40 Years of Bad Practices - Don't Do This!

DON’T DO THIS – ABSTRACT

Having have worked in the chemical and PSM industries since 1976. on this, my 40^th anniversary, I’d like to share with you some of the worst PSM practices that I’ve observed over my working history.

In 1976, I began work at a major commodity chemical manufacturing site.  With 10 individual plants on location, and a management attitude of “run it till it breaks and then patch it,” we averaged three to four explosions, fires, or releases per year.

In 1992, Congress passed the PSM standard, and an internal company debate raged over whether or not we were already PSM compliant.  Finally, management agreed to bring in an outside auditor to answer the question.  The resulting report was so damaging that it was instantly sealed up under attorney-client privilege and was never seen again.

In the year 2000, that company went bankrupt, and I began work as a PSM consultant.  The practices in this article summarize some of the worst PSM practices that I’ve seen over my 40-year history, both at the former employer and at various client companies.

These worst practices are sourced from a wide variety of industries including chemical manufacturing, refining, pipeline, and pharmaceutical.  The practices range across different aspects of manufacturing including:

• Maintenance
• operations authority
• operator knowledge
• emergency response
• fatigue
• quality control
• disabling safeguards
• facility siting
• pre-startup-safety-reviews
• process hazard analysis
• incident recognition and reporting
• personnel access to restricted areas
• fire prevention

Any PSM practitioner with significant experience can easily add to this list.  The examples will be presented in narrative format with discussion of why the practice has serious PSM hazard potential.  Examples will be provided from actual situations and previous incidents in the context of PSM.  In some of the examples, actual fires, explosions, or releases occurred due to the bad practice.  In those cases, the magnitude of the actual consequence will be presented as well.

The time provided for this presentation will allow for audience input at the end of the session.  The audience is encouraged to contribute valuable examples from their personal experiences that will reinforce and expand the material of this presentation.   The sometimes inobvious errors can present potentially catastrophic consequences.  Don’t do this!