Implementing a Process-Safety Program

Between 2006 and 2009, Petronas Carigali embarked on a process-safety program driven by concerns over an increasing trend of process-related incidents. The program focused on defining explicit process-safety expectations and then putting in place the required processes to intensify implementation and mandatory compliance. Some 3–4 years into the program, tangible improvement can be felt across the organization.

Introduction

Petronas Carigali has an established Health, Safety, and Environment Management System (HSEMS), developed and implemented in line with the company’s Group Mandatory Control Framework and its associated Group Technical Standard.

The HSE Management System Manual broadly defines the company’s expectations for the effective management of matters relating to health, safety, and the environment. Associated procedures and guidelines define the processes by which compliance to the HSEMS is achieved.

Process-safety expectations were generally included with those of occupational safety. In retrospect, this approach was far from ideal in that the organizational safety focus would frequently tend to be on occupational safety, with major-hazard management left primarily to the initial facilities engineering design.

Process-Safety Framework

The process-safety program culminated in the development and issue of Petronas Technical Standards in eight key process-safety areas:

• Design integrity (DI)
• Mechanical integrity (MI)
• Management of change (MOC)
• Process-safety information (PSI)
• Process-hazard analysis (PHA)
• Preactivity safety review (PASR)
• Operating procedures (OPs)
• Proprietary- and licensed-technology assessment (PLTA)

On the basis of these distinct process-safety areas, Petronas Carigali was to incorporate these process-safety expectations as part of a substantially revamped HSEMS. Furthermore—and this was not done initially—operational procedures and guidelines defining the processes by which compliance is to be demonstrated needed to be formalized, to lend support in ensuring sustained compliance with the newly developed process-safety expectations.
During the initial 3-year period from 2006 to 2008, minimal progress was made in the implementation of process safety throughout Petronas Carigali. Audit findings alluded to ineffective and nonsustained implementation throughout the company; this was attributed to a lack of (a) process-safety leadership, (b) competent resources through underestimation of the work involved, and (c) clarity regarding the processes required to demonstrate compliance with the HSEMS expectations.

Consequently, a companywide review was carried out that culminated in the relaunch of the Petronas Carigali process-safety program (branded then as the Process Safety Change Management Initiative) in early 2009.

At that time, process-safety leadership teams comprising senior management, middle management, and technical professionals were formalized throughout Petronas Carigali, including process-safety steering, implementation, and working committees. The overall secretariat/coordination function for the process-safety program is vested with the company’s HSE organization, within which dedicated process-safety teams are formalized.

Implementation of Process-Safety Requirements

DI. Petronas Carigali has a well-established DI management system. The key expectations of ensuring that risk inherent in process facilities—in particular, risk associated with major accident hazards—is reduced to a level as low as reasonably practicable can be summarized as follows:

• Equipment and systems shall be designed with due consideration of the hazard associated with their construction and operation.
• The assessment of HSE risks shall be used as a basis for decision making during the design phase.
• Operational performance requirements are defined to ensure that suitable levels of dependability and effectiveness are achieved throughout the life cycle of the process facility.
• Equipment and systems shall be designed such that they can be decommissioned.
• The entire DI process shall be assured and, where necessary, subject to corrective action.
• Competent independent review shall be carried out as part of the assurance process.

MI. Petronas Carigali has an equally well-established reliability and integrity-management system. Key expectations aimed at ensuring that the operational integrity of process facilities is managed effectively through the application of effective inspection, maintenance, and operational strategies reflecting predictive, risk-based assessment of facility deterioration can be summarized as follows:

• All process, control, and utility equipment and systems shall be identified, cataloged, and categorized.
• Risk-based assessment techniques shall be used to determine the priority of facilities, with regard to the impact on HSE and business.
• Collected data shall be analyzed to identify imminent threats to integrity, and to determine trends of deterioration that shall be used to update risk profiles and set future intervention programs.
• Where failures occur, these shall be investigated to determine the root causes, recommendations made to prevent recurrence, actions tracked to completion, and risk profiles updated.
• The ongoing quality and technical basis for MI activities shall be monitored, and corrective actions taken where necessary.
• As part of the process-safety program, dedicated resources including external resources were assigned to carry out a compliance review—in particular, the application of effective inspection, maintenance, and operational strategies for safety-critical equipment/devices.

