Paper Ref: S1707_A0531 3rd International Conference on Integrity, Reliability and Failure, Porto/Portugal, 20-24 July 2009
PRACTICAL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT BASED ON PLANT LIFE CYCLE ENGINEERING Yukiyasu Shimada Chemical Safety Research Group, National Institute of Occupational Safety and Health, Tokyo, Japan Email:
[email protected] Teiji Kitajima Institute of Symbiotic Science and Technology, Tokyo University of Agriculture and Technology, Tokyo, Japan Email:
[email protected] Kazuhiro Takeda Department of Material Science and Chemical Engineering, Shizuoka University, Shizuoka, Japan Email:
[email protected]
SYNOPSIS 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. Existing PSM guidelines just give the minimum elements for safety management, but they do not mention about concrete management activity. Furthermore, consistency between elements is not ensured and practical scope of elements is different each other. This paper proposes practical framework of overall activity of PSM. This has been discussed at the safety division in Society of Chemical Engineer Japan. Activity model for PSM is developed to extract the essential activities for maintaining process safety of production plant. Proposed framework defines the position of PSM elements which reflects the plant life cycle engineering (Plant-LCE) and the relation between each element, and clearly specifies what should be done for each element. IDEF0 standard is used as a description format to develop the activity model for representing the framework for PSM. The discussion with IDEF0 standard focuses on ‘what is needed as function or activity’ at all times and it can be explicit what to do for PSM. Proposed framework on PSM provides following advantages. (1) Structure of safety information sharing through the Plant-LCE can be defined. (2) Environment which integrates PSM activity with production activity is developed. (3) By specifying the PDCA (Plan-Do-CheckAction) cycle, even if some problems happen in the result and performance of PSM, they will be corrected by check and action (change requirement) activities. (4) Resources required for performing the PSM activities can be clearly specified. INTRODUCTION Recently, it is true that there are more and more incidents and disasters in chemical process industry. The reasons include following defect factors on process safety management (PSM): inadequate safety management system in company, inadequate knowledge management and insufficient information on works or tasks and attendant erroneous operation or missjudgment, no standardization for the safety management activity, etc. 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. OSHA in USA emphasizes PSM and requires the established safety management system as a company as well as the improvement of safety
-1-
engineering technique (OSHA 29CFR 1910.119, 1992). Seveso II Directive is also a framework of PSM which aims at the prevention of major accidents which involve dangerous substances, and the limitation of their consequences for man and the environment, with a view to ensuring high levels of protection throughout the community in a consistent and effective manner (Council Directive 96/82/EC, 1996). The OHSAS 18001:2007 - Occupational health and safety management systems - requirements is also PSM system to enable an organization to control its occupational health and safety risks and improve its performance (OHSAS 18001, 2007). AIChE/CCPS (Center for Chemical Process Safety) has published new PSM framework, RBPS (Risk-based Process Safety) (AIChE/CCPS, 2007), which includes process safety culture, process safety information, hazard identification and risk analysis, contractor management, management of change, etc. Existing PSM guidelines just give the minimum elements for the safety management, but they do not mention about concrete management activity. Furthermore, consistency between elements is not ensured and practical scope of elements is different each other. For these reasons, there are subjects on the position of safety management of chemical processes and the practices such as “how the PSM activity should be executed?”, “how far the PSM is done for enough process safety?” In Japan, the importance of PSM based on plant life cycle engineering (Plant-LCE) for chemical processes, which is from process development to process safety design, plant construction, production and plant maintenance, has been recognized for several years. The activity models have been developed for clarifying the contents of PSM activity itself and developing the environment for sharing information on chemical process safety. This paper proposes practical framework of overall activity of PSM. This has been discussed at the safety division in Society of Chemical Engineer Japan. Activity model for