The Process Safety Roundabout
We have been steadily working our way through OSHA’s proposed updates to its Process Safety Management standard. The agency has proposed a total of 24 updates. (The complete list of posts is provided at Update to OSHA’s Process Safety Management Regulation: An Index.)
While writing these summaries and analyses we are reminded once more as to the inherent circularity of so many aspects of process safety management. Here are a few examples.
Process Hazards Analysis
A PHA team may be discussing the risk to do with “high temperature in a process vessel”. The conversation is on the following lines,
Could high temperature cause an accident?
What is high temperature?
It is the temperature that could cause an accident.
RAGAGEP
If this difficulty were confined to PHAs there would not be too much to worry about. But the issue crops up all the time. For example, two of the proposed updates are to do with RAGAGEP: Recognized and Generally Accepted Good Engineering Practice. Therefore, this topic is considered by OSHA to be important. But, once more, we face circular reasoning and that self-referential nature of the topic.
What is “good engineering practice”?
It is that practice that is defined by engineering experts.
What makes them recognized experts?
They know how to recognize good engineering practice.
Staying with this topic, we have the following line of thinking.
What is meant by “reasonable” practice?
It is that practice that reasonable engineering experts agree upon.
Management of Change
Another example would be to do with Management of Change (MOC).
Does this proposed change require that a formal Management of Change analysis be carried out?
We will need to conduct an MOC to find out.
Critical Equipment
Yet another example is to do with the proposed update, Definition of Critical Equipment.
Is this piece of equipment safety critical?
What is meant by safety critical?
The equipment item is considered to be critical to safety.
Risk Management
It is important to recognize that the above examples are not some type of parlor game. Nor is the circular reasoning that we see a weakness to do with process safety systems, or the manner in which OSHA has written its regulation. The circularity comes from the inherently subjective nature of any risk-based strategy. It cannot be avoided.
A fundamental feature of process safety management is that it is risk-based and non-prescriptive. The agency is not saying, “Do A, but not B”. Instead, it says, “Determine the risk associated with a hazard. If that risk is unacceptable then take action”.
But, what defines the concept of “unacceptable”? Once more, we face a conundrum.
If the risk to do with a hazard is unacceptable, take action.
How do we know if the risk is unacceptable?
Conduct a risk analysis.
This way of thinking is not a bug, it is a feature.
