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PT Notes

Process Safety Incidents and Competency

PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.

A recent analysis of 68 incidents investigated by the Chemical Safety Board (CSB) identified competency of personnel as a key contributor to incident causation. In reviewing many incident descriptions, it is hard not to reach the conclusion that the people responsible for the processes were not competent in one or more ways in many cases. This issue likely underlies most of the process safety incidents that have occurred.

The decisions made by personnel ranging from managers to operators can be questioned for many incidents. While facility personnel may not have been obviously incompetent, in numerous cases clearly they were not competent to perform the work required of them safely. In particular, facility personnel often lacked an awareness and/or understanding of one or more critical aspects of a process, such as its hazards. Inadequate operator and mechanic training has been an issue in a number of incidents.

Facilities should implement a competency management program for process safety and critical personnel should be certified and periodically re-certified. For example, operators and mechanics should not be allowed to operate or maintain a process without demonstrating their competence, including such topics as knowledge and understanding of process hazards, the higher risks of non-steady state operations such as startup, previous incidents, the safe operating envelope for the process, handling abnormal and emergency situations, conditions under which the process must be shut down, use of permit-to-work systems, and the identification and management of changes. Responsibility for supervision of the operation of a process should be formally assigned to a single person and the responsibility formally transferred to another individual as necessary. There must be supervisory oversight of processes at all times.

In some incidents, the availability of technical expertise has been an issue. When critical decisions are faced regarding process safety, someone must be available who understands mass and energy balances, physical and chemical phenomena that may occur, process controls and safeguards, hazards present, and the safe operating envelope, that is, tolerable ranges of values of safety-critical parameters. Individuals should be designated as engineering and technical authorities who ensure the proper application of engineering standards and technical practices and adjudicate when deviations are proposed. They must be available for consultation at all times and they must have the authority to shut down processes without the need for consultation with managers and without recrimination. They must be free of production or commercial pressures and should report directly to upper management. A stop work authority that authorizes personnel to stop work in the face of imminent risk or dangerous activity and an ultimate work authority that requires designation of who has the authority for operational safety and decision making should be in place.

This topic is addressed in the article:

Insights into process safety incidents from an analysis of CSB investigations, Journal of Loss Prevention in the Process Industries, Volume 43, pages 537–548, September, 2016.

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