PSM is developed to extract the essential activities for maintaining process safety of production plant. PDCA (Plan-Do-Check-Action) template is proposed to develop activity model in the form of IDEF0 format. This also includes activity of ‘provision of resources’ for performing each activity. Proposed framework defines the position of PSM elements which reflects the PlantLCE and the relation between each PSM element, and clearly specifies what should be done for each element. Provision of resources including engineering standard is managed in an integrated fashion. PROCESS SAFETY MANAGEMENT AND PLANT LIFE CYCLE ENGINEERING Table 1 shows 14 elements which OSHA/PSM requires to prevent or to mitigate the effects of catastrophic releases of chemicals or energy from processes covered by the regulation. Though the main purpose of PSM is to maintain the process safety of production plant, the safety of process plant could be ensured through the Plant-LCE which is from process development to process design, plant construction and plant maintenance as shown in Fig.1. In this paper, plant development phase means process development, process design and plant construction, and plant operation phase means production and plant maintenance. PSM activity at process design phase is to design safe process plant. PSM activity at plant construction phase is to construct safe facility and plant based on the result of process plant design. PSM activity at plant maintenance phase is to maintain integrity of function of facility and plant simultaneously with production. Furthermore, it is important to perform PSM activity in the form of PDCA cycle such as planning of safety countermeasure based on the result of risk assessment, execution of plan and evaluation of outputs, to share process safety -2-
information though the Plant-LCE and to make decision to respond to change after ensuring consistency among activities. Table 1 14 elements required by OSHA/PSM No. (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14)
Name of Element Process Safety Information Employee Participation Process Hazard Analysis Operating Procedures Hot Work Permits Mechanical Integrity Contractors Training Management of Change Pre-startup Safety Review Emergency Planning and Response Incident Investigation Compliance Audits Trade Secrets
Fig.1 Views from Plant-LCE and PSM
POINTS FOR DISCUSSION We have discussed to develop the practical framework of PSM from following points. (1) To make precondition, constraint condition, resources to perform PSM activity clear and to specify what, how and why to do for activity of each PSM element as shown in Table 1.
-3-
(2) To make the positions of PSM elements within Plant-LCE clear, in other words, it should be clearly specified how the activities for the PSM elements are associated with usual PlantLCE activities. (3) To consider the framework of PSM which can convey the requirement and/or the modified information on PSM activity certainly in the form of PDCA cycle. (4) To develop the practical framework which performs the PSM activity according to engineering standard which are set up based on regulations and rules on safety at each company. ACTIVITY MODELS USING IDEF0 STANDARD IDEF0 standard is used as a description format to develop the activity model for representing the framework for PSM. IDEF0, Type-zero method of Integrated DEfinition for Functional model, is a well-known standardized method for enterprise-resource planning or businessprocess (re)engineering. Fig.2 shows the basis of activity model using IDEF0 standard. The rectangle represents activity, and the arrows describe information. The information is classified into four categories; i.e. 'Input' to be changed by the activity, 'Control' to constraint the activity, 'Output' to be results of the activity and 'Mechanism' to be resources for the activity. Each activity is developed to sub-activities hierarchically as needed. Control Input Activity
Output
Mechanism Control Input
Control
SubSubActivity SubSubActivity
Input
Activity
Output
Output SubSubActivity
Mechanism
Mechanism
Fig.2 Basis of activity model using IDEF0 standard The most important benefit of using IDEF0 standard for developing the activity model is it enables function-based discussion. If ‘who does what’ is discussed based on each organization framework in each company, it could be impossible to develop the activity model which can use commonly for the plant operation management because individual company has different techniques and methods with their own operational policy. On the other hands, the discussion with IDEF0 standard focuses on ‘what is needed as function or activity’ at all times and it can clarify what to do for PSM. This means proposed framework can be used for not only specified process company but also various ones. Activity modeling based on function has been focused and some activity models related to PSM have been proposed in a few decades. Aoyama et al. proposed activity models for the process safety design of chemical process plant based on the concept of independent -4-
