“But we’re different, you know” (Part 2)
Yesterday we published the first post in the series “But we’re different, you know”. The post started with the following words,
In any industry there is a tendency for specialists to believe that only they can address the problems of their particular operation. They do not readily accept that people from other industries can make a contribution.
With regard to process safety management (PSM) this attitude is generally incorrect. Certainly, there are differences between industries, but those differences are relatively minor compared to the concepts and programs that they share. The elements of Process Safety can be used in all process industries.
Hardly had I pushed the ‘publish’ button on the above post when I received notification from the Chemical Safety Board (CSB) saying that they had just released their report Equipment Fracture and Fatal Hydrogen Chloride Release at Wacker Polysilicon North America. The incident, which occurred in November 2020, resulted in one fatality and two serious injuries. The full report is available here.
The following paragraph is taken from the Executive Summary. It is worth reading in full.
At the time of the incident, seven workers from two contract firms were present on the fifth-floor platform, which was equipped with a single staircase for access and egress. Three of the workers, tasked with bolt torquing, wore full-body chemical-resistant suits. The four other workers, who were from the other firm, were tasked with insulating equipment and wore only standard flame-resistant clothing.
<my emphasis>
As time permits, we will work through the findings and recommendations of the report. But I was immediately struck by the phrase,
seven workers from two contract firms were present
This observation is worth stressing.
Workers from two different contractor companies were working on different tasks in the same place at the same time.
The CSB identified four areas of concern:
Written Procedures,
Control of Hazardous Energy,
Simultaneous Operations (SIMOPSs), and
Means of Egress.
All four of these recommendations justify thorough study and analysis. For now, let’s look at the third of the recommendations — the one to do with SIMOPs.
SIMOPs Recommendation
The agency issued the following recommendation to OSHA — presumably for inclusion in future upgrades to the process safety standard, 29 CFR 1910.119.
Promulgate a standard or modify existing standards to require employers to ensure the coordination of simultaneous operations (SIMOPs) involving multiple work groups, including contractors. Ensure that the requirements of this standard or standards apply to both general industry and construction activities and are not limited to activities occurring within confined spaces. Include in the standard requirements for Employers to ensure that the following activities occur:
a. Identification of potential SIMOPs;
b. Identification of potential hazardous interactions;
c. Evaluation and implementation of necessary safeguards to allow for safe SIMOPs;
d. Coordination, including shared communication methods, between the SIMOPs;
e. Inclusion of emergency response personnel or services in the planning and coordination of the SIMOPs.
29 CFR 1910.119
The original process safety standard from OSHA — 29 CFR 1910.119 — contains the following fourteen elements. We see that SIMOPs are not broken out as a separate topic.
Employee Participation
Process Safety Information
Process Hazards Analysis
Operating Procedures
Training
Contractors
Prestartup Safety Review
Mechanical Integrity
Hot Work Permit
Management of Change
Incident Investigation
Emergency Planning and Response
Compliance Audits
Trade Secrets
Nor are SIMOPS included in the proposed update to the OSHA standard (see The OSHA Process Safety Standard: The 30-Year Update).
SEMS
It might be thought that the more recent Safety and Environmental Management System (SEMS) rule from the Bureau of Safety and Environmental Enforcement (BSEE) would contain a section on SIMOPs. After all, the topic is frequently cited in literature to do with offshore work, largely because that industry uses a higher proportion of contractors than the onshore process industries. Also, offshore platforms and rigs are typically very congested, so it is difficult to separate maintenance tasks from one another. Moreover, the Piper Alpha catastrophe that occurred in the North Sea in the year 1988 had failed SIMOPs management as one of its root causes.
SEMS has seventeen elements, as shown.
General
Safety and Environmental Information
Hazards Analysis
Management of Change
Operating Procedures
Safe Work Practices / JSAs
Training
Quality and Mechanical Integrity of Equipment
Pre-Startup Review
Emergency Response and Control
Investigation of Incidents
Auditing
Records and Documentation
Stop Work Authority
Ultimate Work Authority
Employee Participation
Reporting Unsafe Conditions
In spite of their importance with regard to offshore work, SIMOPs are not broken out as a separate topic.
CCPS
The Center for Chemical Process Safety (CCPS) — sorry for all the acronyms — provides one of the more recent formulations of the elements of process safety management. But nor does it treat SIMOPs as a separate topic.
The Updated Standard
In The OSHA Process Safety Standard: The 30-Year Update we note that the proposed changes to OSHA’s PSM standard are still as the discussion stage. The agency has not yet issued a formal, proposed update to 29 CFR 1910.119. Therefore, they presumably have time to respond to the CSB recommendation to do with incorporating SIMOPs into the regulation.
