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PSM RM - Understand hazards and risk

Organizations that understand hazards and risk are better able to allocate limited resources in the most effective manner. Industry experience has demonstrated that businesses using hazard and risk information to plan, develop, and deploy stable, lower-risk operations are much more likely to enjoy long term success.

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PSM RM - Understand hazards and risk

  1. 1. KEY PRINCIPLES ESSENTIAL FEATURES WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW Ensure Consistent Implementation 1. Create a written policy governing the knowledge element. Develop and widely distribute a simple index that clarifies accountability for maintaining process knowledge. 2. Specify in the written policy the scope of the knowledge element, including the various types of information and documentation that should be created/compiled for each unit at the facility. 3. Compile chemical hazard information, process technology information, and process equipment information 4. Include in the written policy governing the knowledge element what process knowledge is needed as a function of the life cycle of a process. Usecentral technical groups to develop and maintain process knowledge. Thoroughly Document Chemical Reactivity and Incompatibility Hazards 5. Include in the written policy governing the knowledge element a specific standard for documen- tation of chemical Document saje conditions!features that are incorporated into the design of the process • Review audit results to determine if any significant gaps were identified. Extend the process knowledge to encompass information needed for efficient operation Make Information Available and Provide Structure See the corresponding work activities for the cornpetency element (Section 5.3.2). Implement a centralized database for process knowledge. 7. File documents by equipment or type of information rather than by capital project number, change authorization number, date, project leader's name, an so forth. Develop a standard template or set of forms for recording process knowledge 8. Seek to eliminate parallel copies of process knowledge, particularly if they are not sanctioned as part of the knowledge element. Createpartially completed forms or databasesfor process knowledge. Store Calculations, Design Data, and Similar Information in Central Files 9. Retain the calculations and data that support the process knowledge. Create partially completed forms or databasesfor process knowledge. 10. Develop standards for analysis methods, symbols, terminology, and software. Include specifications for delivery of process knowledge in the scope of work for new capital projects. Provide contextfor process knowledge. Reduce demand on engineering resourcesfor troubleshooting, plant turnarounds, and minor capital projects. 12. If a company policy or regulation requires a particular type of process knowledge that does not apply toa specific unit or process, clearly document that it does not apply and why it does not apply. Create company- orfacility-specific safety data sheets. Control or Limit Access to Out-of- Date Documents 13. Implementa means to control!limit access to out-of-date process knowledge . • Accuracy of process knowledge during periodic reviews. 14. Periodically review the accuracy of process knowledge. • Number of times during audits or assessments that process knowledge (or duplicate copies of reports, etc.) must be retrieved from personal files. 15. Periodically assess the adequacy of process knowledge, and gather new information when needed or request new information from the competency element. • Number of change requests initiated to ''correct" process knowledge Protect Against lnadvertent Change 16. Assign persons with proper knowledge and experience to review and approve corrections or changes to process knowledge. • Engineering staff time spent recreating process knowledge. 17. Survey the organization periodically to determine if different departments have established redundant file systems for knowledge. • Backlog of change requests related to completing updates to process knowledge. 18. Maintain a protected archive of the process knowledge at a separate facility and update the archive file on a regular basis. • Results of random checks of process knowledge files after change requests are closed. 19. Ensure that designers and other persons assigned to compile and maintain information under- stand the definition of a "change" and the scope of the management of change element. • Average number of days required to have a drawing revised. • Ratio of approved change requests (involving equipment changes) to updates to P&IDs. • Results of periodic opinion surveys to determine if users of process knowledge believe that it is current and accurate. 21. Implementa means to check out copies of process knowledge for revision. • Results of random checks of MSDS files to determine if they are complete, current, and accurate. Ensure Awareness 22. Determine if employees who need to use process knowledge thoroughly understand how to use it and how to interpret data it contains. If gaps exist, provide suitable training. Ensure that Process Knowledge Remains Useful 23. Assess whether the information is adequate to meet the needs of the risk element and other RBPS elements at each point in the unit's lije cycle. • Review the facility's policy for the knowledge element to ensure that roles and responsibilities have been assigned. Is a particular person, by name or job title, responsible for maintaining each aspect of the process knowledge? • If any relevant projects are under way at the time of the review, such as conversion from a paper- based system toan electronic storage system, determine if the project is going as planned . If not, identify possible roadblocks that could be cleared by management. • Survey the organization to determine if any effort exists to maintain part of the process knowledge or closely related information in an unofficial system. • Review how archived (out-of-date) documents are stored. • Review the means used to protect process knowledge from loss or inadvertent change. • Interview relatively new employees to determine if they can navigate their way through the process knowledge that pertains to their job duties. • If a policy is in place to review process knowledge prior to a risk analysis, develop a "process knowledge report card" for the as- found condition (i.e., number and type of corrections required). Assign Responsibilities to Competent Personnel 6. Ensure that competent personnel are responsible for (1) maintaining current and accurate process knowledge and (2) reviewing changes to the process knowledge. • The number or percent of blank records in the process knowledge database. • Number of PHA team recommendations that include an indication ofless than adequate process knowledge where the information was not available. • Number of incident investigations that include an element of discovery • Is the information needed to properly manage risk and safely operate the facility well documented and widely understood? • Determine how much effort has been applied to updating existing process knowledge. • Determine how much effort has been applied to developing new process knowledge. • Determine how much engineering effort is being spent recreating lost or misplaced information. • Sample sorne of the data repositories, such as drawing files, MSDS files, or equipment records, to determine if the data exist and appear to be current and accurate. Electronically link the knowledge and management of change elements. Treat mismanagement of process knowledge as a near miss incident. • Frequency that process knowledge is accessed. Fully integrate maintenance of process knowledge into day-to-day activities. • Is it likely that facility personnel can locate current and accurate information that collectively makes up the process knowledge in a timely manner? • Is this information accurate? U N D E R S T A N D H A Z A R D S A N D R I S K Ensure Accuracy Protect Against Physical (or Electronic) Removal or Misfiling Support Efforts to Properly Manage Change 20. Provide a means to ensure the fidelity of process knowledge and prevent unauthorized changes that would corrupt the information. 8.3.3ProtectandUpdatetheProcessKnowledge 8.3.4Use Process Knowledge 6- P R O C E S S K N O W L E D G E M A N A G E M E N T Make the process knowledge management element the hub for all process knowledge. Develop a centralized infrastructure. Protect Knowledge from Inadvertent Loss Document Information in a User-Friendly Manner 11. Use tables or other highly structured methods to summarize results and/or point to the location in the facility's files where process knowledge can be found. • Ifprocess knowledge is web-based, the number orpercent of dead links. • Number of instances in which maintenance planners or purchasing agents cannot locate specifi- cations or similar data. • Results of periodic surveys to determine if users of process knowledge believe it is accessible. • Number of PHA team recommendations that include an indication ofless than adequate process knowledge where the information actually was available. Define the Scope 6- P R O C E S S K N O W L E D G E M A N A G E M E N T 6-PROCESSKNOWLEDGEMANAGEMENT 6-PROCESSKNOWLEDGEMANAGEMENT 8.3.1MaintainaDependablePractice8.3.2CatalogProcessKnowledgeinaMannerthatFacilitatesRetrieval
  2. 2. KEY PRINCIPLES ESSENTIAL FEATURES WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW Document the lntended Risk Management System 1. Establish and implement formal procedures to manage risk. Use standard documentation forms. 2. Determine when HIRAs should be performed Use standard checklists. 3. Specify the allowable time before the risk assessment of an operating process is revalidated in the risk system. Provide model studies. 4. Determine the types and severity of consequences to be addressed in the program, 5. Determine the process systems and chemicals to be addressed in the program. 6. Determine the mínimum objectives of each required analysis. Determine the Physical Scope of the Risk System 7. Develop a list of units and activities to which the risk system applies. 8. Define the roles and responsibilities for risk activities. 9. Assign a job function as the owner of the risk system to monitor its effectiveness on a routine basis. 10. Provide awareness training on the risk system to all affected employees and contractors. 11. Provide detailed training to all employees and contractors who are assigned specific roles within the risk system. 12. Define the basis for judging risks and risk tolerance. 13. Address the criteria for selecting risk control measures in the HIRA procedure. 14. Maintain current risk tolerance criteria. 15. Keep a running status of all HIRA reviews. 16. Establish risk performance and efficiency metrics. 17. Provide input to interna! audits of risk practices based upon the HIRA performance metrics. Gather and Use Appropriate Data to Identify Hazards and Evaluate Risks 18. Consider all of the types of information necessary to properly evaluate risks within the scope of the risk element. Audit RBPS elements during HIRA preparation. 19. Use appropriate HIRA methods. 20. Specify (1) issues that must be addressed in a review regardless oftechnique used and (2) quality parameters for review results. 21. Specify the qualifications for participating in HIRAs. 22. Provide a description of necessary disciplines needed on a HIRA review team for each type of analysis. 23. Use qualified leaders. Include team members from otherfacilities tofoster cross-learning. 24. Train team leaders and participants in the use of risk tolerance criteria. Conduct virtual meetings. • Verify that HIRA forms are being properly completed. 25. Conduct HIRAs at an appropriate level of rigor commensurate with the level of detail that is available for the process life cycle stage. Select analysis methods based on hazards and potential consequences. 26. Address the appropriate technical risk issues based on the available information at that stage of the process life cycle. Limit discussions to analysis scope and threshold severity 27. Address inherent safety issues in an appropriate fashion considering the stage of the process life cycle. Automate parts of the analysis. 28. Document the hazards, risks, and recommendations from the analysis in a formal report. 