Abstract Considerable reductions in process safety incidents have not been realized over the past 40 years despite the extensive developments in technology. Root causes for these incidents remain the same but the likelihood and severity of consequences have been slightly reduced. The debate continues - Why do we continue to experience similar incidents even with establishment of new tools, technologies, management systems and lessons learned? Is it the lack of process safety competency, corporate culture, or complexity of current management systems and associated tools contributing to the continuation of the learning failures? This paper will review the mutual causes of learning failures from past major process safety incidents and examine what has not changed over several decades. Improvement opportunities are provided for the most common learning gaps. Introduction Learning from incidents is not limited to just incident investigation, but much beyond that, learning from incidents is also ingrained into corporate policies, engineering and design standards, and operating management systems. So, it is important to identify and eliminate the gaps in these processes and systems to prevent the recurrences of major accidents. With enormous overall technological developments in the last several decades, processes, tools and management systems are getting more complex leading to inconsistency in operating management systems and hamper the effective implementing. The design, construction, and operation bring several opportunities for errors and mistakes during the life cycle of a project. That's why every project, when handed over to operations, has a long list of design and installation deficiencies. During the initial startup, operating set points are changed and a number of safety systems and alarms are bypassed. Some of these bypassed critical systems are never restored due to a lack of effective management programs. Consistent gaps are discovered in the operating management systems and process safety knowledge of the workforce. The most common causes of learning failures and improvement opportunities are clarified in order for each of the identified gaps to advance the learning process and prevent the recurrences of process safety incidents.

Introduction Many job tasks that expose workers to serious hazards in all industries are non-routine, maintenance-type activities that must be managed to control risks. These hazards are controlled in industry through written safework permits that are completed prior to initiation of these nonroutine activities. Safe work permits are administrative controls and must be developed, implemented, and managed properly in order to be effective at managing risk. Examples include hot-work permits, contractor-work permits, confined-space-entry permits, and line-break permits. Having a safe work permit management system to manage and review the effectiveness of these safe work permits is a proactive best practice. This management system must follow the continuous improvement-plan, do, check, act-process. Safety professionals and process safety practitioners can use this paper to guide them in the development of their own safe work permit management system and program. The Need for a Safe Work Permit System A survey conducted by a safety agency in the UK showed that a third of all accidents in the chemical industry were maintenance-related, the largest single cause being a lack of, or deficiency in, safe work permit systems. In a study of small- and medium-sized chemical factories, the HSE found: Two-thirds of companies were not checking systems adequately; Two-thirds of permits did not adequately identify potential hazards; Nearly half dealt poorly with isolation of plant, electrical equipment, etc.; One-third of permits were unclear on what personal protective clothing (PPE) was needed; One-quarter of permits did not deal adequately with formal hand-back of plant once maintenance work had finished; and In many cases, little thought had been given to permit form design. Safe Work Permit System Defined A safe work permit system (SWPS) is a formal written system used to control certain types of work that are considered non-routine and present potential hazards or take place in potentially hazardous work locations.

Introduction Through advancements in science, engineering, and industrial design, the use of flammable, toxic, explosive, and reactive chemicals in industrial processes continues to become more common. In many cases, commercial and industrial processes utilize a wide variety of chemicals to support the development and manufacturing of products and services. Depending on the process and facility, large quantities of highly hazardous chemicals can be present onsite to support operating needs and process demands. As quantities of highly hazardous chemical increase, careful consideration must be given to ensure hazards are controlled. When hazards associated with highly hazardous chemicals are not appropriately addressed, uncontrolled and unexpected releases can occur. When these incidents occur, they are not isolated to a specific industry or sector. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time hazards are not properly controlled, creating the possibility of a catastrophic or devastating incident. To help ensure safe and healthful workplaces, OSHA issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119). This standard contains requirements for the management of hazards associated with processes using highly hazardous chemicals. Process Safety Management (PSM) is addressed in specific standards for both general industry and construction. OSHA's standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices (OSHA, 2015). Through familiarity with the OSHA PSM standard and implementation where applicable, facilities can be better prepared to address hazards associated with processes using highly hazardous chemicals.

Introduction One of the dangerous and hazardous tasks in the realm of both process safety and safety at all facilities is non-routine process openings, commonly called line breaks. The risks involved in these processes affect the employees performing the task, workers and contractors throughout the entire site, and potentially could even impact off site receptors in the form of people and the environment. Line breaking is the one safe work practice that both the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) mention in their process safety standards, yet these agencies provide no guidance on what a line break process should look like. No Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) or consensus standard exists for guidance either. This paper will provide safety professionals and practitioners guidance on the development of a line break program for their facility based upon best practices. OSHA's Discussion of Line Break 29 CFR 1910.119(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping ; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees. Appendix C (Non-Mandatory) Nonroutine Work Authorizations states… Nonroutine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative or other person needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure for those that need to know the job is now completed and equipment can be returned to normal.

