OSHA: Putting Process Safety Management into Motion

OSHA: Putting Process Safety Management into Motion

For many decades, the oil and gas sector has witnessed the occurrence of many accidents. The mounting number of these incidents rang the alarm bells for the sector’s experts to work on ameliorating the standards of Health, Safety, and Environment (HSE) in order to eliminate these catastrophes.

With an eye on the “S” part of HSE, it was found that there are two types of safety incidents: process safety and occupational safety. Process safety is considered more dangerous than the occupational one as it results in fire, explosions, and releases, which in return affect the whole HSE system, according to a paper entitled ‘Effective Implementation of Process Safety Management.’  Since the business’s success is contingent on lowering risks, an effective process safety management (PSM) becomes an imperative need to abate unsafe practices and prevent disasters.

Therefore, many PSM systems were created. One such system is the Occupational Safety and Health Administration (OSHA), which was created by the US Congress under the Occupational Safety and Healthy Act of 1970. OSHA set standards for managing hazards associated with work processes to ensure the availability of safe and healthful working conditions for the sector’s workforce.

Another PSM system is the Center for Chemical Process Safety (CCPS). The CCPS was created under the supervision of the American Institute of Chemical Engineers (AIChE), and it was adopted by several companies to control their processes.

OSHA, CCPS: The Bigger Picture

Each PSM system includes a set of elements. The implementation of these elements varies according to the criteria of the executing organization.

When it comes to OSHA, the Clean Air Act Amendments (CAAA) specified 14 elements that OSHA requires employers to implement, according to a ‘Process Safety Management’ paper by the US Department of Labor (OSHA 3132).

The first element concerns employee participation, which requires employee involvement in the development and execution of the PSM program, especially when it comes to hazard assessment. The second is process safety information, under which the employer has to compile information related to chemical hazards, as well as the equipment and technology involved in processes. The third is process hazard analysis that requires the employer to conduct accurate analysis of hazards using analysis techniques, with identified teams and recommended measures to mitigate such hazards. The fourth is the development and implementation of written operating procedures for processes over all phases of operation. The fifth focuses on training, as employers are mandated to provide all involved contractors and employees with appropriate training before beginning any process to ensure safe work practices. The sixth concerns contractors; all contractors involved directly or indirectly in processes must be evaluated to affirm that they have the appropriate capabilities as well as a safety history. In addition, all contractors involved in the process must receive proper training prior to commencing operations.

The seventh element is pre-startup safety review, which focuses on performing a detailed review of any new or modified system to ensure that the design is suitable, the construction adheres to the design specifications, the availability of operating procedures, that training and process hazard assessment are complete, and all process safety information is accurate. The eighth focuses on mechanical integrity which entails developing and implementing a methodical program for performing appropriate maintenance to discover any deficiencies in equipment. The ninth involves hot work permits, which includes developing a formal program to prevent fire and explosions from occurring while conducting hot work, including welding, cutting, brazing, grinding, etc. The tenth is management of change, which institutes documented procedures that aim to ensure safe system operation when changes occur to the system.

The eleventh element entails incident investigation to ascertain the causes behind incidents and develop recommendations to prevent them in the future. The twelfth is emergency planning and response, under which employers put in place plans to face emergencies that may arise in the facility. The emergency plan has to include notification procedures, escape routes, alarm systems, and plant-wide training. The thirteenth concentrates on compliance audits, which involves evaluating a PSM program with an implementation extent of three years at least. The audit process must certify that the plant is in compliance with the standards. Finally, trade secrets, which allow employers to protect their processes that are considered as trade secrets.

With an eye on the CCPS system, it includes 20 elements. Some of which are similar to the OSHA elements and others are not. For the dissimilar elements, the first one is about process safety culture, under which the CCPS system focuses on developing and sustaining the organization’s culture to determine the manner in which process safety is managed. Another element is maintaining process safety competency to encompass three interrelated actions, which are continuously improving knowledge, ensuring the availability of appropriate information, and the application of what has been learnt. For stakeholder outreach, it is a process for seeking out individuals or organizations that can be affected by the company’s operations, establishing a relationship with community organizations, and providing accurate information about the company and its facilities. Another dissimilarity is the conduct of operations; conduct of operations is the execution of operational and management tasks in a structured manner which is closely related to the organization’s culture. The CCPS also includes measurements and metrics to establish performance and efficiency indicators to monitor the effectiveness of the management system. A final dissimilar element is management review and continuous improvement to determine whether management systems are performing as intended and producing the desired results as efficiently as possible.

PSM in Egypt

The Ministry of Petroleum and Mineral Resources pays great attention to the enhancement of the HSE standards. That is why key industry leaders began discussions about the importance of improving the process safety system within the sector’s companies to be in line with the ministry’s vision and cope with the international standards for a more sustainable future. As a result, OSHA system was selected to be the main standard followed in Egypt.

Additionally, the Ministry of Petroleum launched a program including 74 young engineers and chemists from the HSE departments of several oil and gas companies. The participants managed to enroll in the training program after passing qualification tests. Moreover, they managed to finalize the first phase of the program.

Launching such programs aims to enhance the abilities of the oil and gas sector’s young professionals and support their talents, which is considered a main pillar in the Modernization Project.

As a reinforcement initiative to the vision of the Ministry of Petroleum and the Modernization Project, Egypt Oil & Gas launched the HSE Subcommittee. The HSE Subcommittee aims at ensuring that HSE standards are incorporated across the Egyptian oil and gas sector, as well as raising the level of awareness among the sector’s workforce.

Since slips, falls, and other incidents are likely to occur in the oil and gas workplace, it is vital to ensure that work environments are safe for all employees, and following a specific standard will guarantee that.


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