resources - Provide appripriate input info to manage the change
Develop Procedures: - Formalize communications, etc. - Apply appropriate technical rigor for the MoC review process
- Address Operating limits Control the status of Systems and - Ensure that MoC reviewers have appropriate expertise and tools
- Address consequences of deviation Equipment: Decide whether to allow the change:
- steps to avoid or correct deviations - Formalize equipment/asset ownership - Authorize changes.
- clear concise instructions - Monitor Equipment status - Ensure that change authorizers address important issues.
- follow the logic of the process - Maintain good housekeeping Complete follow-up activities:
Develop Metrics. - Maintain Labeling - Update records
- Maintain Instruments and tools. - Communicate changes to personnel
Develop Metrics. - Enact risk control measures
- Maintain MoC records.
Develop Metrics.
CCPS, Guidelines for Risk-Based Process Safety
Copyright © 2007 AIChE and used with permission
 Sample Process Safety Management
Assessment Tool
• The following Process Safety Management Maturity
Assessment Tool was developed based on “CCPS’
Guidelines for Risk Based Process Safety”
• The tool provides best practices Sample of Tool Output
used in the chemical industry and
shows different levels of maturity
across the 20 Process Safety
elements.
• The tool needs to be customized
to better reflect the requirements
of the natural gas industry.
This tool was developed by
Andre Da Costa
at PG&E and used with Click the Excel
Microsoft Excel
permission Worksheet Worksheet for the Tool
 Process Safety Management Assessment Tool
Guide (continued)
• Review the 20 Risk Based Process Safety elements and select elements of immediate
interest to your organization; delete the tabs of elements that you do not intend to
assess. CCPS determined that at least 6 of the elements are critical to success: Process
Safety Culture, Compliance with Standards, PHA, Management of Change, Asset Integrity
and Reliability and Metrics.
• Review the practices for selected elements of interest. Delete any practices that may not
apply to your organization. Change the language/terminology of any practices that would
not be readily understood by your organization, use terms that your organization can
relate to.
• Establish a multi-year timeframe to track progress to desired maturity.
• Revise scoring system if required (e.g. adding weights to practices). Simple scores used
without weights in the attachment.
• Get relevant teams to complete the assessment in facilitated sessions. The facilitator
must understand the tool and the language of the best practices.
• Track assessment results on radar charts.
• The benefit of self assessment is not the actual percentage scores, but rather the relative
scores (low, intermediate or high level of maturity) and identification of gaps to work on.
 Baseline PSM Elements
Selected top 10 common Process Safety Management
elements as a starting point.
1. Process Safety Culture
2. Compliance with Standards
3. Process Knowledge Management (PSI)
4. Hazard Identification and Risk Analysis
Elements

(PHA)
5. Safe Work Practices
6. Asset Integrity and Reliability
7. Management of Change (MOC)
8. Operational Readiness (PSSR)
9. Incident Investigation
10. Measurement and Metrics