(82c) Process Safety in Net Zero Programs

Many companies, including those in the energy and process industries, are implementing ‘Net Zero’ programs. The goal of these programs is to reduce their emissions of carbon dioxide and other greenhouse gases (GHGs) to ‘Net Zero’ — often by the year 2050. In response to these initiatives regulators and professional societies around the world are requiring companies to report on their climate-related activities. For example, in the financial community the proposed Climate-Disclosure Rule from the United States Securities and Exchange Commission (SEC) calls on publicly-traded companies to:

• Report on their GHG emissions;
• Describe their programs for reducing those emissions; and
• Identify the risks that they face due to a changing climate.

The process safety profession is also taking an increased interest in climate-related initiatives. In addition to technical research, climate change is also being gradually integrated into management systems. For example, in August 2022 the United States Occupational Safety and Health Administration (OSHA) opened their process safety standard for comment and suggested changes. One of the areas in which they expressed an interest was,

Clarifying paragraph (e) to require consideration of natural disasters and extreme temperatures in their PSM programs . . .

In a similar initiative, the Environmental Protection Agency (EPA) requested comments on ‘Natural Hazards’ for its Risk Management Program (RMP). Their request included the following areas of interest,

• The Agency's proposed approach.
• Whether EPA should develop additional guidance for assessing natural hazards.
• Natural hazard resources such as databases, checklists, or narrative discussions, as well as commenters' recommendations for regional versus national, or sector-specific guidance.
• Whether to specify geographic areas most at risk from climate or other natural events by adopting the list of areas exposed to heightened risk of wildfire, flooding, storm surge, or coastal flooding and if this approach would simplify implementation.
• If the Agency should require sources in areas exposed to heightened risk of wildfire, flooding, storm surge, coastal flooding, or earthquake, to conduct hazard evaluations associated with climate or earthquake as a minimum, while also requiring all sources to consider the potential for natural hazards unrelated to climate or earthquake in their specific locations.

The principles of process safety can be used by those companies looking to develop and implement effective and practical Net Zero programs. These same principles can also be used to make regulations and standards more effective and realistic.

For example, risk assessment and control is a fundamental component of any PSM program. Those risk management techniques can be adapted to help evaluate and respond to climate-related risks.

This presentation will also consider how some of the elements of a PSM program can be adapted to assist with climate-change initiatives. For example, the principles of Process Hazards Analysis can be used to determine the nature of the hazards that companies face, what the consequence and likelihood of those hazards may be, and how management can best respond.

Climate change is not an isolated phenomenon — it is linked in many complex ways to factors such as resource depletion, alternative energy sources, economics and biosphere loss. These relationships are often difficult to understand, or even to identify. Process safety professionals grasp the importance of systems analysis, and its application in a broader context. The techniques of Incident Investigation and Root Cause Analysis, for example, can be used to assess the risks to which a company is exposed in the face of a rapidly changing climate.

Those working in the process industries can help other professions, such as the financial and legal communities, understand the technical and project realities to do with initiatives such as the replacement of fossil fuels with alternative energy sources. Process safety professionals can also evaluate the practicality of ideas such as the widespread use of hydrogen or ammonia as fuels.

Regulators and professional societies in many areas are actively involved in the development of Net Zero programs in industry. This is an opportunity for the process safety community to make an important contribution.