Cover Page

ESSENTIAL PRACTICES FOR CREATING,
STRENGTHENING, AND SUSTAINING
PROCESS SAFETY CULTURE




CENTER FOR CHEMICAL PROCESS SAFETY
of the
AMERICAN INSTITUTE OF CHEMICAL
ENGINEERS

New York, NY









Wiley Logo

Wiley Logo

Disclaimer

It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry; however, the American Institute of Chemical Engineers (AIChE), its consultants, the AIChE’s Center for Chemical Process Safety (CCPS) Technical Steering Committee and the Process Safety Culture Subcommittee members, their employers, their employer’s officers and directors, AcuTech Group, Inc. and its employees, and Scott Berger and Associates LLC and its Principal, do not warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in this book. As between (1) the AIChE, its consultants, the CCPS Technical Steering Committee and Subcommittee members, their employers, their employer’s officers and directors, AcuTech Group, Inc. and its employees, Scott Berger and Associates LLC and its Principal, and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequence of its use or misuse.

SUPPLEMENTAL MATERIAL AVAILABLE ON THE WEB

Additional content referenced in this book as well as an electronic form of the culture assessment tool are available at www.aiche.org/ccps/publications/guidelines-culture

ACRONYMS AND ABBREVIATIONS

AI
Asset Integrity
AIChE
American Institute of Chemical Engineers
ALARA
As low as reasonably achievable
ALARP
As low as reasonably practicable
ANSI
American National Standards Institute
API
American Petroleum Institute
BBS
Behavior based safety
CBT
Computer-based training
CCC
Contra Costa County
CCPS
Center for Chemical Process Safety
DCS
Distributed control system
DIERS
Design Institute for Emergency Relief Systems of the American Institute of Chemical Engineers
EHS
Environmental, health, and safety
FMEA
Failure modes and effects analysis
HAZCOM
Hazard Communication (Standard – a U.S. regulation)
HAZOP
Hazard and Operability (Study)
HAZWOPER
Hazardous Waste Operations and Emergency Response (Standard – a U.S. regulation)
HIRA
Hazard Identification and Risk Analysis
HSE
Health and Safety Executive (United Kingdom)
IPL
Independent protection layer
ITPM
Inspection, testing, and preventive maintenance
ISA
International Society of Automation (formerly Instrument Society of America)
ISO
International Standards Organization, Industrial Safety Ordinance
ISD
Inherently safer design
LOPA
Layer of protection analysis
MI
Mechanical Integrity
MKOPSC
Mary Kay O'Connor Process Safety Center (Texas A&M University)
MOC
Management of Change
NEP
National Emphasis Program
NFPA
National Fire Protection Association
OE
Operational excellence
OSHA
Occupational Safety and Health Administration
PDCA
Plan-Do-Check-Act
PHA
Process hazard analysis
P&ID
Piping and instrument diagram
PSI
Process safety information
PSM
The USA OSHA Process Safety Management Regulation
PSMS
Process safety management system
PSSR
Pre-start-up safety review
QRA
Quantitative risk analysis
RAGAGEP
Recognized and generally accepted good engineering practice
RBI
Risk-based inspection
RBPS
Risk-based process safety
RC
Responsible Care®
RCA
Root cause analysis
RMP
Risk management program/risk management plan
RP
Recommended practice
SDS
Safety Data Sheet
SIL
Safety integrity level
SIS
Safety instrumented system
SOP
Standard operating procedure
SWP
Safe work practice
UKHSE
Health and Safety Executive (United Kingdom)
VPP
Voluntary protection program

GLOSSARY

CCPS has developed a standard glossary that defines many common terms in process safety. By reference the current CCPS Process Safety Glossary at the time of publication is incorporated into this book and can be found at http://www.aiche.org/ccps/resources/glossary. Additionally, there are some specific terms used in this book that are not currently included in the standard glossary. These terms are defined in the book as necessary when they are introduced.

ACKNOWLEDGEMENTS

The American Institute of Chemical Engineers (AIChE) and the Center for Chemical Process Safety (CCPS) thank the Process Safety Culture Subcommittee members and their CCPS member companies for their generous efforts and technical contri- butions to this book. CCPS also thanks the members of the CCPS Technical Steering Committee for their advice and support.

CCPS Process Safety Culture Subcommittee

The Chairs of the Process Safety Culture Subcommittee were Eric Freiburger of Praxair and Shakeel Kadri, then of Air Products and now CCPS Executive Director. The CCPS staff consultant was Bob Rosen. The Subcommittee members were:

Steve Arendt ABS Consulting
Steve Beckel Potash Corp.
Henry Brinker Monsanto
Cho Nai Cheung Contra Costa County
Gretel D'Amico Pluspetrol
Michael Dossey Contra Costa County
Walt Frank CCPS Emeritus
Lou Higgins Solvay Specialty Polymers
Tom Janicik Covidien – Retired
Dave Jones Chevron
Jack McCavit CCPS Emeritus
Dan Miller BASF (Retired)
Gilsa Pacheco Monteiro Petrobras
Anne O'Neal Chevron
Richard Piette Suncor
Ravi Ramaswamy Reliance Industries Ltd. (Retired)
Randy Sawyer Contra Costa County
Karen Tancredi Chevron

CCPS offers special thanks to subcommittee members Anne O'Neal, Karen Tancredi, Steve Arendt, Gretel D'Amico, Gilsa Pacheco Monteiro, and Dan Miller, who provided significant input during the production of this book.

CCPS acknowledge AcuTech Group, Inc. for preparing the original manuscript. The AcuTech Team, under the leadership of Project Manager Michael J. Hazzan, also included David M. Heller, Scott Berger, and Martin R. Rose. Lou Musante of Echo Strategies provided additional content under subcontract.

Scott Berger of Scott Berger and Associates LLC provided a structural edit of the manuscript, provided additional content, and typeset the final book.

Peer Reviewers

Before publication, all CCPS books undergo a thorough peer review. This book was no exception; many people offered thoughtful suggestions and comments.

Wendy Alexander Nova Chemicals
Steve Barre Huntsman Chemicals
Michael Broadribb Baker Risk
Jonas Duarte Chemtura
Warren Greenfield Ashland Chemicals (retired)
Dennis Hendershot CCPS Emeritus
John Herber CCPS Emeritus
Jim Klein ABS Consulting
Paul Leonard Arkema
Bill McEnroe Monroe Energy
Paul Nielson Cheniere Energy
Lawrence Pearlman Oliver Wyman
Dennis Rehkop Tesoro
Susie Scott Oliver Wyman
Mike Smith Plains Midstream
Mark Trail ExxonMobil- Retired
David Black Baker Risk
Dan Wilczynski Marathon Petroleum
Omer Wolff Formosa Plastics USA

PREFACE

I have worked in different sectors of the chemicals and oil refining businesses since the 1960s. I began as a lab technician who worked shifts for a major chemical company in Northern Ireland, where I grew up. It was there that I experienced my first and only chemical process fatality during my working years in the chemical industry. I have very vivid memories of that tragedy to this day.

Later I went to work for a chemical company in the United States and I quickly realized it was vitally important to pay careful attention to preventing accidents as the chemicals we worked with included carbon monoxide, phosgene, chlorine, isocynanates and peroxides. In 1982, I served as the environmental manager in a chemical plant that had a catastrophic explosion. The details of that event and its aftermath are embedded deeply in my memory.

In 2002, I was appointed to the U.S. Chemical Safety Board (CSB) as a Board Member and later as Chairman. At the CSB we investigated failures in the chemical, oil refining and other industries – failures that resulted in loss of life, property damage and community outrage. Sadly, I saw many examples – fires, dust explosions, loss of containment, mechanical integrity failures.

