Implementation of a RiskBased Process Safety Management System

Implementation of a Risk-Based Process Safety Management System A Resource for AGA Members AGA Process Safety Sub-Committee Process Safety Framework Initiative December, 2016 CCPS, Guidelines for Risk-Based Process Safety Copyright © 2007 AICh. E and used with permission PSM implementation at PG&E and used with permission

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Process Safety Compared to Personal Safety Process safety is the prevention and mitigation of unintentional releases of potentially dangerous materials or energy through the use of robust processes and equipment reliability. Process Safety is about: • Identifying and understanding potential hazards • Evaluating consequences, safeguards, and risks • Adding layers of protection (safeguards) to prevent and/or mitigate incidents • Protecting employees, the public, the environment and assets through these safeguards Process Safety is not about: • Slips, trips and falls, or what is commonly referred to as “personal safety”

Process Safety Framework Objective • The objective of this resource is to help a company develop a comprehensive framework which captures industry best practices in Process Safety Management. • The framework is intended to be simple so that it can easily be understood and applied. • The framework focuses on defining what good Process Safety looks like. • The framework is not a ‘one size fits all’ model but rather a set of requirements that can be customized to meet the needs of individual companies based on their safety culture and safety maturity.

Various Safety Management Systems • OSHA Process Safety Management (PSM) 29 CFR 1910. 119 (published in 1992; 14 elements) • EPA Risk Management Plan (RMP) (per the Clean Air Act; 16 elements) • American Chemistry Council (ACC) Responsible Care (18 elements) • CCPS Risk-Based Process Safety (RBPS) (introduced in 2007; 20 elements) – the most comprehensive and rigorous system • API Recommended Practice 1173 Pipeline Safety Management System (API 1173) (introduced in 2015; 11 elements)

OSHA Process Safety Management Elements OSHA 29 CFR 1910. 119, effective 1992 1. Employee Participation 8. Mechanical Integrity 2. Process Safety Information (PSI) 9. Hot Work Permits 4. Operating Procedures 5. Training 12. Emergency Planning and Response 6. Contractors 13. Compliance Audits 10. Management of Change 3. Process Hazards Analysis (MOC) (PHA) 11. Incident Investigation 7. Pre-Startup Safety Review 14. Trade Secrets (PSSR)

CCPS Risk-Based Process Safety Elements PG&E representation of the 20 elements of Risk Based Process Safety from CCPS “Guidelines for Risk-Based Process Safety “, 2007, AICh. E, NY

API RP 1173 Pipeline Safety Management System Elements 1. Leadership & Management 8. Emergency Preparedness Commitment and Response 2. Stakeholder Engagement 3. Risk Management 4. Operational Controls 5. Management of Change (MOC) 6. Incident Investigation 7. Safety Assurance 9. Competence, Awareness and Training 10. Documentation and Record Keeping 11. Management Review and Continuous Improvement

Apply Process Safety Management to These Assets • Gas Transmission Pipelines • Gas Distribution Services and Distribution Mains • Regulator Stations • Compressor Stations • Gas Terminals • Gas Storage Facilities • LNG/CNG Facilities • Measurement and Control • Customer Connected Equipment

Where to Start? Ultimate Goal - reduce risk to a level that can be tolerated by all concerned • Multiple Frameworks to select from • Honing in on RBPS • Why RBPS? • What is RBPS?

Reasons to Implement an RBPS Management System • Reduce risk associated with incidents involving uncontrolled releases of hazardous material and energy. • Improve efficiency by consolidating a range of discrete safety-related activities to protect employees, the public, the environment and property. • Cost savings by identifying safety enhancements early in the design process. • Reduced downtime and maintenance cost. • Improved operations, customer satisfaction, reputation, employee relations, recruitment and retention.

Attributes of an RBPS Management System • Incorporates state-of-the-art and experience-tested features in a holistic process safety management system. § Includes novel elements such as culture, outreach, conduct of operations, metrics and management review addressing gaps in process safety management widely observed over 15 years. • Holistic application will tend to minimize aggregate risk. § Intensity of work activities for each element will be better tuned to the residual risk they are designed to manage. • Optimizes the use of resources. § Description of each element includes lists of several ideas for improving effectiveness either through efficiency improvements (make do with less) or performance improvements (maximize benefits from existing efforts). • Provides a management system that is better tuned to hazards and risks. § Help decide whether the level of effort applied to work activities for each element is inadequate, excessive, or optimal. § Scope of the work activities at a required level of reliability helps focusing the effort and promote risk management practices.

