Implementing PSM in India - Challenges and Opportunities

Abstract

In mid 1980s a major process safety incident in India was one of the key drivers for establishing Process Safety Management standards and practices worldwide. Though India subsequently enacted a law to control industries handling hazardous chemicals in bulk quantities, there is no single comprehensive regulation outlining Process Safety Management implementation as a mandatory requirement. However, the Oil Industry Safety Directorate has evolved standards which recommend implementation of few PSM elements as part of the safety management system implementation.

With this background and the recent major process safety incidents reported in Indian industry, the Indian companies are looking towards implementing process safety as a key element of its operations not only in the oil and gas sector but across the chemical industry sector. However, given the challenges in comprehensively implementing the general safety systems and the reactive process safety culture prevailing in the industries, PSM implementation is a major challenge.

An interesting aspect is the way how the integration of safety happens at the design stage. It is only in the last 5-7 years, the Indian companies have started adopting HSE at the design stage and hence process hazard analysis techniques have gained prominence. Hence the older plants face the challenges of compiling the process safety documentation and reviewing Process Hazard Analysis studies.

Another major area of challenge is the implementation of mechanical integrity systems. Lack of comprehensive guidelines on inspection, testing and maintenance of static and rotary equipment lead industries to adopt a risk based approach which may not be accurate always. With the increasing trend of outsourcing major operation and maintenance works to third party contractors, meeting the requirements of contractor safety as required by OSHA PSM requires significant changes to the style of managing operations.

Similarly the elements of Incident Investigation, Management of Change and Pre Start Up Safety Review also require considerable review and marked shift in the way how these are addressed in the general safety systems adopted by the organizations.

Companies adopt different methods including formation of core PSM teams, element champions to drive specialized knowledge across the organization, establishing challenging process safety lead and lag indicators, nominating focus groups to mine data from DCS on process safety limits, adopting more than the 14 standard elements of OSHA PSM to name a few.

A unique challenge facing the Indian companies adopting PSM is the lack of a nodal agency on the lines of OSHA which can evaluate the PSM systems implemented by the companies and provide an assurance that the system implemented meets the standards requirement.

The paper details the challenges and opportunities PSM element wise, faced by Indian companies and the innovative methods adopted to overcome the challenges. With more and more Indian companies embarking on the journey of continual improvement in safety, PSM is definitely the next destination to ensure sustainable future.