Summary Bullets
Failure to consider hazardous materials not covered by a regulation
Failure to address processes and equipment malfunctions beyond requirements
Failure to maintain a questioning attitude
Background
A specialty chemical facility that produced many products had several product families that involve highly exothermic reactions. The facility had several normal and emergency cooling systems for the reactors that produce these products, including back-up diesel emergency generators.
The feed materials were both toxic and/or flammable and highly volatile. The reactors process chemicals were addressed by regulation, but the final products were not covered, were not highly toxic or flammable and had low vapor pressures. The reactors had multiple Basic Process Control System and Safety Instrumented Systems that monitor and control reactor temperature, pressure, and level, as well as dual relief devices.
The feed materials were both toxic and/or flammable and highly volatile. The reactors process chemicals were addressed by regulation, but the final products were not covered, were not highly toxic or flammable and had low vapor pressures. The reactors had multiple Basic Process Control System and Safety Instrumented Systems that monitor and control reactor temperature, pressure, and level, as well as dual relief devices.
What Happened
The facility defined the regulatory boundaries of the facility to include all equipment from raw material storage to just before the first valve downstream of the reactors. They argued that since the products were not regulated, the equipment handling them need not be addressed in the Process Safety Management System (PSMS). Note that the valve is a remotely operated by instrument air and opens and closes automatically based on the temperature in the reactor.
The facility also excluded the cooling systems for the reactors, including the backup power systems from the PSMS, since water and power are not regulated, and in any case, other reactor safeguards protect the reactor in case of thermal runaway. The regulatory manager corporate legal have reviewed and approved the PSMS boundaries.
What could be the impact of excluding utilities, back-up power, and the downstream valve from the PSMS?
The facility also excluded the cooling systems for the reactors, including the backup power systems from the PSMS, since water and power are not regulated, and in any case, other reactor safeguards protect the reactor in case of thermal runaway. The regulatory manager corporate legal have reviewed and approved the PSMS boundaries.
What could be the impact of excluding utilities, back-up power, and the downstream valve from the PSMS?
Safety Culture Focus
Strong leadership supports hazards analyses beyond the minimum requirements to ensure the safety of personnel and processes.
Safety must be an integrated part of all activities and not limited to specific areas of operations.
The optimum safety culture includes a questioning environment to identify and mitigate potential hazards
Safety Culture Focus Note
**Only 54% of those surveyed indicated risk planning was a strength in their organization.**
Source File
E.03.pptx
(325.27 KB)