RBPS: Four Accident Prevention Pillars To be implemented at a risk-appropriate level of rigor. 1. Commit to process safety — the cornerstone of process safety excellence 2. Understand hazards and evaluate risks — the foundation of a risk-based approach 3. Manage risk — the ongoing execution of RBPS tasks 4. Learn from experience — the opportunities for improvement

The RBPS Approach • The RBPS approach recognizes that all hazards and risks are not equal. • It focuses more resources on greater hazards and higher risks. • It puts just enough energy into each activity to meet the anticipated needs for that activity. • Limited company resources can be optimally apportioned to improve both facility safety performance and overall business performance.

First Steps - Implementation of an RBPS Management System • Obtain management commitment and support. • Provide adequate training. • Solicit assistance. • Field-test the system prior to official implementation. • Ensure adequate resource allocation. • Develop tools to streamline future implementation activities. • Define scope and objectives. • Apply proven project management tools and methods. • Define roles and responsibilities. • Manage expectations. • Communicate. • Advance in discrete, manageable and well defined steps. • Keep it simple. • Obtain widespread commitment. • Be flexible and be aware. • Continually reinforce the commitment.

Select RBPS Elements that Provide Greatest Risk Benefit to the Facility Three RBPS criteria should be considered for improving a PSM system: 1. Understanding of the hazards and risks of the facilities and operations. 2. Understanding of the demand for (and resources used in) process safety activities. 3. Understanding of how process safety activities are influenced by the process safety culture within the organization.

Select RBPS Elements that Provide Greatest Risk Benefit to the Facility (continued) CCPS, Guidelines for Risk-Based Process Safety Copyright © 2007 AICh. E and used with permission

Successful Deployment of an RBPS Management System • • Develop and deploy a strategy to implement a process safety management system. Determine current state by performing a self assessment or benchmarking study for elements of interest. If you are unable to include all 20 RBPS elements, consider including the 10 listed on slide 22 in combination with the self assessment tool described in slides 20 and 21. Develop multi-year roadmaps to close gaps and achieve desired level of process safety maturity. Track progress on maturity curves. Develop and deploy a Process Safety Communication Plan. Establish interdependencies and integration of process safety management with other initiatives underway and add process safety rigor. Establish leading and lagging metrics relevant to the organization or to the current maturity level. Over time more metrics can be evaluated. Consider implementing a management review and continuous improvement process. Review implementation effectiveness.

RBPS Systems Implementation Examples Ex 1: Upgrading Operating Procedures Ex 2: Upgrading Conduct of Operations Key Principles and essential Features Ex 3: Upgrading Mo. C Element CCPS, Guidelines for Risk-Based Process Safety Copyright © 2007 AICh. E and used with permission

Sample Process Safety Management Assessment Tool • The following Process Safety Management Maturity Assessment Tool was developed based on “CCPS’ Guidelines for Risk Based Process Safety” • The tool provides best practices used in the chemical industry and shows different levels of maturity across the 20 Process Safety elements. • The tool needs to be customized to better reflect the requirements of the natural gas industry. This tool was developed by Andre Da Costa at PG&E and used with permission Click the Excel Worksheet for the Tool Sample of Tool Output

Process Safety Management Assessment Tool Guide (continued) • Review the 20 Risk Based Process Safety elements and select elements of immediate interest to your organization; delete the tabs of elements that you do not intend to assess. CCPS determined that at least 6 of the elements are critical to success: Process Safety Culture, Compliance with Standards, PHA, Management of Change, Asset Integrity and Reliability and Metrics. • Review the practices for selected elements of interest. Delete any practices that may not apply to your organization. Change the language/terminology of any practices that would not be readily understood by your organization, use terms that your organization can relate to. • Establish a multi-year timeframe to track progress to desired maturity. • Revise scoring system if required (e. g. adding weights to practices). Simple scores used without weights in the attachment. • Get relevant teams to complete the assessment in facilitated sessions. The facilitator must understand the tool and the language of the best practices. • Track assessment results on radar charts. • The benefit of self assessment is not the actual percentage scores, but rather the relative scores (low, intermediate or high level of maturity) and identification of gaps to work on.

Baseline PSM Elements 1. 2. 3. 4. Elements Selected top 10 common Process Safety Management elements as a starting point. Process Safety Culture Compliance with Standards Process Knowledge Management (PSI) Hazard Identification and Risk Analysis (PHA) 5. Safe Work Practices 6. Asset Integrity and Reliability 7. Management of Change (MOC) 8. Operational Readiness (PSSR) 9. Incident Investigation 10. Measurement and Metrics