29. Document the risk control measures. • Percentage of recommendations for administrative controls, active engineered controls, passive engineered controls, and inherently safer alternatives. Manage analysis depth based on risk ranking. • Ratio of actuallosses to risk tolerance criteria. • Number of recommendations per study or per year. Select Appropriate Risk Control Measures 31. Define preferred risk controls. • Number of recommendations per revalidation. the standards that were applied. Review all high consequence scenarios. Communicate Important Results to Management 32. Inform management of the risks identified and the recommendations for risk reduction. • Number of recommendations unresolved by their due date. Document the Residual Risk 33. Document the residual risk for each operation, unit, and facility. • Percentage of repeat recommendations. Resolve Recommendations and Track Completion of Actions 34. Address HIRA recommendations and document their resolution, including specific actions that address the recommendations. Prioritize actions based on risk and benefit. • Average time corrective actions require for completion. Communicate Results lnternally 35. Communicate risks to potentially affected personnel, including contractors. • Percentage of recommendations rejected by management. • Management exceptions to risk criteria (accepting higher risk). • Investigate any serious incidents in units that were considered low risk. • Residual risks. Maintain Risk Assessment Records 37. Archive the HIRA results, along with key materials and information used by reviewers. • Internal!external risk communications. • Determine whether recommendations are made for every scenario with an unacceptable risk score and for most scenarios that are marginally tolerable. • Determine whether the risk judgments by different teams, areas, and departments are consistent with the risk tolerance guidelines and each other. • Determine whether risk studies are unduly optimistic in claiming credit for engineered controls that are not included in the asset integrity program. • Determine whether risk studies incorrectly list failures of protective systems as causes of the upsets they protect against, for example, failure of the firewater system as the cause of a fire. • Determine whether the latest versions of applicable resources (e.g., checklists, report templates) are being used. • Review the HIRAs scheduled for current processes or projects to determine whether they are appropriate for their stage in the life cycle. • Review the amount of overtime required for team resources to participate in the HIRAs. • Verify that the knowledge element is up to date for scheduled analyses. • Verify that adequate resources, including appropriate subject matter experts, are available for upcoming HIRAs. • Investigate any unexpected delays in starting scheduled HIRAs, and determine whether delays were caused by a lack of information , a lack of leadership or expert resources, or poor planning. • Verify that the actual losses, as tracked through the incidents element, are consistent with the HIRA predictions and corporate risk tolerance criteria. • Investigate whether incidents have occurred that were not anticipated in HIRAs, or if anticipated, whether the controls were inadequate. • Investigate any audit findings of risk program deficiencies and determine whether corrective actions have been implemented. • Determine whether the resolution activities of any recommendations are overdue or have been repeatedly rescheduled. • Verify that recommendations are being resolved in a timely manner, particularly for simple recommendations, such as adding a caution statement to a procedure. • Investigate any long delays between the end of analysis meetings and the issuance of the report. Consolidate small studies. Develop and use HIRA subject matter experts (SMEs). Provide appropriate team composition. Provide administrative support to document HIRAs. Diversify analysis methods. • Considering the pool of qualified leaders and team members, investigate whether only a few individuals are actually participating in the • Verify that the scope of the HIRAs is broad enough to capture the full range of risks. • Determine whether HIRA methods are being selected based on the risk of units and activities. Use an independent risk study leader. Expand the analysis scope to include economic impacts Review previous incidents. • HIRA resource demand and team efficiency. Define and enforce stage gatesfor projects. Train designers in process safety principies. Apply the Risk Tolerance Criteria 30. Address the options that teams have in making decisions in the HIRA procedure. Communicate the Results Externally 36. Inform stakeholders, including emergency management agencies, of the hazards and risks identified, the recommendations for risk reduction, and the residual risks. Ensure that HIRA Participants Have Appropriate Expertise lntegrate HIRA Activities into the Life Cycle of Projects or Processes Clearly Define the Analytical Scope of HIRAs and Ensure Adequate Coverage Involve Competent Personnel Make Consistent Risk Judgments Verify that Risk Practices Remain Effective U N D E R S T A N D H A Z A R D S A N D R I S K Compliance with standards instead of independent analyses. Consolidate and automate corrective action tracking. Prioritize corrective actions based on risk. Maintain current HIRAs. 9.3.3AssessRisks andMakeRisk- basedDecisions 9.3.4FollowThroughonAssessment Results 7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S Perform HIRA Activities to the Appropriate Level of Technical Rigor Commensurate with the Life Cycle Stage and the Available Process Information Prepare a Thorough HIRA Report • Number of qualified HIRA leaders, scribes, and participants. • Number of audit findings. • Percentage of intended revalidations that require the study to be completely redone • Number of HIRAs of each type that are overdue. Select Appropriate HIRA Methods • Technique used • Time required to issue a HIRA report. • Number ofHIRAs of each type scheduled. 7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S 7-HAZARDIDENTIFICATIONANDRISKANALYSIS 7-HAZARDIDENTIFICATIONANDRISKANALYSIS 9.3.1MaintainaDependablePractice9.3.2IdentifyHazardsandEvaluateRisks