Wednesday, May 30, 2012

OODA or Business Intelligence in Process Safety

OODA is an agronym, which I learned today at the IDC Business Intelligence Conference (sorry about the Danish) at the Scandic Sydhavnen Hotel in Copenhagen. Attending this one day event was a real learning experience. More about OODA later.
Business Intelligence (BI) is the art of extracting valuable information from normally large amounts of business data and taking action to improve the business. The basis is usually a datawarehouse on top of which is placed user friendly analysis and reporting tools. Some companies, like the Danish retail chain Imerco, perform the analysis in almost real time. Others, like financial institution Nykredit, update the electronic drill down reports overnight. But why should this be of any interest to process safety?
Process plants are properly some of the worlds largest producers of data, most of which is never turned into information. Data is collected for the operator to monitor the plant, but only in case of a process safety event are the data analyzed. I think the process industry miss out on a major opportunity for continuous improvement of their plants.
How many process plants ask questions such as: Was our process running better or worse today than yesterday? During which shifts are the process most stable? or most optimal? What influence has the engineers once daily adjustment of the secondary air flow to a cracking furnace? These are just some of the questions I would like information about if I was a plant manager or a shift superintendent or a board operator. Is there already usage of BI in the running of process plants? I would very much like to read about them.
OODA stands for Observe, Orient, Decide, Act, and it is the circle of steps which make continuous improvement possible not just at the management level but also in the running of the plant by the operator, or in calibrations of the instruments technicians. The ideas of OODA was first used in the US air force in the 70's. It is in my opinion about time we use it to improve the safety of our plant.
By just monitoring process variables it is very difficult to see if you are getting closer to process safety event or not. However, by analyzing the data we can uncover relations not visible to the naked eye, and stop safety issues before they become safety problems or safety events. What do you think?
So let us start using BI tools on the data collected in our process plants and give our employees from the manager to the operator daily reports, which allow drill down learning. Some will likely argue, that our data are not good enough. I would tend to disagree. There are outliers in all datasets whether from a chemical plant or a financial institution. You need to deal with that in order to perform a meaningful analysis.

Friday, May 25, 2012

Exposure at biochemical plants

Yesterday I attended a half day seminar at the Danish National Research Center for the Working Environment (NRCWE) on microbial air pollution. My reason for attending was, that I am currently involved in risk assessment of a facility for production of protein from waste methane streams. Naturally such a place has the potential to expose workers to  biological agents of different kinds both during normal production, i.e. dust from the drying operation, or abnormal situations, during which the microorganisms decide to produce undesired byproducts. 
I was happy to discover during the first presentation by Susanne Høyer from the Danish Working Environment Authority that the regulation of biological agents are not that different from the regulation of chemical agents. It is a question of workplace assessment and evaluation of the risk of exposure. And biological agents are assigned to classes based on the consequences of exposure. That sounded quite familiar.
However, the third presentation of the afternoon was an eyeopener. Anne Mette Madsen talked about organic dust toxicity (ODTS) among workers involved in the cleaning of grass seeds (Denmark is a major producer of grass seeds used on many football stadiums around the world, e.g. those used during WC in South Africa - but not on the home stadium of FC NorthZealand - Danish Soccer Champions 2012). Pictures of both problem samples and normal samples before and after cleaning was shown. The problem samples looked a bit more dirty before cleaning, but otherwise there was no difference. The biological analysis showed no difference among problem sample and normal samples. So unfortunately a clear cause for the ODTS could not be identified.
The story about the grass seed workers show the complexity of exposure to biological agents. As a consumer you would properly start buying seeds from another supplier to avoid an exposure problem, but as an employee you are in a more difficult position. Changing job is not that easy these days. And employers of operators for biochemical plants properly should conduct regular health checks of their operators from before they start to some time after they stop working.

Friday, May 18, 2012

Will the state be any safer?

Yesterday the CSB commended the State of Massachusetts for new tough hazardous storage and processing rules. The background for the changed rules was a recommendation in a CSB report on an explosion at an ink and paint facility in Danvers. There were no injuries at the site, but a number of local residents had to be treated at a hospital. The CSB writes in their commendation:
The CSB investigation found that CAI had increased its quantities of flammable liquids over the years. The additional quantities went undetected by the local authorities who had no inspected the facility for over four years prior to the the time of the indicident.
 Clearly the owners of the site did not have an understanding of the dangers of storing large quantities of flammable liquids at their site, and the procedures and systems, that need to be in place to ensure, that this takes place safely. Nonetheless the CSB report on the explosion contains 11 recommendations directed at the General Court of the State of Massachusetts (2), Office of Public Safety, Department of Fire Services of the State of Massachusetts (4), the Town of Danvers (1), NFPA (2), International Code Council (1) - number of recommendations in brackets, and finally the company: 1 recommendation. The latter essentially state, that CAI  should comply with relevant federal laws. As of today 20% of the recommendations have been closed.
So what changes have the State of Massachusetts made to their local laws? The CSB describe the changes as follows:
At the time of the accident mandatory notification by companies to local authorities that a facility had increased in quantities of flammable materials from the initial amount listed in the permit was not well enforced. Therefore, the Board recommended that Massachusetts require companies storing and handling flammable materials to amend their licence and re-register with state or local authorities when increasing their quantities of flammable materials; they must also verify compliance with local, state fire codes and hazardous chemical regulations.
Essentially this is prescriptive medicine - and hence more enforcement. Where will this get us if an explosion caused by lack of understanding of proper process safety standards can unleash such a change in state laws? And 10 recommendations to different organisations outside the company?
I would suggest, that it is time to switch from this very prescriptive approach to regulation of hazardous facilities to a performance oriented approach requiring the companies to demonstrate, that they operate safely. This is also recommended by DNV after the Deepwater Horizon disaster.


Tuesday, May 15, 2012

Why safety culture is important!

I am continuously looking for good stories as to why safety culture and top management backing is so important for having a good process safety record. Here is one from a discussion on LinkedIn:

Is using the Audit stick to beat the organization into submission the right tool? Let's see.... You can get a horse to walk forward by twisting its tail. You may get kicked a few times and pooped on, but the horse will ususally walk forward. When you stop twisting the tail, it will stop walking forward. You can also get a horse to walk forward by leading it with the reins. This usually does not carry the same negative effects of being on the back end of a horse. If you lead the horse by using the reins and reward it for following, the horse will eventually follow without you holding the reins. Now apply the horse story to using the Auditing tail twisting and real Management support of leading by being in front. The value of Auditing as a way of improving performance is short term, unsupported and will eventually tail! Leading and rewarding will yield continued success. In practice, both techniques are being used. Guess which ones succeed long term and have more employees "buy-in".
I totally agree with this story, but as usual with stories you need to consider the cultural envinronment in which you use them. If your audience has limited knowledge of horses, then you may need to modify to story. I can highly recommend joining LinkedIn groups and enjoy stories such as this one, and other sharing of information. However, based on yesterdays post: You need to be selective about which groups you join, and be ready to leave if the benefits of your reading decline.

Sunday, May 13, 2012

Are LinkedIn discussion groups keeping on track?


I am active in quite a number of groups on LinkedIn related to safety. I very much enjoy the discussions which I often find provide me with perspectives, that I would not have thought about myself. Therefore I get concerned when a group owner or moderator need to remind us about that rules of copyright also apply to those discussions. Since I enjoy the challenge of searching for information on the WWW, I properly have on one or two occassions provided a link, which I should not have provided due to copyright issues. However, I really get sad when I see someone poste things to a discussion group without seeking the views of others or information. The following is my comments on such a case.
The following is a series of postings on a LinkedIn group. This particular discussion was started under a heading relating to HAZOP, and in a later posting the author stated, that the purpose was to share experience about HAZOP. So let us analyse what experience have been shared up to the point, where I decuded to unfollow the discussion.
The initial posting was:
HAZOP study is part and parcel of PHA intended to examine and evaluate overall process design through continuous brainstorming sessions and to find any operational deviations and process interactions which may lead to an hazardous environment which leads to hazardous environments and operability problems including
1. Leading to safety, occupational health and environmental ailing to personnel
2.damage to asset/equipment/environmenta.
3.environmental emmissions
4.operability and manitainability problems etc.
The first sentence gives an incorrect view of what HAZOP studies are. The purpose of a HAZOP study is to identify hazards and operability events in a proposed design caused by deviations from normal operation and evaluate the possible consequences of such events. Of the four bullet points listed in the first posting only the last one have some relevance to a HAZOP study. What experience is shared here?
The second posting was:
Plant non-availability / limitation and lack of product quality / production loss;
 Environmental emissions;
 Demolition / Decommissioning / Abandonment reviews;
 Construction and commissioning hazards.
I wonder what the relationship is between the first line and the three bullet points? And again: What experience is shared here?
The third posting was:

