How can you identify process safety gaps in your plant?

The ultimate "holy grail" could potentially sound as "to be at least one step ahead". Not always possible, but the best way to achieve this goal, is to include PDCA (Plan-Do-Check-Act) cycle to this life-long (at least work-life) to repeating occasions (maintenance, shutdown, major turnaround, emergency events etc). However, the best is to learn from others' learnings / faults. There is a handful of sources to look into (e.g. CSB database) and learn from safety gaps.

Understanding your plant's process safety framework is an essential first step in mitigating risks and enhancing operational efficiency. It's not just about compliance; it's about fostering a culture of continuous improvement. Start by familiarizing yourself with the key components—regulatory standards, best practices, and internal policies—that define the goals and measures of safety. This will give you a solid foundation for assessing performance metrics that matter, avoiding legal pitfalls, and ultimately boosting your bottom line. Let's not forget that responsible management of hazardous materials serves the dual purpose of protecting your team and the environment, thus ensuring the sustainability of your operations.

Audit (that serves the purpose) looks for "glitches" and "space for error", barriers defunct or (maybe due to proffesional blindness) potentially dangerous conditions. To be able to achieve this, auditor must not only be prepared in advance in high quality (there are numerous checklists to prepare oneself), but also combined knowledge AND experience. The experience is usually the auditor's best friend and advisor :) The audit should not happen just once. The more the auditor returns to the site, documentation, instructions and SOP's, investigation reports, etc., the deeper he's able to dig (and uncover potential danger sooner than it happens).

Conducting a process safety audit is a critical next step for pinpointing gaps in your safety management system. By engaging in a thorough examination of elements like process design, operational procedures, and emergency response protocols, you not only confirm adherence to essential compliance standards but also uncover areas for improvement. Keep in mind that the scope and frequency of these audits can vary; internal audits may suffice for routine checks, but external audits provide an unbiased, third-party perspective. Ultimately, the aim is to identify weaknesses and take corrective action swiftly. This not only elevates your safety protocols but also contributes to operational efficiency and long-term sustainability.

What really is a base for (and a ground stone for process safety) is precise and up-to-date documentation AND operators complying. Documentation should be checked for updates regularly (at least once per TA/SD cycle) and updated every time some physical or operational condition changes (e.g. CAPEX finished, new line installed, change in e.g. catalyst preparation, moving, loading etc.). Each and every operator should be adressed with the changes (in my experience, the best way to do this, is to highlight changes in documentation compared to previous issue). Regular check with operators on structured (scheduled or random) questions and situations.

Analyzing process safety data is instrumental in closing safety gaps and enhancing operational robustness. Utilize both lagging and leading indicators to get a comprehensive view. Lagging indicators like incident reports and environmental impacts offer retrospective insights into what went wrong. Leading indicators, on the other hand, such as risk assessments and communication metrics, provide a proactive framework to predict and mitigate future issues. Through meticulous data analysis, you can discern underlying causes, discernible trends, and recurring patterns. This actionable intelligence allows you to prioritize areas for improvement, fortifying not only your safety protocols but also operational efficiency and long-term viability.

In my opinion, most repeated gaps should be "accumulated" and "popularised" as, say, Life-Saving rules. Those should be not only output of (repeated) learning points from one's plant, not even whole company, but whole (accessible) knowledge - worldwide statistics, worst events investigation reports, safety gurus' publications (e.g. Trevor Kletz). These rules should then be propagated (teach-by-example) and checked top-down. Regular study and learning path then is aimed to look for similarities (and hence dangerous gaps) with unplanned events investigation reports. The last (but not least) "safety net" is to perform hazard identification study (e.g. HAZID or HAZOP) at NEW (planned) test-run or investment AND regularly on the plant as such

Implementation of process safety improvements marks a critical juncture in addressing identified gaps. Any modifications—be it in process design, operational protocols, or emergency response plans—need to be systematically executed. Employ a structured approach like the Plan-Do-Check-Act cycle to ensure these changes are not only implemented but also rigorously evaluated for effectiveness. Monitoring and continual adjustments are key to achieving lasting impact. Additionally, the inclusion of all stakeholders in this process is vital. Their collective feedback creates a more comprehensive and effective safety improvement plan, thereby enhancing not only your safety metrics but also overall operational excellence and stakeholder confidence.

There is just one rule I feel working always - talk to people. Regularly and irregularly. When needed and also when all-goes-well. Teaching by example (walk-the-talk) is of course true, but still, some people are immune even to this.

The final step in identifying and addressing process safety gaps is clear and effective communication with all relevant stakeholders. This step is crucial for several reasons—it fosters awareness and understanding of the safety goals and requirements, enables the sharing of lessons learned and best practices, and builds broad-based support for ongoing and future safety initiatives. The mediums for this communication can vary from formal reports and presentations to newsletters and even visual cues like posters. The key is to ensure that the communication is tailored to different audiences, from the shop floor to the boardroom, thereby promoting a safety-first culture that boosts overall performance and stakeholder confidence.

Everything changing should be covered by a proper "Change management system". Each capex, TA actions, minor upgrades, major (e.g. catalyst type) change in process chemicals / catalysts / adsorbents / fillings / packings, each should have a trackable process, records and especially risk assessment document (HAZOP / HAZID / WHAT-IF / BOW-TIE).