1. Overview
2. Causes of failure to contain hazardous chemicals
3. Components of improving the ability to contain hazardous chemicals
4. Improvement implementational methodology
5. The EPSC PSF Guidance Cards

Overview

EPSC, EUROPEAN PROCESS SAFETY CENTRE, is an international not for profit organisation. It was founded in 1992 and provides an active network for members to work together on process safety. The containment of hazardous chemicals is a particular ‘sub-set’ of process safety management. The EPSC has a particular focus on this aspect of safety, and this page is based on their publication ‘Process Safety Fundamentals’. It points out that the successful containment of hazardous chemicals involves a distinctive combination of actions and approaches that thus warrant specific attention:

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• A focus on detailed operational management, involving process operators, supervisors, operational management, contractors and maintenance technicians:
• Involves relatively complicated and multi-faceted solutions, rather than simple ‘rules’.
• Sustainable improvement often requires involvement of multiple parties and levels, with iterative discussions and open dialogue.

The EPSC Process Safety Fundamentals (PSFs) described here do not replace existing safety management systems (including policies, safe systems for work, safety training programs, change management, critical task analysis and procedures etc.) but provide a tool to increase understanding on the items that can go wrong with respect to the containment of hazardous chemicals. They addresses 18 typical hazardous operational situations. Not all of these will be relevant to all production, storage, and handling sites, but provide a ‘menu’ that operators can select from.

Causes of failure to contain hazardous chemicals

EPSC carried out a large study of the causes of incidents that classify as process safety incidents (according to the International Council of Chemical Associations, ICCA, or the American Petroleum Institute, API, -recommended practice 754, Process Safety Performance Indicators for the Refining and Petrochemical Industries), among their industrial members. The result, shown in Figure 1, shows that the majority, 51%, of cases were caused by aspects of how the installation was operated. 35% were caused by a failure of the mechanical integrity of the plant, while 14% were due to the engineering design of the plant. Instances were typically caused either by operator handling or the maintenance of the installation. This indicates that operational excellence on process safety is of great importance.

Components of improving the ability to contain hazardous chemicals

This analysis of the causes of failed containment incidences indicates that there should be a focus on strengthening process safety operational excellence on hazardous sites. To obtain this, Leadership and Competency on the critical operational and maintenance tasks is essential. The effectiveness of the integrity assurance processes is highly dependent on demonstrated leadership by management at different levels of the organisation, but also by collective commitment demonstrated by the entire workforce.

To avoid chemical releases so called “barriers” need to be identified. These barriers can be hardware, human or organisational as shown in Figure 2. This page focuses on preventive and mitigating human barriers, and more specifically the operating discipline principles that need to be respected rigorously to avoid process safety incidents and accidents. This rule based layer forms a solid foundation on which the risk based methods can be built, which are used to prevent the more complex process causes of incidents.

Improvement implementational methodology

The deployment of the hazardous chemical PSFs differs from that typically used for Personal Safety Management. Personal Safety rules are introduced and managed as a set of non-negotiable simple requirements while the PSFs address more complex situations, where design and the practical situation need to be considered, to decide how the work can be executed safely. Therefore the PSFs allow for more flexibility, that is they have to rely more on advanced understanding and competency.

The intent of the PSFs is to emphasise some critical front-line tasks and behaviours that need to be fully understood and supported by all operational leaders to enable successful process safety performance. The deployment of the PSFs must allow a renewed focus on existing, good operating practices that must be right every time. However, in practice, full application of the PSFs may not be easy or even possible. It is also the aim of the PSFs to give visibility to these dilemmas that frontline operators may face and to engage them in a discussion with involved operational management on how to deal with these situations. In this context, the PSFs are not intended to be seen as “another set of rules”, but rather as an opportunity for discussion between front-line operators and operational management when difficulties arise in the execution of some critical tasks . In this context, the PSFs provide an excellent tool for leaders to instil an open culture to drive process safety excellence, which is an important requirement.

Leaders should:

• Drive safety from a position of care.
• Be visible in the field.
• Have a regular dialogue on the PSFs.
• Help front line staff to comfortably surface dilemmas, operational issues, and weak signals.
• Have a detailed understanding of the compromising factors in practical situations. Once dilemmas are brought forward, work with the front line to resolve the issues.
• Show curiosity. Seek to understand and comply with the PSFs before allowing deviations.
• Recognise risk normalization in many daily activities and address it.

The success of the deployment of the EPSC PSFs is highly depending on the way in which they are rolled out.

