(57an) Flying Under the Radar of PSM Regulation: Implementing Process Safety Improvements in Research Facilities

In research and development facilities, many aspects of process safety are not addressed by applicable process safety regulations due to the small quantities of hazardous chemicals being handled in these facilities. Risk-based process safety (RBPS) elements such as asset integrity, operating procedures, and change management may be applied inconsistently in different laboratories or pilot units or perhaps even not at all. Evaluating incidents and near misses in laboratory facilities through the lens of process safety can reveal opportunities for growth in this area and the need for a more comprehensive, risk-based approach beyond the boundaries of regulation and compliance. When applying RBPS to research facilities of varying scales, correctly identifying and quantifying the hazards involved and defining the appropriate envelope of operation for the equipment is an essential foundation for further improvements. In the process of implementing strategies to address RBPS elements, such as asset integrity, it may become apparent that other elements, like process knowledge, also must be improved in order to see results in the original area of concern. This paper will explore how the elements of RBPS can be applied to research and development facilities across an organization and give several examples of challenges associated with right-sizing risk management strategies for the laboratory or pilot plant environment.