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Chemical Safety Board Changes

Hamlet: Lose the Name of Action

The Chemical Safety Board (CSB) continues to undergo unsettling changes, as described in the C&EN article Changes on tap at U.S. Chemical Safety Board, and in the PEER report Outgoing Chemical Safety Chair Fires Managing Director.

The following is a comment on the C&EN article made by Ian Sutton.


As a process safety professional I have two responses to this article.

The first is that clients reasonably expect to receive reports from incident investigations and hazard analyses promptly. Delays lead to justified frustration for the client, and the sense of urgency and opportunity is lost. In particular, if there has been a serious event at a process facility, senior management is shaken up and is usually willing to spend the money and do whatever it takes to prevent something similar from happening again.
When I read, “six reports were incomplete, one of which stretched back six years”, my mind jumped to Hamlet’s words to do with delay (in his case, procrastination),

. . . enterprises of great pith and moment . . . their currents turn awry, And lose the name of action.

After six years, any sense of urgency is long gone. The “name of action” has disappeared.

The Chemical Safety Board want their investigations to be thorough. But that goal has to be traded against the importance of timeliness.

In the immediate follow-up to a serious incident, site management will often issue “Immediate Temporary Controls (ITC)”  — generally within 24 hours. They don’t know the root causes of the event but that can identify immediate causes.

Let’s say that a leak was caused by corrosion under insulation; the ITC could be to “Check the integrity of all piping under insulation”. Later on, the incident investigators may identify a root cause, say to do with not properly following engineering standards.

Maybe the CSB could do something similar, i.e., issue recommendations very quickly based not on root causes, but on immediate causes.

The second thought is that process safety management (PSM) is now well-established and mature. After all, the first standards were issued in the early 1990s. This means that managers are used to looking at incidents in terms of the elements of PSM such Management of Change, or Operating Procedures, or Prestartup Safety Reviews. It would be helpful if the CSB could organize its analysis and finding around those well-established elements.


 

Revised BSEE Drilling Rules

BSEE (the Bureau of Safety and Environmental Enforcement) is proposing to roll back some of the offshore safety rules that were promulgated following the Deepwater Horizon/Macondo catastrophe. Specifically, they have published a Revised Well Control Rule for comment. Their justification is,

. . . after thoroughly reexamining the original Blowout Preventer Systems and Well Control final rule (WCR), experiences from the implementation process, and BSEE policy, BSEE proposes to amend, revise, or remove current regulatory provisions that create unnecessary burdens on stakeholders while ensuring safety and environmental protection.

Many reviewers are concerned that this rollback is not justified and that it could increase the chance of another major event. This article in the online journal The Hill is representative.

Further discussion is provided in the article White Whales and Black Swans.

Safety Moment #45: Inherent Safety

This week’s Safety Moment (Safety Moment #45: Inherent Safety) draws a distinction between the following types of safety:

  1. Inherent;
  2. Passive;
  3. Active; and
  4. Procedural

Of the four, the most effective is Inherent Safety because, no matter what happens, the system will always remain in a safe condition.

The Fundamentals of Process Safety Management

Chemical-Plant-small

This week’s Safety Moment describes the basics of Process Safety Management (PSM) at https://iansutton.com/topics/process-safety-management.

The article describes:

  • How PSM programs developed in the late 1980s in response to a number of catastrophic events that occurred at that time.
  • The successful decision to make PSM non-prescriptive and performance-based.
  • The fact that PSM is about process safety — and why that is such a challenge.

The article then discusses the three words that make up the phrase ‘Process Safety Management’, i.e., ‘Process’, ‘Safety’ and ‘Management’.

The PSM Report: Welcome

Sutton Technical Books

Welcome to the PSM Report — where the letters PSM stand for ‘Process Safety Management’. We post information, news and opinions to do with the management of safety in the process industries, including chemical plants, oil refineries, pipelines and offshore oil and gas.

Much of the material at this site is based on the following books: