(71a) Process Safety Management: 21 Years Plus or Minus - What I Wish I'd Known Then and What We Can't Afford to Forget Now

Presenter:   Alan C. Brackey, Senior Manager Process Safety Audit - Valero, San Antonio, TX

Brief Bio:  B.S. Chemical Engineering, EIT - Iowa State University, 1979.  34 years experience in chemical, petrochemical and refining processes, including 30 years at large manufacturing facilities, the past 19 years directly involved in all aspects of Process Safety Management (PSM).

My proposed presentation for the 2013 Congress would expand and build upon the key precepts outlined in my 2012 presentation to the Congress entitled “Process Safety Management Plus or Minus 20 Years-What I Wish I’d Known 20 Years Ago and What We Can’t Wait Another 20 Years to Learn!”.  The paper upon which this presentation would be based, targeted primarily at those who may be relatively new to the industry and/or to PSM practice, provides practical thoughts and insights on the essence of PSM, distilled from my 34 years in the industry, the past 19 of which have been spent solely as a “boots on the ground” PSM practitioner.  The paper focuses on several key elements which I believe make up the “heart and soul” of PSM and comments on the importance of and a few of the challenges presented by each of those elements and the systems used to manage them.

One topic I believe worthy of increased emphasis this time would be the need to recognize the importance of incorporating multiple layers of protection to ensure the maintenance of highly effective fully functioning PSM programs.  This key concept is brought to bear not only in conventional LOP analyses involving ranges of engineering and administrative controls, but in a broader sense, must also be appreciated as the interrelationships across the various PSM elements and systems are played out.

The presentation would offer some thoughts on the recent and future advancement of PSM, including the increased sophistication of regulatory oversight and the need to keep abreast of developments in this area.  It would then also touch on a few of the frustrations that can be encountered in PSM practice, including the fuzzy lines that can sometimes exist between quality and compliance (e.g., with respect to what a PHA revalidation should “look like”, dilemmas posed by “pie in the sky” internal policies and standards, considerations related to “recognized and generally accepted good engineering practices” and “limits”, etc.).  As with the 2012 presentation, a key takeaway would relate to the importance of never losing a sense of one’s own vulnerability with regard to future PSM events.

While shifting the emphasis as noted above, this presentation would also retain a number of key points from the 2012 presentation, as follows:

To reinforce the importance of not losing a “sense of one’s own vulnerability”, I would again briefly comment on a few incidents which have directly impacted me and/or others with whom I’ve closely worked over the years:

• Small dust explosion/fire in a fiber handling system.
• Explosion in a reactor piping system.
• Reactor explosion while a unit was down for maintenance.
• Explosion and fire in a compressor train during a unit startup.
• Major fire due to a hydrocarbon release from failed piping.

As mentioned above, I would again emphasize that all the PSM elements are important and must work together to provide the layers of protection that we rely upon, however I would note that over the years I’ve found that certain elements have sometimes come to be viewed as the “heart and soul” of PSM.  I would offer some brief thoughts and comments on the role and importance and a few of the challenges presented by each of these elements and the systems used to manage them:

• Process Safety Information
• Process Hazards Analysis
• Operating Procedures
• Management of Change
• Pre Startup Safety Review
• Mechanical Integrity
• Management Systems/Performance Audits

Regarding the “frustrations that can be encountered”, I would retain one comment that seemed to resonate with the 2012 audience:

• In the PSM world, we can really never prove a negative, in other words prove that something we did (or money we spent) actually caused something bad not to happen.  It’s similar to the challenge that the Department of Homeland Security faces every day.  They have to be right every time.  The bad guys only have to be right once.

In closing, I would again emphasize that over the past 20 years, the chemical, petrochemical and refining industries have made significant progress toward materially improving their process safety performance, but that we’re not there yet, that the bar will continue to be raised and that it will be up to each one of us, and those who will follow in our footsteps, to commit to always maintain a strong sense of our own vulnerability, to never be satisfied with anything less than full and proper execution of our systems and to always remember that yes, the things we do, do in fact make a difference, and that difference is that lives are saved, livelihoods are preserved, and our licenses to operate are continually renewed.