Given the current circumstances surrounding the Covid-19 pandemic, face-to-face meetings may not be possible for upcoming process hazard analyses (PHAs) and other team-based studies at your facility. However, when it comes to the performance of process-safety-related compliance activities, regulators expect that companies will exert their best efforts to conduct studies on schedule. Increasingly, we are being asked by our clients about the practicality of remotely facilitating PHA studies.

The COVID-19 pandemic has seriously disrupted the operations of most companies. Many employees are working from home, physical distancing is necessary for employees working in proximity to each other, supply chain interruptions pose challenges, and the list goes on. In dealing with these challenges, it is easy for companies to lose focus on managing process safety risks, or even to seek relief from compliance with process safety program requirements in order to provide resources to address the disruption in operations. However, this is not the time to ease up on process safety programs or defer important process safety studies because the impacts of the pandemic on process operations may actually increase process safety risks.

Continual, lifelong learning is necessary for process safety personnel, but can easily be neglected. It contributes significantly to ensuring industrial processes stay safe and avoid catastrophic incidents that can harm employees, the public, the environment, and the company. Lifelong learning benefits the individual, the company, and the community at large. 

Process hazard analysis (PHA) studies provide large databases of information on what can go wrong in processes and the measures that have been taken to prevent incidents. Many companies view PHA studies simply as a means to identify hazard scenarios to comply with regulations and help ensure necessary risk reduction measures have been taken. 

With more companies instituting competency management programs, greater scrutiny is being placed on the selection of PHA/LOPA facilitators, regardless of whether they are third-party or internal resources. As companies see the value of conducting high quality PHA studies, more emphasis is being placed on finding a facilitator who is thoroughly competent to perform a top notch study. But how do companies assure the competency of potential PHA/LOPA facilitators? Simply finding someone who has some knowledge of the process being reviewed isn’t enough. Neither is a reference check or two. 

Combustible dust fires and explosions have resulted in many process safety incidents that have caused multiple fatalities and injuries together with considerable property damage. According to the US Chemical Safety Board (CSB), 386 major incidents occurred from 1980 to 2017. They killed 178 people and injured 1021 people. The incidents came from a wide variety of industries. 

In everyday life, people learn from their own and others’ experiences, mistakes, and daily activities. But what about learning when attending a training course? Remembering everything covered during a course and putting it into practice is a challenge. There is simply too much information to process in a short time and to retrieve from memory when necessary.

Preparation is key prior to starting any task. Buildings are not constructed without blue prints. Projects are not started without first knowing you have all required items to complete tasks successfully. Performing process hazard analysis (PHA) studies shouldn't be any different. Protocols should be used to ensure all necessary information is available.

Every three years, companies in the process industries must perform a compliance audit for their Process Safety Management (PSM) systems and Risk Management Programs (RMP). Many companies turn to third parties for assistance in conducting their PSM / RMP compliance audits in order to gain an outside perspective regarding implementation of PSM and RMP practices at their facility. However, companies often focus on the wrong factors in making a decision on selecting a third-party auditor. 

Process hazard analysis (PHA) studies identify hazard scenarios in order to determine whether or not existing safeguards need to be enhanced or new safeguards installed. Consequently, recommendations to reduce hazard scenario risks by mitigating the severity of their consequences or reducing their likelihood must be developed.