protection layer (Aoyama, 2002). Fuchino et al. proposed activity models for performing effective maintenance activities and defined the specification of knowledge and information management environment needed to perform each activity (Fuchino, 2008). PDCA TEMPLATE FOR IDEF0 ACTIVITY MODELING To standardize the framework of PSM, this paper proposes a templete for activity modeling by using IDEF0 format shown in Fig.3. This template consists of ‘PDCA cycle for performing PSM activity’ and ‘Provide Resources’ activity within each plane. The meanings of each activity in the template are follows. (1) Representation of PDCA Cycle Basic concept is that each activity should be carried out according to engineering standard given by ‘Provide Resources’ activity T1) ‘Manage (Action)’ activity - To manage the progress of overall activities within the plane. - To require the provision of resources for performing ‘Plan’, ‘Do’, ‘Check’ activities. - To indicate to put action in execution, that is to give specific directive for policy given from upper level and indicate to make execution plan. - To output the approved result of activity. - To decide next action after receiving requirement of change for the fail to activity execution and bad evaluation. - To request the improvement of ES. - To send the requirement from each activity. T2) ‘Plan’ activity - To make execution plan for given specific directive proportion. - To indicate execution according to the plan. T3) ‘Do’ activity - To execute plan. - To give requirement for administrative defect factors. T4) ‘Check’ activity - To evaluates from following view points; a) execution result for direction and plan, b) compliance with engineering standard, c) provision of resource and d) consistency among engineering standards. (2) Representation of ‘Provide Resources’ T5) ‘Provide Resources’ activity Resources for performing ‘Plan’, ‘Do’, ‘Check’, ’Action’ activities include followings; a) human resources which are educated and trained and organization, b) tools and methods for supporting PSM activities, c) information stored as results of activities to decide next action, including information on defect factors, and d) engineering standard for controlling each activity which are distributed from upper level. -5-
Directive (from upper plane)
Requirement (from other section) Directive to perform execution plan (incl. requirement from other section)
Requirement to provide resources
Engineering standard (from upper plane)
Request to make or change standard Requirement of change
Manage (Action) T1
Output (Approved)
Result of performance for execution plan (incl. requirement of change)
Plan
Engineering standard for performing each activity
T2 Directive to make Execution plan (incl. requirement from other section)
Do Result of evaluation
T3 Check
T4 Provide Resources
Output (part of)
T5
Info. for progress management (incl. result of evaluation)
Fig.3
Info. to perform PDC activity, Resource (human, facility, etc.) (operation log, etc.)
Resource (Info.) (from upper plane)
Template for representing PDCA Cycle and ‘provide resources’
PRACTICAL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT The activity model for representing practical framework of PSM has been developed according to the PDCA template shown in Fig.3. The position of the activity of PSM element is clarified based on the purpose of activities in the form of PDCA cycle and provision of resources. Figs. 4-6 show parts of developing activity models. Fig.4 shows top framework for PSM related with Plant-LCE. Proposed framework consists of five activities (A1-A5) which are formed in PDCA cycle; that is management of overall PSM (Action), planning of PSM (Plan), execution of PSM (Do) and evaluation for performance and result of PSM (Check) and two activities (A6, A7) which have also scheme of uniform management and provision of resources such as human resources and organization (H&O), information, and so on. Activity A1 gives management policy according to basic corporate philosophy on PSM and manages the execution of overall PSM activity. Activity A2 makes the execution plan for PSM activity according to the management policy given by Activity A1. Activities A3 and A4 show the execution of PSM activity based on Plant-LCE. Because the target of PSM is to maintain process safety of production plant, PSM activity though the Plant-LCE is divided into plant development and plant operation phases according to the classification shown in Fig.1. Purposes of PSM at plant development and plant operation phases are to develop the safe process plant with established safety measurement and to maintain the process safety of production plant respectively. Outputs from these activities are result of PSM activity, including requirement of change or modification of engineering standards (ESs). -6-