In my early years in the chemical industry there was a strong focus on safety, but the emphasis was on the slips, trips and falls type of safety – avoiding injury to workers. Metrics were developed for first aid cases, reportable injuries and lost work day injuries. This was and still is a good practice and for the more progressive companies it made for a safer workplace environment. These companies were said to have a strong safety culture. Of course, process safety was still important, but not in an organized way. We knew the hazards of phosgene or dinitrotoluene and we took steps to mitigate those hazards. In the more enlightened companies, greater attention was paid to the chemical process hazards, but the culture in many companies was to equate overall safety with personnel safety, including some measures of process safety.

While the personnel safety record in the chemical and oil industry was better than general industry, unfortunately there continued to be major and well publicized fires and explosions in these industries. Tragedies such as the 1989 Phillips 66 explosion in Pasadena, Texas, the 1974 Nypro cyclohexane explosion in Flixborough, England, and the 1988 Shell refinery explosion in Norco, Louisiana. In response to these and other incidents, the U.S. Occupational Safety and Health Administration published its regulations on the process safety management of highly hazardous materials, commonly known as OSHA PSM. The 14 elements of PSM set an obligation for the safe operation of facilities with highly hazardous materials. The process industries have been required to comply with these regulations since 1992.

However, when the fourteen elements of PSM are examined there is an omission. That omission is the development and assessment of the process safety culture. I am very pleased that this absence has now been remedied by the publication of Essential Practices for Creating, Strengthening and Sustaining Process Safety Culture by the Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers. This excellent book fills a gap in the literature on process safety and guides companies and manufacturing facilities on the road to a strong process safety culture. It is the latest in a series of more than 100 high quality texts on process safety published by CCPS, many of which can be found on shelves in chemical plants and oil refineries around the world. Writing CCPS books requires the volunteer efforts of many experts from the chemical and oil industries. It is a time consuming but very satisfactory labor of love. I know because I have participated in the writing of a CCPS book.

This book offers several definitions of process safety culture. Even though there may be some disagreement about a definition of process safety culture, when you visit a facility you very quickly get a sense how important a positive process safety culture is to the facility. You will know it when you see it. From the first moment when you encounter a security guard or a receptionist to a tour of a control room you can quickly gauge the culture. Are process safety metrics displayed around the plant? Are operators communicating with each other in a professional manner? Is the senior manager well versed in the hazards of the operation?

As you read this book you will learn many aspects of how to develop a sound process safety culture. From my experience, a strong process safety culture must start with leadership. By leadership I mean everyone in a leadership position from the chairman of the board to the supervisor on the shop floor. They must set the example. It starts with leadership being aware of the hazards in their processes and putting in place the organization and expertise to control those hazards. Just as important, the senior leadership must communicate his or her concerns about the need for an effective process safety program. These concerns should be an ongoing part of senior leadership's communications with the organization. This is the way to ensure the establishment of a culture of process safety across the organization.

I commend CCPS on the publication of its latest book and I encourage readers to turn its lessons into actions in their day-to- day work of ensuring safety for employees, contractors and the surrounding community. As well as saving lives and preventing injuries it is vital for the financial success and reputation of the chemical process industries.