Even though HAZOP essentially performed when the design is essentially complete and P&ID's were developed and contains all essential information. Even though HAZOP can be applied on different stages of a project as below. 
a. conceptual design phase and capital porject phase where the design content and major system components are decided still the design and documentation to conduct HAZOP not ready. Eventhough it is necessary to identify all the major hazards at this stage itself to facilitate their consideration in the design process to facilitate future HAZOP studies. 
b.FEED PHASE:
It is very critical phase where a detailed design is developed, methods of operations and respective documentation is intact.the ideal period for HAZOP is just before the design is frozen as it elaborates and helps to prepare a meaningful questioning crieteria upon which meaningful answers can be obtained. 
c. Detail Design Engineering Phase(DEED): Here HAZOP is conducted in between finalyzed design and before issuing engineering drawings for P&ID's, C&E etc. with approval for construction. 
    d.Installation and commissioning Phase: 
    Wherever the operation sequences are critical and commissioning and operation can be hazardous or there is a substantial change in the design at the fog end of the design stage it is advisable to have HAZOP review before system start up. 
e.Operations PHASE: HAZOP Study CAN be considered during Operational Phase before implementing any changes to the existing system (for example, through MOC Procedure) that could affect the safety / operability or impact the environment. 
NOTE: HAZOP Study conducted after finalization of FEED will improve the process safety to a great extent and will help in reducing high risk recommendations at a later stage.
The first paragraph in this posting makes it sound as if HAZOP is another of those things, that need to be ticked off during a process design. Much like environmental impact evaluation seem to be in some countries.
At least in the major projects, which I have been involved with, design drawings were released in a more or less continuous stream to sub-contractors. Hence the HAZOP studies, and there were indeed several was scheduled with moving from one project phase to the next, e.g. from design to start of construction or from construction to commissioning/startup. Usually three different HAZOP studies were performed.
At any stage in the design process there is sufficient information to conduct the form of HAZOP outlined in the early papers published by the people at ICI, such as H.G. Lawley's ”Operability Studies And Hazard Analysis” (Chem. Eng. Progr. 70(4), pp. 45-56. 1974) or C.D. Swann and M.L. Prestons “Twenty-five years of HAZOPs” (J. Loss Prev. Process Ind. 8(6), pp. 349-353, 1995).
The fourth posting was:
HAZOP Study PROCESS
The process of HAZOP analysis is based on a “guide word examination”, which is a deliberate search for deviations from the design intent of study nodes / process section.
 The review shall follow a structured step by step format in detail.
a) The complete process needs to be studied is divided into various study nodes.
b) For each node, various parameters, guidewords and deviations are considered.
c) For each deviation, causes are identified (if any cause is not credible, it is ignored).
d) For each credible cause, consequences are identified assuming no safeguards are present.
e) For each consequence, existing protections are identified.
f) Assess severity & likelihood and identify Risk Rank for the consequence.
g) After considering existing protection, if the risk level is considered unacceptable, recommendations for mitigation of the risks are made
This posting makes me wonder if the poster have ever participated in a HAZOP study, or acted as a HAZOP study leader. It reads as if it was based on a single lecture on HAZOP included in many academic process design courses without the course lecture having had any practical experience with HAZOP either as a participant or as a leader. How is the process divided into nodes? How are guidewords and parameters selected? Also most writers agree that the HAZOP study process has 3 phases: 1) A pre-meeting or preparation phase, 2) A HAZOP team meeting phase, and 3) A post-meeting or follow up phase.
Excellent examples of relevant combinations of guidewords and parameters have been published by e.g. American Home Products. And other may be found by googling "hazop guide word tables". However, before these can be used one need to adapt them to the type of process under consideration. For biochemical plants one have to add for example contamination.
The reason for this comment is, that I am sad to see the quality of discussions in the LinkedIn groups being reduced to just sharing of poor textbook content.