C3 – Contain, Control, Communicate: A Framework for Implementing Process Safety Management

By Fred Ramirez, Controls & Automation Process Safety Technical Consultant

Every day, you take steps in your personal life to mitigate risks. Diversifying your investment portfolio, changing the oil in your vehicle, or wearing sunscreen are just a few examples. The motivation for doing these things is most likely driven by the desire to avoid the negative outcome that could occur if you don’t do them. In other words, you evaluate the risk and decide on appropriate actions to avoid or mitigate its effects.

For example, you might consider how likely it is that something bad will happen (engine damage) if you don’t change the oil in your vehicle. If engine damage occurs, the consequences (thousands of dollars for repair) could be pretty severe. That’s why, as a diligent car owner, you check your oil regularly and change it according to your vehicle’s owner’s manual to minimize that risk.

Corporations also take steps to mitigate risk. While their methods are more analytical and structured than personal risk mitigation strategies, both are driven by an analysis of the likelihood and the severity of a hazard. The higher the likelihood and the higher the severity of an adverse event, the more important it is that the risk be minimized.

Why Process Safety Management Is Important

This is especially true for the process industry. If you work in a facility that deals with highly hazardous chemicals (HHCs), you’re likely involved in the implementation or maintenance of your company’s Process Safety Management System, as set forth in OSHA Regulation 29 CFR 1910.119, process safety management of highly hazardous chemicals. The Process Safety Management (PSM) standard was implemented with the aim of preventing and mitigating hazards associated with catastrophic releases of flammable, explosive, reactive, and toxic chemicals that may endanger workers.

The PSM standard contains 14 elements, which spell out a wide range of requirements in different functions and areas – from employee participation to non-routine work to compliance audits. With a scope this comprehensive, ensuring that your company’s PSM system meets and follows the intent, requirements, and expected outcomes of the standard can be challenging. This is why we’ve distilled its core objectives down into three components – contain, control, and communicate, which we refer to as C3.

These C3 principles of PSM can help your organization determine the priorities, structure, and tasks involved in setting up a Framework for conducting the required analyses, programs, and audits.

Contain

The “contain” portion of the standard includes three elements:

• Mechanical integrity of equipment such as pressure vessels, piping, and emergency shutdown systems.
• Hot work permit requirements for fire prevention and protection when operations such as welding or grinding are conducted.
• Emergency planning and response requirements for a plant-wide emergency action plan, including for small releases of HHCs.

Together, these elements work to ensure that containers, such as piping, vessels, drums, and pumps are inspected and maintained, during operation, implementation, and design. These elements of the OSHA PSM Standard also ensure that HHCs are adequately contained by specifying that a plant should have procedures for non-routine work authorizations. The requirement of a documented, company-wide emergency response plan helps mitigate risk to employees, contractors, the public, and the environment if an incident does occur. In short, the ”contain” principle ensures that adequate safeguards are in place so that the risk of a hazardous event is reduced to an acceptable level for the operation.

Control

The “control” portion of the standard includes five elements:

• Process Hazard Analysis (PHA), which requires that any hazards related to the process are identified, evaluated, and controlled through engineering or administrative measures.
• Operating procedures, which address the need for procedures during any operation or startup/shutdown activity involved in the process.
• Pre-startup safety review requires that a process system check be conducted prior to startup for new or significantly modified PSM processes or facilities.
• Management of change (MOC) indicates that procedures be established for managing any change in chemicals, equipment, technology, or operating procedures, and that employees are properly trained when a change occurs.
• Employee Participation includes all members of the company to be actively involved in the process of containing, controlling, and communicating all appropriate actions necessary to safely store, handle, and process highly hazardous chemicals at all times.

The “control” principle refers to controlling the process, both from an administrative standpoint such as operating procedures, policies, and safety reviews, and from the standpoint of physical controls, such as actuators or solenoids to open and close valves. Administrative controls ensure control and management of the safety process, while physical controls prevent the unwanted transfer or release of hazardous chemicals. Management of change and pre-startup safety reviews ensures that the PSM system is applied not only to existing processes and equipment, but also to any changes that occur or to new equipment being placed into service. The key supporting element of the “control” principle is employee participation – in both the development and implementation stages of the PSM Framework.

Communicate

The “communicate” portion of the standard includes six elements:

• Process safety information, which specifies that information regarding the hazards of the chemicals, technology, and equipment used in the process should be compiled and organized.
• Training of personnel regards the safety and health hazards of a process, emergency operations, and safe work practices.
• Contractors, which specifies that the employer must inform and train contractors on processes, hazards, and safe work practices, and that the contract employer has similar responsibilities.
• Incident investigation, which must be carried out for incidents that resulted in or could reasonably have resulted in the release of HHCs in the workplace.
• Trade secrets, which defines where it may be necessary to disclose trade secrets for safety-related purposes and the right of the employer to enter into a non-disclosure agreement.
• Compliance audits, which must be conducted every three years to verify that procedures and practices are adequate and are being followed.

Communication encompasses the delivery of information necessary for the PSM Framework, as well as delivery of status information regarding the operation of the process. For example, sensors and alarms communicate the status of physical contain and control measures.

However, the safe operation of a facility also depends on effectively communicating processes, procedures, and expectations to personnel and contractors. Additionally, communicating the outcome of reviews, such as compliance audits and incident investigations, helps continually improve and strengthen the PSM Framework. A key enabler for the “communicate” principle is a commitment from the management team to support a culture of safety, including providing the training, resources, and policies required for the PSM Framework.

Put the C3 Principles to Work for Your Facility

The OSHA Process Safety Management standard contains elements relating to all aspects of storing, handling, and processing highly hazardous chemicals (HHCs) to protect the environment. Successful PSM programs are built on employee participation and supported by management commitment and adequate safeguards against risks.

The Hargrove Controls & Automation Process Safety Team includes process hazard analysis facilitators with comprehensive experience developing and implementing process safety management programs for clients. To learn how the C3 principles can help with your Process Management System, contact us today.