A description of suggested steps is given below:

Engagement Workshop

To introduce the PSFs, a workshop may be organised with key people in the operational chain to ensure their commitment and involvement. These people include representatives from operations, maintenance, process safety, asset integrity. The participation and commitment of senior leadership is vital for successful implementation of the PSFs. In the workshop, a presentation can be given about the PSF program and a discussion can be organised with front line operators on how to effectively implement the PSFs in the field. A formal plan for implementation of the PSFs, endorsed by all people involved, may be one of the deliverables of the workshop.

Analysis and promotion

To coordinate the implementation of the PSFs, a company may choose to nominate one or more stewards or champions. The role of the stewards/coaches includes the organization of sessions to give further clarification to enable front line workers to understand the scope and objectives of the PSF program. These sessions can also be used for discussions on possible front-line dilemmas in the application of the selected PSFs. The content of the EPSC PSF guidance sheets can be used as a tool in the discussions. In the discussion it helps if the people that work in the field can openly share all the cases, where there have been deviations from best practices.

The type and number of PSFs to be included in the program may vary. One or more of the EPSC PSFs may be selected. However, other PSFs may be included, based on specific local process safety challenges and supported by a thorough analysis of internal incident and leading indicator data related to actual or potential high consequence process safety events.

One option could be to initially select a minimum set of PSFs to be promoted during a pilot phase over a one-year program, allowing a better estimate of the required effort in terms of budget and resources allocation for a full-scale deployment over the following years.

Roll-Out

Below are some suggestions that can help with the roll-out of the PSFs within a company or plant. More details are provided by the PSF handbook, pages 8-11.

• Carry out a gap analysis, to identify strengths and areas for improvement.
• Implement education activities to improve awareness and motivation. Suitable tools can include HSE days, interactive exercises, toolkit talks, posters, videos and booklets.
• Build desired attitudes and behaviours into Human Resources processes and systems.
• Build PSF behaviours into broader HSE processes and systems.
• Integrate PSF behaviours into day-to-day operational practices.

Monitoring and follow-up

Management system activities should include monitoring and follow-up. In the case of PSFs (as part of process management), some time will be needed to measure the outcome of the implementation of PSFs (in terms of reduction of the number of process safety events related to operating integrity). A more immediate step change is more likely to be visible in terms of increased front-line awareness, competence and engagement in process safety.

The EPSC PSF Guidance Cards

Below are links to download guidance cards covering each of the 18 EPSC PSFs that have been developed so far. These guidance cards give supporting information for the implementation of the PSFs. They give a description of the operation principles to be followed, with a focus on hazards, possible challenges in the field and options for success. It should be noted that the list of 18 EPSC PSFs is not a comprehensive or exclusive list of all possible challenges that operators may face in the field. Therefore, other PSFs may be developed and adopted by companies depending on the local context and needs.

Apply double isolation

Empty and de-energise before line-breaking

Monitor an open drain

Manage over-rides of safety critical systems line-breaking incidents

Walk the line

Verify leak tightness after maintenance work

Avoid working behind a single valve

Verify the condition of flexible hoses

Operate within safe limits

Control utility systems connected to a process

Report deficiencies on safety critical equipment

Unplugging of equipment

Stay out of the line of fire

Control (un)loading

Check atmosphere in fire box before igniting the burners

Avoid splash loading

Avoid run-away reactions

Report process safety incidents

References

European Process Safety Centre. (2021). Process Safety Fundamentals

Links to related IFS Proceedings

843, (2020), Occupational and Process Safety in Ammonia Plants – Pitfalls to Avoid, H Duisters

749, (2014), First Practical Experience with Robot Inspection of Ammonia Storage Tanks, K Bakli, O N Mortensen, C Valand

745, (2014), Detection and Localisation of Leakages in Toxic/Flammable Chemicals Pipelines Using Distributed Fibre Optic Sensors, D Inaudi, R de Bont, R Walder

694, (2011), Risk Based Inspection Implementation: Increasing Plant Safety and Reliability, G Franceschini

674, (2010), A Fertiliser Company Approach to Improving Process Safety Performance, J-P Fossum, H Navsaria

673, (2010), Process Safety in the Fertiliser Industry, P Eames, J R Brightling

622, (2008), Corrosion Beneath Insulating Materials, F De Vogelaere / Safety and Protection of Overhead Pipework, N G Oates

604, (2007), Safety Issues in Ammonia Handling and Distribution ,K D Shah

603, (2007), Inspection of Atmospheric Ammonia Storage Tanks; New EFMA Recommendations, H A M Duisters

561, (2005), Urea-Ammonium Nitrate Solution: Corrosive Characteristics and Hazards, K DeMarsh

382, (1996), Control of Stress Corrosion Cracking in Liquid Ammonia Storage Tanks, R Nyborg, L Lunde, P-E Drønen