Amplify Your Process Safety

In this episode, Rob and Molly compare the requirements of combustible dust management systems with the requirements of the PSM standard. They walk through each similar element and then point out the three largest differences between the PSM standard and the NFPA combustible dust standard. Whether your facility is already PSM-covered, or isn't, you'll want to catch this episode if you handle combustible dusts. We also recommend that you check out Episode 16 - Combustible Dusts & DHAs and Episode 51 - Combustible Dust Testing with Guest Michelle Murphy too to learn more. 

In this very special episode, Rob is joined by guest Gilsa Monteiro, a process safety expert with nearly nineteen years of experience in the Oil & Gas industry, to discuss how an organization's decentralized structure may undermine process safety. In this episode, you'll learn the defining features of both a centralized and decentralized organizational structure, the process safety dangers of a decentralized structure and how to avoid those dangers, and other factors to consider when it comes to process safety, like how bonus structures can impact risk and process safety. 

Useful links from today's episode:

Read Gilsa's paper (part 1) How do organizational structures impact operational safety? Part 1 – Understanding the dangers of decentralization 

Request a copy of Gilsa's paper (part 2) How do organizational structures impact operational safety? Part 2 - Designing structures that strengthen safety

Check out Organising for Safety: How structure creates culture by Andrew Hopkins

Connect with Gilsa Monteiro on LinkedIn. 

On August 19, 2022, an explosion at a sugar refinery in Andhra Pradesh's Kakinada district took the lives of two workers and injured nine others. In this episode, Rob and Molly bring you the latest information about the incident, and offer a reminder about the role good housekeeping plays in keeping the people who work in facilities that handle combustible dusts safe. For additional information, check out the resources we've gathered below.

News Releases:

2 dead, 6 hurt after explosion rocks sugar refinery in Andhra Pradesh’s Kakinada

Andhra Pradesh: Two dead, 9 injured in sugar factory explosion in Kakinada

In this episode we also referred to the CSB's video for the Imperial Sugar Company Dust Explosion and Fire, which you can view here. 

On August 2, 2022, the US Chemical Safety Board (CSB) released its final report into the 2017 pressure vessel explosion at Loy-Lange Box Company in St. Louis, MO. In today's episode, Molly and Jo take a deep dive into that report and break it down for you. So what can you expect in this breakdown? We'll cover some background information about the facility and its process, give you details about the day of the incident, and then break down the factors that ultimately led to the vessel's failure on April 3, 2017. Finally, we'll discuss how certain elements of a robust process safety program could have helped to prevent this tragedy, and provide you with three big takeaways that we think you'll find valuable, regardless of the industry or materials you work with. 

Find the resources we mention in this week's episode at the links below:

We're back with another Top 10 Talk, this time to discuss how to Amplify Your P&IDs. In this episode, Rob and Molly cover their top ten tips for how to improve your P&IDs, and touch on consistent standards, drawing details, managing revisions, reference flags, tag numbers, line numbering, instrumentation, equipment information, relief devices, referencing P&IDs across your PSM program, and more. Then they break the rules and throw in two more bonus tips at the end (so I guess this is a Top 12 Talk). If you're looking to improve your process safety information (PSI) documentation, or improve the quality of your PHAs, then this is the episode for you. 

We want to know what you think; did we miss any P&ID best practices, or do you have any questions about what we covered? Leave us a voice message at the link below or send a note to [email protected]. 

If you haven't already, check out our previous Top 10 Talks here (PHAs) and here (Compliance Audits).  

In this episode, Molly and John discuss the subtleties of Management of Change (MOC). If you're familiar with MOC, then you already know that in order to comply with the PSM standard, you need to "establish and implement written procedures to manage changes (except for 'replacements in kind') to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process". But what if the line between a real change and a replacement in kind isn't totally clear? For example, what if you replace a pressure relief device with another of the same size, but the replacement is from a different manufacturer than the original device? Tune in to this episode to learn more about this specific situation and other similar cases, where you might find yourself on the fence about whether an MOC is truly required. 

