Process Safety
Share your safety experience and passion with next generation
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have asked Bob Rosen, retired from BASF, to help me write this column. Bob and I have been working with the senior Chemical Engineering plant design course students at Lehigh University in Bethlehem PA for several years as volunteers. Our job is to enhance student awareness of process safety and help them to understand the responsibility of process engineers for the safety of the facilities they design and operate. This has been a very rewarding experience, and I encourage readers to look for opportunities to share their knowledge, experience, and perhaps most importantly, their passion for safety with students in chemistry and chemical engineering. The Lehigh senior design class is a full academic year class in which the students are divided into 2 or 3 person groups, each of which is given a specific plant design project. The projects come from industry engineers who volunteer to work with a student group for the year. Each student group has a different project, and the range of technologies is large – for example, specialty chemical processes, refinery and natural gas processes, commodity petrochemical processes, and new technology such as alternative energy and bioprocessing. The range of potential safety concerns is equally wide. We essentially serve as the process safety department for the class, helping them to review their designs for process safety issues and identify approaches to risk management. Here are some of the important messages we try to convey to the students: They are responsible for the safety of their design. It is not the responsibility of the safety department (in this case the two of us). Process industry companies understand that safety, and process safety, are line responsibilities. Production management has control of the resources, personnel, and management systems required to operate a safe plant. In the case of a new design, the plant designers (for the course – the student design team) are responsible for designing a plant which is capable of being operated safely. They must also document how the plant must be operated and maintained so that it continues to meet their design criteria in the future. Ultimately, process safety is about understanding the technology of the plant, knowing
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ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
how the process works. Even more importantly, process safety is about understanding how the process can fail in ways that can cause a safety or environmental incident. Nobody understands the technology of a plant better than the people who design or operate it. Those people are best qualified to understand process safety risks, and develop technical and management systems to eliminate or manage those risks. Process control is critical to process safety. Development of process control strategies is an important aspect of the senior design project, and the importance of a robust control strategy for safety is emphasized. A plant which is under control is generally a safe plant. The safety department serves in a consulting role, but cannot have primary responsibility for the design of a safe plant. The engineers, chemists, and other technologists in the safety department have a general understanding of process hazards and material hazards. However, they cannot possibly have the in-depth knowledge of the hazards of a specific process that is developed by people who work with the process design and operation every day. The safety department consults with a wide range of plants, processes, and technologies (last year, for us, 17 different processes from the student groups), and cannot be experts on all of them. This is true for most process industry companies or plants, which will most likely operate a wide range of technologies and chemistries. There is a lot more to safety than following the regulations. Knowing and following the rules is certainly important, but meeting regulations does not ensure that a plant is safe. To some extent this is for the same reason that a company or plant safety department cannot have primary responsibility for safety. Government regulatory agencies are responsible for the full range of operations throughout their jurisdiction, covering a wide range of technologies and potential hazards. No regulations can ever cover every potential hazard which might be encountered in all of those activities. Nobody can understand how to manage the hazards of a specific operation better than those that design and operate it. Many processes which are not covered by the OSHA PSM regulation are
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just as hazardous as processes that are covered, but they use materials which are not on the OSHA PSM list. For example, sugar dust is not on the OSHA PSM list, but the February 2008 Port Wentworth, Georgia dust explosion in a sugar refinery killed 13 people, injured 42, and destroyed a large part of the plant. Also, regulations generally follow best industry practice, and often adopt those practices years after they have become common among industry safety leaders. For example, the OSHA Process Safety Management (PSM) standard was issued in 1992, and adopted many practices which had already been developed by industry leaders. The current Center for Chemical Process Safety (CCPS) Risk Based Process Safety elements go beyond the requirements of OSHA PSM. Safety culture, a personal belief in the importance of safety and recognition
of your own responsibility for safety are critical. While the designers and operators of a facility are best qualified to manage safety, they must accept that responsibility, understand how to manage safety, know when they need specialized knowledge or resources, and how to access those resources when needed. Plant designers must recognize that safety is an integral part of the design process. You can’t design a plant, and then call in the safety engineer and ask him to tell you what to do to make it safe! Safety cannot be separated from design. One of the best ways to promote improved safety and process safety in the future is to make sure that today’s students understand and accept their responsibility for their own safety, the safety of others, and the safety of the communities in which they work. They
Journal of Chemical Health & Safety, November/December 2011
must believe that safety is part of their job, whatever that job is, and not somebody else’s responsibility. One of the recommendations of the United States Chemical Safety Board from the investigation of the December 2007 T2 Laboratories Inc. reactive chemical explosion in Jacksonville, Florida was that the American Institute of Chemical Engineers (AIChE) and Accreditation Board for Engineering and Technology, Inc. (ABET) work together to add reactive hazard awareness to baccalaureate chemical engineering curricula requirements. AIChE has broadened this to require that the curricula provide graduates with knowledge to address the hazards associated with the types of processes covered by curricular objectives. To improve safety performance in the future we need to focus on safety awareness among the industry leaders of the future – today’s students.
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