MOC. Petronas Carigali has a fairly well-defined MOC system, assessed as being generally consistent with the key stipulations of the 2006 Petronas Group Technical Standard, though some room for improvement remains. Key expectations, aimed at ensuring that the proper level of review is applied to prevent adverse effects from changes, can be summarized as follows:

• All facility, process, organizational, and procedural changes shall be subject to proper hazard identification and risk-assessment reviews.
• MOC shall ensure that the change is reflected on all relevant documents.
• MOC shall ensure that the change is communicated to, or training is provided to, affected personnel.
• The MOC process shall be monitored and improved continually, on both the usage and the compliance level as well as on the systemic level.

PSI. The requirement addressing PSI analysis is one of the process-safety areas in which a more-concerted effort is required as part of the process-safety program. The following key expectations are aimed at ensuring that all process-safety information is available and accurate.

• An inventory of PSI shall be maintained on the basis of a comprehensive and risk-based need assessment covering chemicals, process technology, and process equipment.
• Information shall be maintained in a controlled manner to ensure its integrity and accuracy.
• The development and update of PSI shall be triggered by events within other management processes.
• The quality of PSI shall be monitored and corrective action taken when necessary.
• Substantive efforts were required to attain compliance with this process-safety requirement, including developing operational procedures and guidelines and verifying the availability of the required process-safety information.

PHA. The PHA is another process-safety area in which a more-concerted effort is required. Key expectations aimed at ensuring that risk is reduced and maintained at a level as low as reasonably practicable can be summarized as follows:

• All installations handling hazardous materials and conditions shall be assessed by use of PHA.
• Fires, explosions, toxic and flammable releases, and major spills shall be considered in relation to equipment, instrumentation, utility systems, routine and nonroutine work, and other factors affecting the installation or process system.
• The analysis shall be led by competent personnel supported by a team of individuals with knowledge and experience of the installation or process system being considered.
• The results of the analysis shall be reported along with any recommendations for improvement.
• Actions resulting from the analysis shall be logged and tracked to completion.

PASR. The expectation on the conduct of PASR, previously limited to major simultaneous operations, was expanded to include other process-related activities, and some refinement of the overall expectations was applied. At a minimum, the required PASR shall be carried out before precommissioning and commissioning of new and modified facilities; shutdown and startup of facilities; decommissioning, mothballing, abandonment, or demolition of facilities; conduct of simultaneous operations that may result in greater risks to the facility; and establishment of handover processes for projects and operations. The required processes are now documented in operational procedures and guidelines.

OPs. While the requirement on written OPs has been well embedded in the HSEMS, audit/assurance regularly highlights issues relating to noncompliance. Key expectations can be summarized as follows:

• All normal, abnormal, and emergency tasks shall be described in written OPs.
• Hazards, including human behavior and error, associated with conducting the procedures and practices shall be identified and controls put in place to manage them.
• OPs shall define the activities to be completed; methods and tools to be used; data to be recorded; operating conditions to be maintained; samples to be collected; and health, safety, and environmental precautions to be taken.
• Training shall be conducted to ensure that users of OPs are aware of their existence, understand their applicability, and can apply their requirements.
• The development, review, and update of OPs shall be triggered by key events within other management processes.

PLTA. Managing risks inherent in adopting new technology or making changes to existing technology may have associated limitations, in particular where access to details of that technology may be restricted because of intellectual-property-rights issues or the needs of licensing.

This element of the process-safety program defines the risk-review process with a view to ensuring that the application of proprietary/licensed technology is properly specified, designed, configured, commissioned, operated, and maintained through adequate and effective risk management.

Key expectations are summarized as follows:

• Equipment and systems shall be designed with full cognizance of the risks associated with the specific operational environment and interfaced equipment.
• Sufficient information shall be made available to determine that suitable risk assessments have taken place and have been acted upon.
• Operator awareness of risks inherent in the technology will be ensured, and operators shall have sufficient information to be able to operate equipment effectively.

This article, written by JPT Technology Editor Chris Carpenter, contains highlights of paper SPE 157022, “Implementing a Process-Safety Program,” by Saiee B. Julaihi, Saifuddin Shah B. Sowkkatali, and Rabiatul Adwieah Bt Shukor, Petronas Carigali, prepared for the 2012 SPE/APPEA International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production, Perth, Australia, 11–13 September. The paper has not been peer reviewed.