Thursday, June 02, 2016

Was it the intention, that OSHA PSM should be a continuous improvement activity?


I first time I heard about OSHA's PSM standard 29 CFR 1910.119 was in discussions with van Rijn from Shell during a trip to Osaka and Nagoya to participate in the 1st Production Control in the Process Industry conference arranged by van Rijn and O'shima. I vividly remember discussion about making the complete plant operating procedures available electronically through the control room computers to the board operator. 

I the time I had just left major Canadian petrochemical producer to take up an academic position at the Technical University of Denmark, and I recall that complete operating documentation for our polyehylene plant was more than 5 meters of ringbinders. I could not envision al that on a computer in the control room. But IT have improved, so today I have no problem with envisioning the complete documentation for a chemical plant as one hyperlinked online document. Later I was again confronted with PSM as I attended a local conference on process safety in Houston, Texas, where I was introduced to SAChE by professor Ron Darby from Texas A&M. During a luncheon speech a regional OSHA director stated, that at the time in mid 90's OSHA envisioned circles of visits to process industry facilities to assess their PSM performance. During the first circle all companies were just to be rated, and fines only giving for obvious negligence. However, he added, that during the next circles OSHA would set the bar at the performance of the best companies during the previous circle. To me that was a clear signal, that OSHA was looking for continuous improvement in PSM performance, and not just compliance.
Hence it was nice to discover Michael Marshall's article "Enhance PSM design with metrics-driven best practices" in the February issue of Hydrocarbon Processing. In this article Michael Marshall clearly states, that is OSHA's aim, that PSM should be a continuous improvement circle with Plan-Do-Check-Act as in other management activities, and he mentions recent developments in Flare and Overpressure Management Systems (FOMS) as an example to follow. Mr. Marshall goes on to argue, that the continuous improvement of PSM should be sustained through KPI's relevant for the facility and task, and states that API 754 Measuring Process Safety may not have all the answers. This are shortcoming which also the Chemical Safety Board have pointed to.
Michael Marshall goes on to state, that the development of the relevant KPIs is a four phase process involving:

  • Phase 1: Where are we now?
    • Identify and engage process owners and stakeholders
    • Compile available documents and information
    • Flowchart current processes, tasks and procedures
    • Identify current tools and technology
    • Understand strengths, weaknesses, opportunities, opportunities and threats (SWOT) in existing processes
  • Phase 2: Where do we want to go?
    • Engage process owners and stakeholders for vision, objectives and value drivers
    • Baseline processes and perform gap analysis
    • Evaluate gapsand tradeoffs (costs)
    • Redesign processes and functionalities
    • Specifiy tool and technology needs
  • Phase 3: How are we going to get there?
    • Identify needs and objectives
    • Develop strategy purpose
    • Establish team leadership
    • Perform root cause analysis
    • Design metrics, KPIs, reports, automation tools
    • Initiate training programs
    • implement transition plan, pilot and then role out
  • Phase 4: How do we improve, grow and keep going?
    • Implement and validate redesigned process
    • Initiate ongoing metrics and management systems
    • Monitor, evaluate and report on new processes
    • Review targets and performance
    • Audit and adjust for continuity, sustainability and growth
(I have in the above only included the top two levels of the more than 1½ page long list of bullet points in Mr. Marshall's article). In my view the bullet points could be more specific to the task at hand, i.e. development of KPIs to be used in process safety management (PSM). Especially since Mr. Marshall already the start of this section state, that he believe the KPIs should be based on the data in enterprise asset management systems in order to allow drill drown deeply enough to find root causes.

So unfortunately, this very well motivated article on continuous improvement of PSM leave me without congrete advise except a list of bullet points to consider in developing my own KPIs. Can't we do better than that? I certainly believe so!