C3 C1 C2 PSM system Enforcement of policy for improving safet y cult ure on PLCE- PSM Practical act ion plan for PLCE- PSM
C4 Engineering st andard (ES) for PLCE- PSM
Result of PLCE- PSM Requirement of change for performing PLCE- PSM
ES for PSM execut ion management I1
Pumped resources
Manage PLC E- PSM exec ution A1
CSR report Requirement of resources for performing PLCE- PSM
Opinion from part icipat ion of employee
Requirement of H&O for performing PLCE- PSM
Safet y management policy
PLCE- PSM execution policy ES for making execution plan of PLCE- PSM Make execu tion plan of PLCE- PSM
Resources for making execut ion plan of PLCE- PSM H&O for making execu t ion plan of PLCE- PSM
Requirement of change for making plan of PLCE- PSM PSM execut ion plan
A2 ES for PSM at plant development Requirement of change for performing PSM at plant development Perform PL CE- PSM at Result of PSM at plant development plant deve lopment phase Plant A3
Resource for PSM at plant development H&O for PSM at plant development
ES for PSM at plant operat ion Perform PL Requirement of change for performing PSM at plant operat ion CE- PSM at plant oper Result of PSM at plant operation at ion phase A4
Resource for PSM execut ion at plant operat ion H&O for performing P SM at plant operat ion
Evaluate p erformance of PLCE- PSM
Resource for performance evaluat ion of PLCE- PSM H&O for performance evaluation of PLCE- PSM
ES for performance evaluat ion of PLCE- PSM Requirement of change for PLCE- PSM perofrmance
A5
Result of process safet y audit Result of performance evaluat ion for PLCE- PSM ES for Provide hu man resour ces and or ganizat ion (H&O) for performing PLCE- PSM A6
providing H&O for PLCE- PSM Info. on H&O for performing PLCE- PSM Measure and policy of enhancement of PS culture H&O for performing PLCE- PSM
Resources for providing H&O for performing PLC- PSM ES for performing PSM (sit e level) Provide resources for performi ng PLCE- PSM
Info. for management of PLCE- PSM
Resources for performing PLCE- PSM A7
St ored safet y info. and knowledge and inccident info. M1
Fig.4 Top framework for PSM related with Plant-LCE
-7-
O1 O4 O2 O5 O3
Activity A5 evaluates the result and the performance of PSM execution. This activity requires the change of the basic policy and improves the PSM activity and framework of PSM system by giving feedback the result of evaluation to activity A1 after stored them as log at Activity A7. Activity A6 provides human resources and organization needed for execution of PSM activities as follows; - Employees which can follow out an instruction according to engineering standard, and - Employers (managers) which can manage overall activity of PSM and decide next action based on information from Activity A7 and according to the requirement from other section. Environment of employee participant and contractor management, applicable education and training programs, etc. are needed and detailed activity models for them are developed under A6 activity. Activity A7 stores the outputs of ‘Plan’, ‘Do’, ‘Check’, ‘Action’ activities and provides resources for performing the PSM activities as follows; - Information on result of activity execution including requirement of change, - Information on result of performance evaluation, - Tools and methods needed for supporting each activity, and - Engineering standard which includes technical standard, rule, regulation, management criterion, and so on for performing each activity. Furthermore, the meanings of terms and the example of tasks as well as the explanation of activity above mentioned are written down in the glossary separate from IDEF0 activity model. This glossary can help user to discuss about the activity model in the common perception and to understand what, how and why to do for PSM referred with activity model specifically. POSITIONING OF PSM ELEMENTS Activities A3 and A4 are further developed as shown in Figs. 5 and 6, respectively. Fig.5 shows activity model for the PSM performed at the plant development phase. This model includes PSM activities related to process development, process design and plant construction. Fig.6 shows activity model for PSM performed at plant operation phase. This includes PSM activities related to production and plant maintenance. In these activity models, performing mechanical integrity and hot work permits which are PSM elements themselves can be represented as PSM activities at the plant maintenance phase. The outputs from these activities are stored at A46 activity through the performance evaluation (A45 activity) and are also used for improvement of PSM activities. On the other hand, process hazard analysis (PHA) should be performed at each phase through the Plan-LCE. The results of PHA at each phase are stored at A37 and A46 activities through each performance evaluation and provided as process safety information. Aside from direct representation of activity, some elements of PSM can be represented as the structure of information flow among activities. Checking the specific activity flow on the IDEF0 activity model makes it possible to confirm the positioning of PSM elements such as “management of process safety information”, “management of change”, “Compliance audits” as follows. 8 / 12
