Towards Management Systems Perfection – Successes with Implementing a Layer of Verification Analysis to Continually Treat Process Safety Risks

Trust, but verify, by continually checking everything! This paper will demonstrate the importance of verification as a critical step in continually improving the treatment of process safety risks, including implementing inherently safer designs and operating practices, and controlling residual risks.

A well-established design concept for management systems is the continual improvement lifecycle involving the steps: Plan-Do-Check-Act (PDCA). Similar to standards for managing quality, environmental, occupational health and safety, and security, models for effective process safety management (PSM) systems also utilize the PDCA cycle. At a higher level, the PSM elements of Mechanical Integrity, Incident Investigation and Compliance Audits address verification in the “Check” step; while every management process of the PSM System should incorporate a "Check" step with verification processes and procedures to monitor and assure compliance and performance. This paper will present a taxonomy of activities for meticulous verification against policies, objectives, plans and other requirements for a vibrant PSM system, showing the importance of examining, analyzing, assessing, confirming, inspecting, testing, and reviewing planned activities, desired conditions and achieved results.

Attendees will benefit from practical takeaways of how each management system element can be developed with "verification designed in" and a verification culture created to treat process safety risks at three opportune times: before the incident (prevention), during the incident (emergency management) and after the incident (incident investigation, root cause analysis and lessons learned).

A comprehensive case study with practical examples will be presented to demonstrate a proven technique of Layers of Verification Analysis (LOVA) as a best practice integrated into the conduct of a process hazard analysis (PHA). The case study will show the audience "how to" enhance the PHA facilitation wearing an "auditor’s hat" to raise questions and verify the effectiveness of existing safeguards, all of which are managed by the PSM System. Borrowing from the basic principles of management systems auditing, LOVA asks these questions for each hazard scenario: are systems, processes and procedures associated with causes (of human errors and equipment malfunctions), with consequences (of physical phenomena and resulting impacts), and with safeguards (for both engineering and administrative controls) (1) in place?, (2) adequately designed? and (3) effectively implemented? LOVA has also been used for supplemental analyses within the PHA to address human factors, previous incidents, facility siting and changes (e.g. MOCs). Recommendations from the LOVA in PHAs can be used as lessons learned for improving the implementation of the PSM system on a daily basis, without having to wait on the next periodic audit or PHA revalidation. The LOVA technique has been shown to be equally suitable for any stage of the process lifecycle, including inherently safer design evaluations.

The paper will also present three incident case histories to show how missing, inadequately designed or ineffectively implemented verification processes and activities have contributed to process safety incidents.

This paper will draw upon the authors’ extensive experiences in designing, developing, implementing and auditing PSM systems, as well as conducting PHAs, building siting evaluations, and incident investigations.