(13c) Protection Layers Integrity Management – an Illusion?

Consistent gaps are discovered in the operating management systems and process safety knowledge of the workforce. Many organizations still contemplate that if the PHA / LOPA is done and all recommendations are completed, then the process safety risks are taken care of. This is an illusion. No doubt, a good PHA study is a must for hazard identification and risk assessment, however; PHA alone cannot guarantee the safe operation. A robust integrated management system and a strong process safety culture is essential for safe operation. This brings up the question: how do we know if the management system is effective and the process safety culture is sufficient? There are two approaches; a proactive approach in which opportunities are identified before a loss, and, a reactive approach in which opportunities are realized after a loss. There are several processes and activities management can apply as a proactive approach.

This paper will cover one of the proactive approaches of identifying the gaps in the management program and process safety culture. The author in his current role as a senior risk control engineer performs audits and inspections of a variety of high hazard industries including refineries, chemicals, petrochemicals, oil terminals, etc. In this paper, he will share real life scenarios and examples by walking through the process of reality check of efficacy of management programs, employee competency, and process safety culture. The examples include; discussions on management programs in the conference room, interviews and implementation verifications in the control room, integrity of protection layers with maintenance, and physical check in the field.

The focus of the discussions will be on the integrity and availability of protection layers throughout the process including procedures, maintenance, training, drills and exercises. A number of surprises revealed during the verification, interviews, and discussions will be shared with best industry practices.

The paper will be concluded by sharing the strategies on how to recognize the management system gaps and apply best practices to maintain the integrity of safety critical systems to prevent process safety incidents. The author will explain how the outcomes of PHA/LOPA are integrated in the operating procedures, maintenance programs, training of employees and contractors, operational drills and exercises.

Keywords: protection layers integrity, operational discipline, and process safety culture