(1) Management of process safety information Results of planning, execution and performance evaluation on PSM are stored at ‘provide resource’ activity. This makes it possible to manage process safety information in an integrated fashion. (2) Structure of management of change For the change requirements which are outputted from certain phase, log of them is recorded at ‘provide resources’ activity and consistency with existing information is examined. If some information or conditions, etc. are updated, modified information should be conveyed to all affected sites. (3) Compliance audits Basically, each activity is performed based on engineering standard which each company sets up according to regulations and rules. In this framework, ‘Check’ activity evaluates which each PSM activity is performed or not according to engineering standard. If the result of evaluation includes the requirement of change, the compliance with them is requested at next action. Each activity shown in Figs. 5 and 6 will be developed into detail activities. In this framework, not only engineering techniques for PSM but also their execution procedures of each PSM activity and the resources required for performing PSM activity can be clarified specifically at lower-level activity model. And activity models to make environment of employee participant and contractor management, applicable education and training programs, etc. will be also developed under A6 activity. CONCLUSIONS This paper proposes practical framework for process safety management (PSM) based on plant life cycle engineering (Plant-LCE). Activity model for representing framework of PSM is developed by using IDEF0 format. Proposed framework on PSM provides following advantages. (1) Proposed framework for PSM can be useful for various chemical process companies because it has been developed based on function-based discussion by using IDEF0 format. (2) To clarify that target of PSM is the safety management of production plant makes the purposes of process design, plant construction and plant maintenance works and the positions of PSM elements within the Plant-LCE clear. (3) By using a template to specify the PDCA cycle, even if some problems happen in the result and performance of PSM activity, they will be corrected by check and action (change requirement) activity. Because ‘Check’ activity can evaluate not only the result of performing activity but also the PSM framework itself, performances of PSM and PlantLCE activities can be improved progressively in the form of PDCA cycle. (4) Resources required for performing the PSM activities can be clearly specified. Provision of human resources and organization is represented as an activity. This activity can clarify the positions of education and training, contractor management, etc. which are parts of elements of PSM framework. Another provision of resources such as information, tools, methods, etc. is also represented as an activity. This makes it possible to manage process safety information and so on.
9 / 12
C1 PSM execut ion plan
C2 ES for PSM at plant development
ES for management of PSM at plant development Manage PSM at plannin g phase A31
Requirement of change for performing PSM at plant development Result of PSM at plant development
Requirement of resources needed for PSM at plant development Direction of PSM at plant development
O1 O2
ES for making execut ion plan for PSM at plant development Make execu Requirement of change for making plan of PSM at plant development t ion plan for PSM at plant deve Plan for PSM at plant development lopment phase ES for PSM at process A32 development Resource for making ionatplan of PSM at plant development Plan execut for PSM process development H&O for making execut ion plan of PSM at plant development Perform PS Requirement of change for performing PSM at process development M at proce ss develop Result of PSM at process development ment phase A33 ES for PSM at process design Plan for PSM at process design H&O for PSM at process development Requirement of change for performing PSM at process design Perform PS Resource for PSM at M at proce process development ss design Result of PSM at process design phase A34 H&O for PSM act ivity at process design Resource for PSM at process design
