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PT Notes

Managing Process Safety During the Pandemic

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.

The COVID-19 pandemic has upset the routines of normal business. The pandemic poses very serious risks to the health and well being of people. However, risks from catastrophic process safety incidents still exist and must be managed. This is particularly true during a time when employees are distracted by the pandemic and operating and maintenance practices may deviate from the norm.

Care must be exercised to ensure process safety risks do not increase. This is not the time to ease up on process safety programs or defer important process safety studies, nor should the challenging times we face cause companies to lose focus on managing process safety. No company should have to face the problems presented by a process safety incident while trying to navigate the pandemic.

During stressful times, such as those we are now experiencing, it is common for human failure rates to increase. Usually, the concern in process safety is with the possibility of only one or a few employees experiencing stress at one time, but during the pandemic stress will affect all employees, which is a far more serious situation.

Stress may manifest itself in various ways such as inattentiveness to tasks, forgetfulness, inadequate communications, fatigue, and taking shortcuts with work. These factors can all be expected to increase process safety risks and they must be addressed and managed.

Key actions to take to help ensure process safety is not degraded include:

  • Monitor key performance indicators. Ensure they include factors attributable to the pandemic, such as increasing reliance placed on administrative safeguards.

  • Conduct MOC PHAs. Ensure organizational changes are addressed. Reduced or modified staffing due to absences from COVID infections or quarantine, or economic pressures from the effects of the pandemic must be considered. In particular, differences in the competency of substitute personnel or their familiarity with the plant’s processes must be addressed.

  • Update PHAs for current conditions. For processes experiencing multiple changes in their operation and maintenance, it is prudent to update their PHA studies to address the collective and synergistic effects of the changes and their impacts on the process hazards and risks.

  • Assess the risks of new ways of performing tasks necessitated by the need to reduce the risk of COVID-19 transmission, for example, maintaining physical separation and using appropriate PPE that would otherwise not be required.

  • Use PHA analytics to identify key safeguards that are susceptible to compromise and degradation during the pandemic so that special attention can be paid to ensuring their integrity.

  • Stay on schedule with PHA revalidations. It is as important as ever to ensure that process hazards are properly identified and the risks managed. PHA revalidations provide an essential means of doing so and must continue.

  • Perform audits and reviews during the pandemic. They provide an important means of identifying deviations from process safety requirements that may occur as a result of impacts from the pandemic.

  • Continue inspection, testing and maintenance of critical equipment. Often these activities are among the first to be deferred when companies face financial or other pressures. Process changes resulting from the effects of the pandemic may influence the designations of critical equipment. They should be reviewed and updated in light of changes.

  • Keep procedures updated. Modifications to the ways processes are operated are possible during the pandemic and they should trigger updates to the procedures. This may provide an opportunity to improve procedures as often existing procedures do not comply with CCPS guidelines.

  • Maintain focus on operational discipline. Human performance under stress may adversely impact key aspects of operational discipline such as alertness and judgment. Deviations outside the safe operating envelope or beyond limiting conditions for operation may occur. Operating under stressful conditions may result in the normalization of deviance being accepted. This must not be allowed to happen. Companies should provide a refresher briefing to employees that emphasizes the importance of operational discipline and the responsibilities of employees for its continuance. Also supervisors and managers should be vigilant in monitoring performance and addressing deviations promptly.

  • Manage contractors needed to supplement the workforce. Contractor personnel need to be properly briefed on process hazards and must be competent to perform the tasks assigned. Contractor selection and qualification should not be glossed over under pressure to maintain staffing.

Companies must avoid taking actions that would increase risk, such as:

  • Relaxing compliance with standards.

    • Government agencies still expect compliance with regulations. This includes the OSHA PSM standard that is essential to protecting workers and the EPA RMP rule that is essential to protecting the public and the environment from catastrophic process accidents.

    • The OSHA PSM and EPA RMP regulations are dated. AIChE’s CCPS has addressed many process safety topics that are not covered by the regulations in its Risk Based Process Safety (RBPS) program. RBPS elements such as Measurements and Metrics and Conduct of Operations are even more important now than before.

    • Compliance with industry standards such as IEC 61511 is critical to maintaining safe processes and must be continued.
  • Reducing stakeholder outreach.

    • During times of uncertainty, such as those posed by the pandemic, people need to be kept aware of developments that may affect them. This is particularly true for employees and contractors.

    • Community organizations and neighboring companies may benefit from awareness of how the impacts of the pandemic on your plant may affect them.

    • Local emergency responders should be informed of any changes in your plant that could impact on their ability to respond to incidents, e.g. switching from road to rail shipments of hazardous materials.

    • Local, state and/or federal authorities may need to be made aware of changes in your process safety practices.
  • Cutting back on training.

    • Refresher training for operators and mechanics is essential for a safe process.

    • Technical personnel need to maintain their skill sets and certifications.

    • Some professionals have found that working from home is more efficient and may be able to use some of their time for online training.

Some ways to adapt your process safety program to the pandemic environment include:

  • Attending virtual training to avoid gathering in groups of people. This is becoming a new way of life for many people ranging from students to professionals.

  • Facilitating PHA studies remotely. The occasional study has been facilitated this way over the years but the pandemic has resulted in a switch to this mode of facilitation. The capabilities of modern software video applications help to ensure the effectiveness of such studies wherein a meeting can be conducted with multiple participants who can see each other and collaborate on a project. Team members do not need to travel which reduces the cost of studies and makes more time available to conduct them. Subject matter experts located remotely can also easily be called upon to participate when needed.

  • Conducting reviews and audits remotely. Documentation and record reviews and personnel interviews can be performed remotely. A process walk though can be conducted by using appropriate devices to live stream video of the plant to people offsite.

Some key items to manage during the pandemic are:

  • Absence of key personnel.

    • Who are the backups?

    • Could backups be infected at the same time because they work physically together?

    • Can key employees be reached remotely should the need arise?
  • Supply chain disruptions.

    • Will you need to seek alternative sources of raw materials? What are the impacts on process safety? For example, will specifications change?

    • Will product back up in your plant? If so, will the risks change or increase?
  • Lack of availability of spare parts and materials for maintenance.

    • Do you have access to substitutes?

    • Do they qualify as replacements in kind?
  • The need to place your plant or processes in a dormant state because of disruptions in the supply chain or the need to shut down due to a COVID outbreak in the plant.

    • Have job hazard analyses addressed the risks involved?

    • Have you identified the risks of a dormant plant and how they will be managed?

We sincerely hope that this PT Note finds you, your family, friends, and colleagues safe and well.

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