By E.J. (Ted) Lightfoot, Ph.D., principal consultant, Ted Lightfoot LLC

What is Process Safety Management, and what can be learned from it? Process Safety Management, or PSM, refers to a set of best practices for managing the safety of chemical processes that are mandated for high-hazard processes [1]. The converting industry usually operates below the threshold that triggers regulation, so why would people in the converting industry want to even think about these regulations? Because the regulations were developed from best practices used by leading chemical companies to analyze, document and train people on how processes are supposed to run (and not supposed to run). One of the primary challenges addressed by PSM is the turnover of people and the loss of knowledge that comes with changing personnel. And that is the biggest organizational problem in the converting industry today. A primary objective of PSM is creating documentation that facilitates bringing new people up to speed on the process, its hazards and how it is supposed to run. The focus of this article is on helping people in the converting industry create documentation to help minimize the impact of employee turnover on safety and operability.

There are many consulting companies that specialize in developing PSM systems for companies – each with its own way of organizing the program. The program structure is not spelled out in regulations, but the system must cover the required topics. Table 1 shows the elements utilized by the Center for Chemical Process Safety of the American Institute of Chemical Engineers. Other structures may show relatively little similarity at the top level. But, at the detailed level, they should cover all of the required specifics.

However, very few converting operations pursue PSM to the detailed level. Even such top-level elements as establishing a “process safety culture” may seem unwarranted. But, the converting industry is not an inherently safe industry. There are many well-recognized hazards, such as cuts, avulsion of fingers or arms and oven fires. In a typical year, there is at least one oven fire in the United States from solvent-coating operations. In some cases, those fires become deflagrations that destroy the oven. However, oven fires often are not the most significant hazard in the operation. The worst safety incident in the converting industry occurred in 2003 when a dust explosion killed six, injured 38 others and destroyed a laminating plant in Kinston, N.C. So, while converting may not pose the same level of public risk as incidents like Three Mile Island (that helped motivate the Seveso directive), there are reasons to treat process safety seriously in the industry. However, if operators work below the threshold (for flammable liquid hazards, the OSHA threshold is 10,000 lbs excluding atmospheric storage tanks, drums and hydrocarbon fuel on site), there is no legal requirement that companies adopt any element of PSM, and there are several best practices incorporated into PSM that many choose to ignore. Still, there are several components of PSM that every converting operation should consider. These are described below.

Components of Process Safety Management

One category of risks is from changing personnel (sometimes called “Management of Change: Personnel”). All PSM systems require written operating procedures that operators are trained on and formally qualified for before operating the equipment. This also is required for quality certifications such as ISO 9000. However, new operators also need to be trained on the hazards of the operation and hazard management systems. That should include documenting what personal protective equipment (PPE) is required for each procedure and for handling each material.

Closely related to the PPE matrix is the chemical interaction matrix. The chemical interaction matrix lists all of the chemicals utilized in the area (components of the coatings, as well as cleaning and other process aids, such as lubricants) and shows hazardous interactions between them. The optimal structure for this depends on the nature of the operation. For example, some operations coat only as received commercial adhesives, whereas other operations use hundreds of ingredients to manufacture a range of different products. There are commercial software packages for creating chemical interaction matrices. One free option is the Chemical Reactivity Worksheet distributed by the Center for Chemical Process Safety of the AIChE. In addition to a spreadsheet that helps identify hazardous interactions, it also comes with a mixture manager that can be used to formulate coatings (and that warns of safety hazards as ingredients are entered).

Another key tool for PSM is the Process Hazards Analysis, or PHA. All pieces of equipment that pose hazards should come from the manufacturer with a PHA (FM worksheet DS 7-43 Process Safety). This often is called a HAZOP if it is performed by “What-if…” analysis, while for more complex equipment, a Failure Mode and Effect Analysis (or FMEA) is used. However, the manufacturer typically will analyze the safety of only the equipment, not the safety of the installation. The Kinston explosion that killed six was not caused by the equipment; it was caused by the interaction of an ingredient and the building. There is much to be said for doing a complete PHA on the operating area. For some operations, the EPA requires a PHA to protect the environment from a chemical release as well. Doing a good PHA requires a skilled leader, and there are consultants who specialize in that.