John S. Bresland

Shepherdstown, West Virginia

NOMENCLATURE

Culture:
When used alone in this book, the term culture specifically means process safety culture, and the two terms are used interchangeably. When used to refer to other types of corporate culture, the specific type of culture will be specified, e.g. business culture.
Element Names:
Process safety element names have been taken from CCPS Guidelines for Risk Based Process Safety. When alternative names are in common use, both the RBPS name and the common name are used, e.g., HIRA/PHA.
Operations:
The full spectrum of tasks and activities involved in running a facility, including process operation, maintenance, engineering, construction, and purchasing.
Operator:
An individual who runs the process from the control room and/or the field.
Process safety:
A disciplined framework for managing the integrity of operating systems and processes handling hazardous substances by applying good design principles, engineering, and operating practices. It deals with the prevention and control of incidents that have the potential to release hazardous materials or energy. Such incidents can cause toxic effects, fire, or explosion and could ultimately result in serious injuries, property damage, lost production, and environmental impact.
Process safety management system (PSMS):
A management system for implementing process safety. PSMSs include Risk Based Process Safety (RBPS) as defined by CCPS, the many PSMSs developed by companies to suit their specific requirements, PSMSs specified by regulations, and others.
References to process safety culture core principles:
Throughout the book the names of the core principles of process safety culture are typeset in italics. Italics are also used when the context requires use of a different syntax, including the negative forms, such as “They allowed deviance to be normalized, leading to…”
Should vs. must and shall:
The term should, used throughout the book, refers to actions or guidance that are recommended or presented as options, but not mandatory. The pursuit of process safety culture is very personal, and therefore a single approach cannot be mandated. The terms must and shall, commonly used in voluntary consensus standards and regulations, appear in this book only when quoting other sources. Quotes are offered only to provide perspective, and their use in this book does not mean that the authors consider the quoted text to be mandatory.

EXECUTIVE SUMMARY

Leading process safety practitioners have long recognized that the way leaders shape attitudes and behaviors can make the difference between success and failure in preventing catastrophic incidents. Investigations of incidents in the chemical, oil and gas sectors, as well as experience in the nuclear, and aerospace sectors have shown cultural failures rival management system failures as leading causes. Similarly, when long-term successes have been achieved, strong cultures of process safety excellence have been an integral factor.

This book provides current guidance on developing and improving process safety culture. It discusses how leaders can develop the commitment and imperative for process safety at the top, and then cascade that commitment throughout the organization. It shows how leaders can take the ultimate responsibility for process safety, and foster the core principles of process safety culture.

Of course, process safety culture does not exist in a vacuum relative to overall company culture. Changes to process safety culture may thus require changes in other aspects of the company culture, including, for example, operational excellence, human resources, and quality. This should not be viewed as a zero-sum game. Process safety may borrow key positive cultural attributes from other parts of the culture. Likewise, strengthening process safety culture may help strengthen other parts of the overall culture.

Leaders at any level of the organization will benefit from the guidance provided in this book. Senior executives will likely be drawn most to the first 3 chapters and the beginning of chapter 5, while the remainder of the book contains more detailed guidance useful at the implementation level. However, all readers will find useful information throughout the book.

After defining process safety culture, this book outlines 10 core principles of process safety culture:

The book then shows how these core principles strengthen process safety management systems (PSMSs), which implemented together can lead to success. The role of process safety culture in metrics, compensation, and other related activities is addressed. Lastly, the book discusses how to make process safety culture sustainable.

Appendices include more detailed descriptions of several concepts presented in the book, such as organizational culture, human behavior, and high reliability organizations, along with case histories useful for prompting culture discussions and a process safety culture assessment checklist.

The concepts discussed in this book began to be developed in the wake of the loss of the Space Shuttle Columbia. Members of CCPS toured the Columbia launchpad the day before launch as part of a learning-sharing session with NASA safety experts. This personal exposure to tragedy motivated Jones and Kadri (www.aiche.org/ccps, “Process Safety Culture Toolkit”) to lead an effort to capture key culture lessons-learned from the Columbia investigation and apply them to the process industries.

Since that time, lessons continue to be learned about what makes process safety culture effective. This book attempts to distill the significant amount of published work, as well as the personal experience of CCPS member companies into actionable guidance.

Like other CCPS books, the guidance provided includes numerous options companies can choose from to suit their needs. While the book has been prepared with the similar care of a voluntary consensus standard, it is not a standard or a code, and has no legal or regulatory standing. And that is entirely appropriate to the mission of process safety culture – to create an imperative for process safety with felt leadership that comes from the heart, not forced by requirement.