Have a specific scenario that we didn't discuss? Send an email to [email protected] and our consultants will respond with their expert advice. 

For those not familiar with MOCs, we suggest checking out these previous episodes of our show:

Episode 5 - MOC & PSSR

PSM: Back to Basics, Part 4 - Management of Change (MOC)

Episode 48 - Management of Organizational Change (MOOC)

In a previous episode (#52), Mat Todaro, an attorney who specializes in enforcement defense, talked with us about EPA's General Duty Clause (GDC) at a high level. In this companion episode, Molly and Rob dive into the specific requirements of EPA's GDC, and point out its similarities and differences to OSHA's Process Safety Management (PSM) regulation and EPA's Risk Management Plan (RMP) regulation. 

Be sure to check out the resources we've gathered below regarding EPA's GDC, or reach out to us with any questions you might have related to your facility and EPA's GDC by sending us an email at [email protected]. 

Episode 52 - EPA's General Duty Clause with Guest Mathew Todaro

The General Duty Clause Fact Sheet (pdf) (April 2020)

Guidance for Implementation of the General Duty Clause: Clean Air Act Section 112(r)(1), May 2000 (pdf)

This week we're excited to bring you a new type of episode, a movie breakdown. In this episode, John and Molly give their take on what's happening in a clip featuring a nuclear power plant control room in the 1979 thriller/drama film, The China Syndrome. We invite you to watch the clip at the provided link below before you tune into this episode. In this episode, we cover our concerns related to the events transpiring in the control room, and offer useful reminders about relief mitigation, process deviations, operating procedures, PHA considerations, evacuation plans, maintenance outages, and more. 

The China Syndrome clip: https://youtu.be/nemYBeT4aQY 

Let us know what you thought about this episode, or send us an idea for a future movie breakdown episode, where we explore a clip through the lens of process safety by sending an email to [email protected].

In Episode 45, we covered the basics of piping requirements for pressure relief devices. In this episode, Rob is joined by Eric Hirsch, to take a deeper dive into pressure relief device concepts. Eric, a principal process engineer at Nexus Engineering Group, works in process design with a focus on pressure relief devices. In this episode, Eric and Rob cover basic requirements for pressure relief devices and the calculations that go with them. You'll learn about back pressures, considerations for common subheaders and global relief scenarios, impacts to the relief capacity of a system, identifying fire zones/circles, design issues with flare knock out pots, Eric's thoughts on the use of rupture disks for overpressure protection, SIS instrumentation, designing for 2-phase relief, and more. Then Eric gives his expert advice regarding a frequently asked question: Do I have to have overpressure protection on every pressure vessel and/or piping system and do I need calculations for all of those? He'll touch on what could get you in trouble with OSHA during an enforcement audit when it comes to your pressure relief scenarios, how often you should revalidate them, and more. Don't miss this content-packed episode from an expert on pressure relief devices. 

To contact Eric Hirsch directly, send an email to [email protected] or give him a call at 216-456-8564.

Operators, maintenance technicians, and I&E technicians - those we deem "boots on the ground" - are a vital and often untapped resource when it comes to a successful Process Safety Management (PSM) program. In this episode, John and Molly discuss how to set yourself up for successful buy-in and a positive PSM culture with boots on the ground personnel and talk about how experienced operators can be utilized to build, review, and optimize Standard Operating Procedures (SOPs). John and Molly also touch on how operators can assist with field labeling and P&ID updates, delivering relevant and engaging refresher training, and how experienced operators can be involved in the Management of Change (MOC) process, Process Hazard Analyses (PHAs), and in Incident Investigations. Whether you manage "boots on the ground" personnel, or you are one yourself, you'll want to catch this episode to learn more about how this important resource can contribute to overall PSM program success. 

To learn more, be sure to check out a previous episode we have on this topic, Episode 20 - Why "Boots on the Ground" are Vital to your Process Safety Program.