Magazine article Occupational Hazards

Process Safety Management Programs: Continuous Quality Improvement; the News Reports Were Chilling. Some 200,000 People Were Injured with More Than 2,500 Fatalities from the Methyl Isocyanate Release at Bhopal. Could It Happen at Your Company?

Magazine article Occupational Hazards

Process Safety Management Programs: Continuous Quality Improvement; the News Reports Were Chilling. Some 200,000 People Were Injured with More Than 2,500 Fatalities from the Methyl Isocyanate Release at Bhopal. Could It Happen at Your Company?

Article excerpt

At the time of the methyl isocyanate release at Bhopal, I was working in the corporate offices of a Fortune 50 company. The stillness of the air in the headquarters offices and the questions on the faces of executives were quite obvious. "Could it happen here? What will be the fallout for our company? What do we need to do to make our operations safer? Will there be a regulatory response affecting our operations?" I am sure that these questions and concerns were prevalent throughout the world's chemical-producing companies.

[ILLUSTRATION OMITTED]

Almost beyond belief, just months after the Bhopol incident, the unthinkable happened again--a facility released methyl isocyanate into the community of Institute, W.Va., just a few miles from where I was working. There were no fatalities, but more than 135 people sought medical treatment for exposure. It now appeared certain that new regulations were coming and coming soon, and the overriding question was, "How will we implement and manage improved safety processes for our chemical operations?"

Among the regulatory responses in the years following the Bhopal incident, OSHA implemented the Process Safety Management (PSM) standard (29 CFR 1910.119). The Environmental Protection Agency (EPA) promulgated a similar regulation. Accidental Release Prevention Requirements: Risk Management Programs, under the Clean Air Act Risk Management Plan (RMP) Rule (40 CFR Chapter 1, Subchapter C, Part 68). Industry now has nearly a decade of experience in implementing PSM and RMP. Herein are some of the resulting accomplishments and issues of implementation that we have seen.

IMPLEMENTATION AND CONTINUOUS IMPROVEMENT

Our PSM and RMP consulting projects and program audits have indicated that facilities, overall, are making concerted and effective efforts to implement programs and procedures to comply with applicable rules. With over a decade since the PSM and RMP rules became effective, covered facilities have the core regulatory elements in place. Efforts now are primarily for continuous quality improvement.

Some of the areas undergoing continuous quality improvements include:

* Improved communication and interaction among facility technical, operations, maintenance and management personnel teams during periodic and systematic reviews of covered processes.

* More reliable processes resulting from process hazards analysis (PHA) team problem-solving efforts.

* PSM-RMP Audit Team activities and findings are shared among facilities within the same corporations to enhance the implementation of safer equipment and procedures.

* Covered process system components are listed and tracked in greater detail.

* On-site libraries of manufacturers' manuals and design manuals are compiled to establish a core repository of technical references for system instrumentation and other components.

* Service lifetimes for piping, vessels and other components are determined by mechanical engineers, so that replacements are scheduled and replaced well-before the end of projected service life.

* Computerized preventive maintenance databases are utilized to schedule timely maintenance and replacements of system components.

* Redundant operating systems are installed, so one system is operating while another is undergoing preventive maintenance. This allows continuity in process production in one system, while a companion system is undergoing overhaul.

PSM and RMP regulations mandate periodic and systematic evaluations of covered processes containing "listed" chemicals meeting threshold quantities. The evaluations, whether in the form of PHA, audits, pre-startup safety reviews or operating procedures preparation and reviews, bring together the facility personnel--engineers, operators, maintenance technicians, safety specialists, trainers, chemists, managers and, often, consultants--to dynamically review and evaluate a covered chemical process. …

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