Plan for ES PSM for PSM at plant at plant construct const ruct ion ion Perform PS M at plant const ructi on phase A35
Plant
Requirement of change for performing PSM at plant const ruct ion Result of PSM at plant const ruct ion
H&O for PSM at plant construct ion Resource for PSM at plant const ruct ion
Evaluat e p erformance of PSM at plant deve lopment phase A36
ES for performance evaluation of PSM at plant development Requirement of change for PSM performance at plant development Result of performance evaluat ion of PSM at plant development
H&O for PSM performance evaluat ion at plant development Resource for PSM per formance evaluat ion at plant development
Engineering st andard for performing PSM at plant development Provide resources for PSM at p lant development phase
A37
Info. for management of PSM at plant development H&O for execut ing PSM at plant development Resources for execut ing PSM at plant development
Resource for PSM at plant development H&O for PSM at plant development M2 M1
Fig.5 Activity model for performing PSM activity at plant development phase
10 / 12
O3
C1 PSM execution plan
C2 ES for PSM at plant operat ion
ES for management of PSM activity at plant operation Manage PSM act ivity a t producti on phase A41
Requirement of change for performing PSM at plant operat ion Result of PSM at plant operation
Requirement of resources needed for PSM at plant operat ion Direct ion of PSM at plant operat ion ES for making plan for PSM at plant operation Make execu Requirement of change for making plan of PSM at plant operation tion plan for PSM at Execution plan for PSM at plant operation plant oper ation phase A42 H&O for making plan of PSM PSMfor plant at operation Plan Stfor andard atat product PSM ion product ion Requirement of change for performing PSM at production Perform PS Result of PSM at product ion M at produ Operating dat a (information) ction phase Deteriorated plant ES for PSM A43 at plant maint enance Plan for PSM at plant maint enance Resource for PSM at production Requirement of change for performing PSM at plant maintenance Perform PS H&O for PSM at production M at plant Result of PSM at plant maint enance maintenanc e phase Integrity info. on equipment and facilit y A44
Resource for making plan of PS M at plant operation
Resource for PSM at plant maintenance H&O for PSM at plant maintenance
ES for performance evaluation of PSM at plant operation Evaluate p Requirement of change for PSM perofrmance at plant operation erformance of PSM at Result of performance evaluation of PSM at plant operation plant oper ation phase A45 Resource for performance evaluation of PSM at plant operat ion ES for performing PSM at plant operation H&O for performance evaluation of PSM at Info. for management of PSM at plant operation plant operation Provide resources fo r PSM at plant opera Resources for executing PSM at plant operation tion phase A46
H&O for execut ing PSM at plant operation
Resource for PSM execut ion at plant operation H&O for performing PSM at plant operat ion M3 M2
Plant M1
Fig.6 Activity model for performing PSM activity at plant operation phase
11 / 12
O1 O2
As future works, following subjects should be discussed continuously to develop more practical framework for PSM. (a) Confirmation of position of the elements of existing PSM system within the proposed framework and extraction and addition of new important element according to it. (b) Enhancement of contents of glossary to help understanding the proposed model. (c) Validation by companies. ACKNOWLEDGEMENT The authors are grateful to the following process safety experts for their cooperation in discussion; Dr. Hideo Saito (Fuji Oil Company), Mr. Hiroshi Sumida (Toyo Engineering Corporation), Mr. Toshinori Kawabata (Ochanomizu Univ.), Mr. Hitoshi Motoyama (Daikin Industries), Mr. Kiyotaka Bito (Kaneka Corporation), Mr. Noboru Yamamuro (Zeon Corporation), Mr. Daisuke Takeda (CRIEPI), Mr. Yoshihiko Sato (AIST) and Dr. Mieko Kumasaki (Yokohama National University). REFERENCES AIChE/CCPS, Guidelines for Risk Based Process Safety, WILEY, 2007 Aoyama,A., et.al., A Framework of Independent Protection Layer Design for Process Industries, 6th International Conference on Probabilistic Safety Assessment and Management, PSAM6, 9G, 2002 Council Directive 96/82/EC of 9 December 1996 on the control of major-accident hazards involving dangerous substances, 1996 Fuchino,T., et.al., Business Process Model for Knowledge Management in Plant Maintenance: 18th European Symposium on Computer-Aided Process Engineering, Elsevier, 2008, pp.955-960 OHSAS 18001 Health & Safety Standard, http://www.ohsas-18001-occupational-health-andsafety.com/ OSHA, 29CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, 1992
12 / 12