Two analyses that are closely related to the PHA are the Layer of Protection Analysis (LOPA) and the Process Equipment Reliability Database (PERD). The LOPA analyzes the interlocks in the area and looks for failure modes that can create hazards, while the PERD looks at the reliability of equipment – in particular, the reliability of equipment that protects operators from hazards. The need for these varies with the scope of the operation.

The single most useful PSM document for most operations is the Technical Standard. For simple operations, all of the following may be included in a single Technical Standard; however, in most cases, it is convenient to break it up into smaller pieces. But the following elements need to be recorded:

• Process description: a clear explanation of how the process is supposed to work. This includes a description of the equipment, the general operating principles, the known hazards, the standards that apply to mitigate those hazards and a description of the mitigation strategy. Usually, it is convenient to have separate equipment files containing further details, including the operating manuals that came with the equipment; however, for simple operations, it may be convenient to include all of these in the Technical Standard.
• A complete list of chemicals utilized in the area and the Chemical Interaction Matrix. If the Chemical Interaction Matrix is kept in a separate system (e.g., computer spreadsheet), the Technical Standard should document the known hazards at the time the standard was written and give instructions on where to find the current spreadsheet.
• A list of safety incidents in the area
• A list of changes to the equipment. (This is separate from, but should reference, the detailed documentation that may be in the files for each piece of equipment.)
• A list of all products made on the line (in some operations with large product lines, this may need to be recorded separately, but at a minimum, the Technical Standard should list the major product lines and attributes), including when they were commercialized and what changes to the technology came with them. Many safety incidents come from hazards that were not recognized because the changes made were subtle (e.g., oven explosions caused by changing solvent blends). The Technical Standard should list all of the test authorizations and changes for the area.
• Safe Operating Limits for the equipment. Often, this is recorded in a system that records Standard Operating Conditions (with upper and lower limits for each variable). However, the Technical Standard should list key safety limits (e.g., maximum operating pressures of various pieces of equipment), while the SOC sheet often lists quality limits (QSOCs).

Looking at this list of documents can be daunting. However, the documents contain the information that a new engineer should have in order to be trusted in the area. Some, such as a PHA, require allocating time from experienced resources and are best facilitated by someone trained in doing PHAs. However, creating a Technical Standard can be integrated into the training of a new engineer, as illustrated in the next section.

Creating a Sample Training Program

For a sample training program, individuals should engage both the operators and experienced professionals in answering the following questions and creating the requested descriptions.

1. Describe the process (from start to finish).

2. What known hazards exist in the operation? What are the highest hazard operations in the production area?

3. Does the company have a safety management system?

4. Review the safety incidents for the past five (or more, if available) years.

5. Read the operating manuals for the process.

6. Read the Process Hazards Analyses that came with the equipment.

7. If there is no Chemical Interaction Matrix,

8. Make a list of all raw materials handled as powders.

9. Is there a protective equipment matrix listing the proper PPE for each procedure/each class of raw material? If not, create one.

10. Read the Technology Standard for the line, if it exists.

Summary

The biggest organizational challenge facing the converting industry is the rapid turnover of personnel and the loss of information that comes with that. High-hazard chemical operations face the same challenge and have developed “best practices” to address the issue. These since have been codified in regulations. Many converting operations will find the full scope of these practices to be onerous; however, there are elements of these best practices that make sense for any operation. This list of suggestions may not include all of the elements that make sense for a company’s operation, but the elements described here make sense for virtually all operations. 

Resources

1. In the US, PSM requirements are documented in 29 CFR 1910.119;, European requirements are laid out in Seveso III Directive. 2012/18/EU
2. https://www.csb.gov/assets/1/20/csb_westreport.pdf?13815, Videos are available on the internet.

E. J. (Ted) Lightfoot, worked for DuPont for over 35 years in film casting, coating and laminating. His experience includes R&D, plant support, being a Six Sigma Black Belt for Growth and helping customers develop and troubleshoot their products and processes. Ted can be reached at email: ejl@TedLightfoot.com, www.TedLightfoot.com.