Feature

Process Safety : A Proactive Approach

Posted on 27 January, 2010 | Tags: Inherent Safety, Safety in Chmical Processes, Safety solutions, test

In India, many safety regulations are chalked out and help to control the incidents. But most of the times these are managed in India. Government needs to be proactive aware and aim for continual improvement as against following only legal requirements

Safety can be defined as the state of being protected against any physical, occupational, emotional, social or any other outcome of accidents, harm, failure or any other non-desirable condition. Safety rules, guidelines and best practices assist to achieve safer working conditions. In India, many safety regulations are chalked out and help to control the incidents. However, these regulations are very generic and highly diluted as compared to specific and precise regulations found in the USA and Europe. In a way, safety regulations can be managed in India. To achieve the international standards the Government and organisations would need to be proactive, aware and aim for continual improvement as against following only legal requirements.

Current Safety Regulations
In India, chemical industries follow the below mentioned safety standards

• Factories Act, 1948
• Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules, 1989
• Disaster Management Act, 2005
• Code of Practice on Occupational Safety and Health Audit - IS - 14489:1998
• Environment (Protection) Act, 2005
• The Petroleum Act, 1934
• Others include - Explosives Rules, 1983; SMPV (U) Rules 1981; Gas Cylinder Rules, 1981; Petroleum Rules 1976; Calcium Carbide Rules, 1987; Cinematograph Film Rules, 1948; Chemical Accidents (EPPR) Rules 1996; OISD Standards; Transportation of Hazardous Wastes 2004; Chemical Disaster, NDMA, 2007.

These regulations are adopted at different levels and are for different chemical industries. Some are rules and laws while others are best practices and guidelines.
Safety statutory rules and guidelines are protective tools against industrial accidents. The risks associated with the chemical industry commensurate with their rapid growth and development. Compliance to these guidelines and rules not only results in the benefit of reduction in accident rate, but also gains better production, quality, brand name, etc. The commitment to safety rules is equivalent to providing quality products to the customers.
In India, safety standards are mostly based on personal safety as compared to the developed nations where process safety and personal safety have equal importance. It's important to note that incidents due to process safety failures are catastrophic in nature. All the major recorded incidents in the past be it the Bhopal Disaster or the BP Texas incident were due to process safety failures.
United States follows standards like NFPA Standards, which consists of over 4500 codes and standards dealing with various industries, resources and stages of operation and design. The other widely used standard is OSHA PSM, which contains 14 process safety elements to strategise inherent process and personal safety of the industry.
DSEAR, ATEX and CAD are a few examples of the standards in Europe. These consist of specific guidelines on Hazardous Area Classification, Dust Explosion Hazards Assessment, Electrostatic Hazard Assessment, Chemical Reaction Hazard Assessment, and Testing for Chemicals and Powders, etc. which are not adequately addressed by the Indian statutes. The chemical industries across USA and Europe follow these laws and guidelines proactively and as a result there are fewer undesirable events

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Disregard of Safety Regulations
The enforcement of safety regulations are also an area of concern. The unfortunate example of this is Bhopal disaster. The Black Day being observed on fourth December, when world's worst disaster had struck Bhopal with Methyl Isocyanate (MIC). It has contributed to the necessity of making the safety rules exceedingly stringent. Although the magnitude of accidents had been shrunken compared to Bhopal tragedy, the number of accidents happening across the industrial belts has not come to an end. Not to say that industries do not follow the safety norms, it is rather clear that least importance is given for its compliance. This statement could be well proved with the table below (Table 1).
Table shows that areas like Maharashtra, Gujarat and Uttarakhand are the forerunners as their industrial areas are highly populated with manufacturing industries and industries having MAH status.

The major contributors to ignorance of safety rules can be pointed out as lack of budget for safety, lack of awareness among industries and employees, weak infrastructure of states to provide resources for safety adherence, lack of monitoring of safety compliance, etc.

Incidents and Costs Involved
"If You Think Safety Is Costly, Try An Accident"
Violation of safety rules and responding reactively in regards to safety can lead to considerable damage. Depending upon the intensity of the accident, damage may be in the form of an injury to begin with and can amplify to shutdown of the factory. The BP Texas refineries Isomerisation unit was shut down for 2 years after the incident in 2005. The loss of production can be safety assumed to be astronomical. Amidst these extreme situations, it can also cause loss of life of employees and public, release of toxic material, thermal runaway, fire or explosion, self ignition of process materials, damage to the surrounding environment, groundwater contamination, bioaccumulation, loss of production, increased scrutiny from regulatory authorities, fines and compensation, bad publicity (public perception), etc.

In today's highly competitive and well connected market, bad publicity, with such incidents generate, can be the most detrimental of all the effects listed. A one-off incidence can bring the organisation to the verge of bankruptcy owing to the clients moving on to the competitors due to inability of the organisation to produce on one hand and reluctance to associate owing to the bad public perception on the other. Thus a very careful and proactive assessment procedure is crucial in avoiding incidents.

