Safety Management Systems

OSHA/API
• Safety Management Systems Overview

• OSHA

• International Approach to Safety

Management Systems
• Review API 9100 A/B Model EHS
Management System
 Overview
History
Originally in the Chemical industry and has subsequently
developed into regulatory and industrial standards after several
catastrophic incidents including;
 Flixborough (1974)
 Mexico City (1984)
 Bhopal (1984)
 Piper Alpha (1988)
 Pasadena (1989)
ISO 14001 Environmental
Management Systems

Environmental
Policy

Planning

Implementation
& Operation

Checking &
Corrective Actions

Management
Review

4
API 9100
Model
 Safety Management Systems
Model (Typical)

Overall vision,
Continual goals and
commitment to
Improvement
improve

• Legal compliance
 Suitable, adequate, Safety Policy • Objectives and targets
effective • Implementation plans
 Changes needed?
 Opportunities to
improve?
Management Planning
Manageme
Review • Resources
• Monitoring and
Revie
nt • Leadership responsibility
• Training and competency
measurement
• Incident investigation g
Implementation
• Consultation and communication
• Documentation
Measurement Implementation
• Records management Checking & Operation
• Hazard identification, risk assessment and
• Audits Correctiv
& Evaluation
& controls
Actio • Emergency response

6
 Key Elements of SMS
Policy

Planning
From the previous
examples, there are
common elements
Implementing

Assessing

Management
Review

7
 Policy
Effective health and
Planning safety policies set a clear
direction for the
organisation to follow
Implementing

Assessing

Management
Review

8
 Policy

Planning An effective management

structure and arrangements
are in place for delivering the
Implementing policy.

There is a planned and

Assessing systematic approach to
implementing the health and
safety policy

Management
Review

9
 Policy
The policies and procedures
Planning are put in place to manage
all aspects of the control
measures that ensure safe
Implementing operation of the facility

Assessing

Management
Review

10
 Policy

Planning
Performance is measured
against agreed standards
Implementing to reveal when and where
improvement is needed.

Assessing

Management
Review

11
 Policy

Planning

The organisation learns

Implementing from all relevant
experience and applies the
lessons.
Assessing

Management
Review

12
 The Importance of SMS
• In reviews of accidents, a common thread
throughout is the inadequacy of management
systems that might have prevented the accident
from occurring
• Examples of some issues identified are
– Lack of hazard review and risk assessment to
predict and prevent incidents
– Insufficient investigation and follow up after
previous incidents
– Inadequate training of staff
– Failure to implement effective mechanical
integrity programs

13
The following information provides broad details on
some US incidents and contributing causes
Causes Expressed in Broad Management System Categories

12%

32%

Engineering & Design

Procedures & Practices
Management & Oversight
27%
Training & Communication

29%

14
OSHA in its Regulations uses the term
Process Hazard Management & Process
Safety Management
…same thing as SMS really
Process Hazard Management Overview
Definition
Process Hazard Management is the application of
management principles, methods and practices to
prevent and control accidental releases of
hazardous chemicals or energy

Goal of PSM
The goal of an effective PSM program is to prevent,
minimize or mitigate the consequences of
catastrophic releases of toxic, flammable or
explosive chemicals
Process Safety Management Overview
14 Elements of OSHA’s PSM Regulation

 Employee Involvement  Mechanical Integrity

 Process Safety Information  Work Permit Programs
 Process Hazard Analysis  Management of Change
 Operating Procedures and  Incident Investigation
Practices
 Employee Training  Emergency
Preparedness
 Contractors  Compliance Audits
 Pre-Startup Safety Review  Trade Secrets
 Steps to Implementing a PSM Plan
• Assess current status of PSM activities (Gap Analysis)
• Establish priorities for PSM activities
• Evaluate need for organizational changes
• Develop plan and schedule
• Estimate resource requirements
• Develop site-specific PSM guidelines
• Train personnel
• Phase in PSM activities
• Audit and Reassess for Continuous Improvement
 Keys for PSM Effectiveness
 Management Commitment
• Goal/Objective
• Resource
• Intent
 Training
• Managerial
• Personnel
 Auditing
• Self
• Third Party
 Employee Participation
Employers must develop a written plan of action
to implement the employee participation required
by PSM.