Inherently Safe Process
An inherently safe process helps to achieve a low level of danger even though errors might occur. Comparatively, safe systems use protective methods to control a high degree of hazard. As zero hazards cannot be realized, common practice is to incorporate inherently safer design. To define the term an inherently safer design is one that avoids hazards instead of controlling them, particularly by reducing the amount of hazardous material and the number of hazardous operations in the plant. (Heikkilä, Anna-Mari. Inherent safety in process plant design. An index-based approach. Espoo 1999, Technical Research Centre of Finland, VTT Publications 384. ISBN 951-38-5371-3).

It has been proven that, considering the lifetime costs of a process and its operation, an inherently safer approach is a cost-optimal. Inherent safety is achieved best when it is in-built in the project from the conceptual phase although it can be incorporated at later stages as well. The main methods of achieving inherent safety during the lifecycle activities are
 

• The Route Selection 
  Choosing the effective chemical route to attain the desired end product considering safety of the same. This process should be safe, cost effective and achievable at the large scale. Options like substituting one material with another of less hazardous nature, etc. can be taken into consideration.
• Process Development and Optimisation
  This deals with maximising yield, maximising quality, maximising output and minimising the hazards. Incorporating safety systems with the route is as important as these safety systems need to be vigorous to handle the intensity of the production.
• Pilot Scale Production
  Verifying if the safety measures taken in the earlier stages are as robust as the chemical process itself. These safety measures need to be operating effectively and efficiently. Few alterations such as reducing the strength of an effect, for instance having a cold liquid instead of a gas at high pressure, or using material in a dilute rather than concentrated form and/or problems can be designed out rather than adding additional equipment or features to deal with them. Using fitting options and complex procedures only if they are really necessary.
• Large Scale Production 
  Assuming safety measures have been integrated carefully in the previous stages, scaling up the production process should be smooth.  Some measures, which can be utilized at this stage, are Intensification (eg reducing the inventory at one given point of time), Attenuation (eg changing to less hazardous conditions) and Control (reliable control and relief systems).

Assessment Strategy for Inherent Safer Process
It is true that reduction in productivity is not an option and hence only a few of the many alternatives can be incorporated. The development of inherently safer chemical processes and safer products are not easy, demanding innovative thinking and fundamental changes to traditional modes of operation. Hence, there are newer technologies, for eg plug flow reactors, being developed for effective and safer production and safety solutions need to be carried out and documented. Some examples of safety solutions used worldwide are Process Hazard Analysis (Hazop, FMEA, FTA, etc). Testing of chemicals to know their characteristics, process safety management, hazardous area classification and many others. Depending upon what is the need of the process the specific study and the technology should be featured and documented. Proactive behaviour in regards to safety helps a long way.

The Path for Continual Improvement
"Companies should strive for excellence in process safety performance, not legal compliance"

The Baker Panel Report
There was an explosion that took place at the BP Texas refinery in the isomerisation unit on March 23, 2005 killing 15 workers and injuring more than 170 others. The Baker Panel investigated the explosion and came to the conclusion that BP management had focussed on personal safety while ignoring process safety. BP had perplexed the development in personal safety for a general improvement in all types of safety. It also carried out an employee survey of the five BP refineries with focus on Process Safety. The outcome of the survey showed that Toledo and Texas City had the worst process safety culture while Cherry point refinery had the best process safety culture. It also pointed out that white-collar workers appreciated process safety culture as compared to the viewpoints of blue-collar workers.

Process Safety concerns itself with the integration of technology, facility and people. Technologies are facing constant change and to keep up with this change the facilities should be updated and human resource more informed. Solutions for facilities such as Hazardous Area Classification, Emergency Relief Systems, Process Hazard Analysis, Electrostatic Hazard Assessment, etc. can be carried out in order to modernize it. Additionally, with regards to people management, solutions like behaviour based safety implementation, process safety culture, various trainings, etc can be conducted. People are an intrinsic part of the process and hence awareness is vital. Companies should aspire to achieve continual improvement instead of only complying with legal requirements. Process Safety elements are the key to continual improvement.

With progress of the technology and knowledge, updation of the rules and standards are necessary to facilitate continual improvement. And as an input, Government should adapt the standards, best practices and laws from time to time. In view of the large and growing industrial activities in India, Government should enforce the internationally accepted laws and best practices. These laws should be adopted and implemented keeping in mind continual improvement in safety, health and environment.

Sathya Priya  is a Safety Consulting Engineer with Chilworth Technology
Email: priya@chilworth.co.in

 

Neha Bhagtani is an Environmental Specialist with Chilworth Technology Pvt Ltd
Email: neha@chilworth.co.in