Under PSM, employers must consult with

employees and their representatives on the
conduct and development of process hazards
analyze and on the development of the other
elements of PSM, and they must provide access to
PHAs and to all other information required to be
developed by the standard.
 Process Safety Information
Information is required on:
• Hazards of the process
– Toxicity information, permissible exposure limits, physical data,
reactivity data, corrosivity data, thermal and chemical stability data
• Technology of the process
– Block flow diagram or simplified process flow diagram, process
chemistry, maximum intended inventory, safe upper and lower limits,
evaluation of the consequences of deviations
• Equipment in the process
– Materials of construction, P&IDs, electrical classification, relief system
and design basis, ventilation system design, design codes and
standards, material and energy balances, safety systems
 Process Hazard Analysis

Various PHA Techniques listed by the Standard:

• What-if
• Checklist
• What-if/Checklist
• Hazard and Operability Study
• Failure Mode & Effect Analysis
• Fault Tree Analysis
 Operating Procedures

Operating Procedures must cover:

• Initial Startup
• Normal Operations
• Temporary Operations
• Emergency Shutdown
• Emergency Operations
• Normal Shutdown
• Startup Following a Turnaround or Emergency
 Contractors

 Obtain and evaluate information regarding contract

employer’ s performance & programs
 Inform contract employees of plant hazards
 Explain applicable provisions of emergency plan
 Safe work practices
 Periodically evaluate performance of contract
employees
 Maintain a contractor employee injury/illness log
 Training

 Required content of training:

• Overview of Process
• Operating Procedures
• Health Hazards
• Emergency Operations
• Work Practices
 Refresher Training
• Maximum interval 3 years
 Documentation
 Pre-Startup Safety Review

 Construction & Equipment in Accordance with

Design Specifications
 Safety, Operating, Maintenance, & Emergency
Procedures in Place and effective
 Process Hazard Analysis Conducted &
Recommendations Implemented
 Modification of Facility Meets Management of
Change Requirements
 Operator Training Completed
 Mechanical Integrity

 Identification & Categorization of Equipment &

Instrumentation
 Document inspection criteria, Codes,
Manufacturer’s Recommendations, Types of
Tests, Frequency, Criteria for Replacement, etc..
 Develop Maintenance Procedures
 Training of Maintenance & Inspection Personnel
 Documentation of Test & Inspection Results
 Mechanical Integrity (continued)
Develop and implement written procedures to
maintain equipment integrity
 Procedures will be based on:
• Applicable codes
• Manufacturer’ s Recommendations
• Experience
 Process Equipment tests and inspections
 Inspection and testing frequency
• Manufacturer’ s recommendations
• Good engineering practices
 Documentation
 Correct mechanical deficiencies
 Work Permit Program
A formal work permit program must be in place to
control activities and procedures that present a
release and/or ignition hazard including:
• Hot Work
• Line Breaking
• Confined Space
• Lockout / Tagout
 Management of Change
 Written procedure for change
 Management of Change must address:
• Technical basis
• Impact of change on risk and health
• Modifications to operating procedures
• Time period for change
• Authorization requirements
 Inform and train affected employees
 Update Process Information
 Update Operating Procedures
 Incident Investigation

 Document releases and near misses:

• Date
• Description
• Contributing factors
• Recommendations
 Corrective Action Tracking
 Communication
 Emergency Planning and Response
)
Plan must be in writing and employees trained in:
• Employee Emergency Plans;
• Fire Prevention Plans; and
• Hazardous Waste Operations
 Compliance Audits
Certify evaluation of compliance (3 years)
 Document findings
 Implement findings, address deficiencies
 Can be addressed by developing checklists to
address:
• Paper compliance
• Actual effectiveness
 Trade Secrets
• The existence of trade secrets shall not interfere
with Process Hazard Management.
 Safety Management Systems
Similar to managing hazards by implementing the
elements we have just reviewed, international energy
companies have also focused their hazard management
efforts on implementing integrated
operations/quality/safety/environmental programs.
Safety Management System
 Safety Management Systems

Typical SMS Elements

1. Management Commitment and Planning
2. HS&E Standards and Procedures
3. Risk Identification, Assessment and Control
4. Employee Participation
5. Engineering and Change Management
6. Contractor HS&E Management
7. Compliance Controls
8. Equipment and Facility Maintenance
9. Health Management
10. Preventive and Corrective Actions, Assessments and Audits
11. Training
12. Emergency Preparedness Response & Security
13. Document Control and Recordkeeping
14. Performance Measurement and Continuous Improvement
SMS Standards Within Each Element
Management Commitment and Planning

• Health, Safety and Environmental Management

Policy Statements
• Roles and Responsibilities
 HS&E Standards and Procedures

This section of an umbrella SMS Program will

normally reference company HS&E Procedures
Manual(s) that may include:
– Management Systems (Details of SMS
Elements)
– Administration (Training, Inspections,
Audits, etc); and
– Work Practices (OIMs, PPE, ERP, etc.)
 Risk Identification, Assessment and
Control
To Reduce Risk As Low As Reasonably Practicable
(ALARP)
• HAZID
• Job Hazard Analysis
• HAZOP
• What-if
• Checklist
• HAZAN
• Environmental Impact Assessments (EIA)
 Employee Participation
• Hazard Control Committees
• Hazard Identification (e.g.. STOP Program)
• Employee Meetings
• Hazard Alerts
• Toolbox Talks
• Training Classes
• Investigation Feedback
• Awards and Recognition
Engineering and Change Management
• MOC Documentation and Feedback
• Project Management and Communication
• Shift Handover Meetings
• P&ID Reviews
• QA/QC Inspections
• Procedural Review
 Contractor Management

• Contractor EH&S Pre-Qualification

• Critical Vendor List
• Contractor Oversight
• Contractor Performance Evaluation
• Regular Contractor Meetings
 Compliance Controls

• Regulatory Updates
• Internal Compliance Audits
Equipment & Facility Maintenance
• Critical Equipment Review
• Critical Spares Program
• Preventive Maintenance Program
• Hazardous Materials
• Housekeeping
• Equipment Control Systems
• Inspection Programs
 Health Management

• Industrial Hygiene
• Medical Screening
• Food Hygiene
• Wellness Programs
• Injury Case Management
• Hazard Communication
• Waste Management
 Preventive and Corrective Actions,
Assessments and Audits

• HS&E Management System Audits

• Internal & External
• HS&E Management Inspection Schedule
• Senior Management & Line Supervisor
• Incident Investigation and Reporting
• Corrective Action Item Tracking
 Training

Training is key to the success of any Operations

and Hazard Management System. Training
standards should include guidelines on:
• Orientation
• Required Training
• Training Documentation and Tracking
 Training : Orientation
All employees, contractors and visitors should be
given a HS&E Orientation that at a minimum includes:
Review of HS&E Policy Statements
Facility layout and any special hazards
Safe Work Practices Handbook
Emergency Preparedness and Responsibilities
 Training : Required Training

The employer should develop a formal program of

required operational and HS&E training programs
for Management, Engineers, Supervisors,
Employees and Subcontractor employees.
This requires the development of a training matrix
that shows the required training for each job
position within the organization.
Both initial and refresher training guidelines
should be defined for each position
 Training : Documentation and
Tracking

All training programs should be formally

documented with written course agendas,
outlines and testing results.
A central tracking database should be maintained
that documents who has received what type of
training and when refresher training has been
scheduled
 Emergency Preparedness and
Response
Response Plans
• Conduct an emergency assessment
• Develop plans based on assessment results
• Publish a formal preparedness plan that is facility
specific
Emergency Equipment
• Conduct an emergency equipment assessment
including
• Fire Fighting
• Emergency Medical
• Communication
• Alarms
 Document Control and Recordkeeping

HS&E Records
• Medical Records
• Training
• Inspections/Audits
• Investigations
• Corrective Actions
Procedures
• Update when the following changes occur:
• Personnel Changes
• Equipment Changes
• Regulatory Changes
• System Clarifications
 Performance Measures and Continuous
Improvement
Leading Measurements
• OMS Implementation
• Job Hazard Analysis
• Hazard Recognition Programs
• Hazard Awareness Communication (Meetings, Courses, etc.)
Lagging Indicators
• First Aid
• Medical Treatments
• Lost Time Injuries
• Near Misses
• Equipment Damage
• Environmental Spills
API 9100 A/B Model Environmental, Health &
Safety (EHS) Management System

Two Parts:
API 9100 A Describes the Model
API 9100 B Guide to Implementation
 13 Elements

POLICY & PLANNING [PLAN]

1. Management Leadership,
Responsibilities & Accountability
2. Risk Assessment & Management
3. Compliance & Other Requirements
4. EHS Management Planning &
Programs
IMPLEMENTATION & OPERATIONS [DO]
5. Personnel, Training & Contractor Services
6. Documentation & Communications
7. Facilities Design & Construction
8. Operations, Maintenance & Management of
Change
9. Community Awareness & Emergency
Response
•MEASUREMENT & CHECKING [ASSESS]
10. EHS Performance Monitoring &
Measurement
11. Incident Investigation, Reporting & Analysis
12. EHS Management System Audit

MANAGEMENT REVIEW & CONTINUAL

IMPROVEMENT [ADJUST]
13. Management Review & Adjustment
 API 9100 B The “Guides”
Objectives
•more easily implement an EHS management system at a
company or facility;
•understand the basic purpose and scope of EHS
management systems (EHS MS);
• be familiar with the definition of a management system;
• clarify the relationship between operating and other
systems and an EHS management system ;
•understand and describe the characteristics of an
effective management system; and
•understand and describe how to evaluate an EHS
management system and its elements
 Conclusion
•Number of Safety Management System
“Models”
•All fundamentally are based on:
PLAN
DO
CHECK
ACT
Number of Elements used are variable but all
the basics must be covered.