Introduction Chemical safety and process safety continue to garner significant media attention around the United States as chemical and process safety events continue to occur. OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program (RMP) standard provide a framework for preventing unwanted release of highly hazardous chemicals. It is also important to note that these are performance standards, meaning that regulated processes are told what the goal (unwanted release) is, not how to meet it. OSHA began a PSM National Emphasis Program (NEP) for Petroleum Refineries in June of 2007 and later implemented an additional PSM National Emphasis Program for Chemical Facilities in November of 2011. Enforcement data shows key trends and areas where both EPA and OSHA focus their efforts. This paper will review the key enforcement trends for PSM and RMP regulated processes, provide some best practices for ensuring process safety is a way of life, and review actual and potential regulatory activity resulting from Executive Order 13650 Improving Chemical Facility Safety and Security. OSHA and EPA PSM and RMP Enforcement Trends Most Cited OSHA PSM Elements February 26, 2014 – XXXXXXXX (Includes specific PSM standards cited ≥: 100 times by both Federal and State-Plan) Table 1 – Citations Sorted by Frequency Table 2 – Citations Sorted by PSM Element PSM Inspection History Summary (February 26, 2014 - XXXXXXXXXX) 1 Total Number of PSM Inspections 2 …………………………………………….…3,721 Total Number of Violations………………………………………………………..20,100 Total Initial Penalty……………………………………………………………$93 Million Total Number of CHEM NEP Inspection (Opened Nov. 2011 to 2/26/14)….………890 Total Number of Refinery NEP Inspections (opened as of 4/4/2013)……..…………74 Data Source: OSHA Office of Statistics Top Three (3) Best Practices Permit to Work System for Contractors Car Seal Program MOC for Personnel Changes Permit to Work System for Contractors Contractors tend to have a safety disadvantage due to their ever changing working environment. One week they are working in ABC Chemical Plant and the next they are working in XYZ Chemical Plant. Both of these plants have different safety and emergency response procedures with different phone numbers, different evacuation areas, different alarms, and much more. Even within the same facility, different units will have different alarms, different chemical hazards, different PPE requirements, and numerous other safe work practices. This is a lot to keep straight from plant to plant and unit to unit on a DAILY basis. Keeping in mind that almost all businesses train their contractors on an annual basis. A Contractor Work Permit provides a DAILY REFRESHER training for these workers as well as provides a HAZARD ASSESSMENT based on the current working conditions and the work the contractor will be conducting. Like other permit processes the daily Contractor Work Permit must be kept at the site of the work being performed. This permit reviews required safety equipment, emergency procedures, other required permits, and safe work practices such as lockout. The work permit process also fulfills the safe work practices of controlling the entrance, presence and exit of contract employers and contract employees in covered process areas. (1910.119(h)(2)(iv)

Executive Summary Managers of petrochemical companies are accountable for managing the safety of all workers within their facility. This requires addressing the two fundamental types of safety: personal and process. Although both ultimately result in workplace injuries, they have different characteristics. Personal safety manifests itself through unsafe working conditions or unsafe worker actions that result in an injury to the worker or his co-workers. While personal safety incidents may have a fatal outcome, they usually only expose the worker, or at most, a single work crew. The frequency of these types of incidents is driven mainly by the work environment that is allowed to exist. An insight into a company's effectiveness at managing personal safety incidents can be accomplished through reviewing their recordable injury frequency (RIF) rate. A process safety incident occurs when there is a loss of primary containment of a chemical being used in the production process. The magnitude of such an incident depends on the hazards of the chemical released. The chemicals may form a gas cloud that grows over a large area before finding an ignition source, or may be an inhalation irritant that affects everyone in its path. Process safety incidents have the potential to injure a large number of workers, and in some cases, the civilian population outside the manufacturing facility. These types of incidents usually occur when process equipment fails to operate as designed. They are often the result of the process equipment being assembled incorrectly or the wrong parts being installed. As described, there are significant differences in the underlying causes of personal and process safety incidents. Because of these differences, reviewing an organizations RIF rate will provide little insight into their ability to manage the prevention of process safety incidents. The best way to manage the risks associated with process safety incidents is to ensure that the craft workers repairing and assembling the process equipment are competent.

Introduction Chemical safety and process safety continue to garner significant media attention around the United States as chemical and process safety events continue to occur. OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program (RMP) standard provide a framework for preventing unwanted release of highly hazardous chemicals. It is also important to note that these are performance standards, meaning that regulated processes are told what the goal (unwanted release) is, not how to meet it. OSHA began a PSM National Emphasis Program (NEP) for Petroleum Refineries in June of 2007 and later implemented an additional PSM National Emphasis Program for Chemical Facilities in November of 2011. Enforcement data shows key trends and areas where both EPA and OSHA focus their efforts. This paper will review the key enforcement trends for PSM and RMP regulated processes, discuss how other OSHA regulations are pulled into the PSM NEP inspections, and provide some best practices for ensuring process safety is a way of life.

Safety professionals are continually looking for indicators that can forecast future safety performance, and "near-misses" can serve as one of those leading indicators. Of primary importance is the reporting of "near-misses", followed by investigation into the causes and into the effectiveness of devices and systems that had prevented a "near-miss" from escalating to a serious incident. Presented here are several types of "near-misses" that may be overlooked in the chemical industry, but that can provide insight into improvements that can be made in the design, operation, and maintenance of chemical facilities, with the objective of preventing injuries, minimizing property losses, and avoiding damage to the environment. "Near-Misses" as Leading Indicators for Process Safety Introduction As safety professionals, we are continually looking for indicators that can guide us in evaluating safety performance and in allocating limited resources in directions that can have the greatest benefit. The so-called "lagging" indicators are derived from past performance, typically in terms of injury frequency, property losses per year, and the frequency of "insults" to the environment or to the surrounding population. Lagging indicators are easy to compile, because the data may be required by Federal or local regulations, or may be readily available in some other form, such as news reports. Somewhat in contrast, "leading indicators" are more difficult to derive, and the data for their derivation may not be readily available. The simplest leading indicators are trends in the lagging indicators. An example would be a downward trend in injury frequency that may forecast a continuing decrease in the number and frequency of injuries. Contrarily, an upward trend in injury frequency should be a cause for alarm, and indicating a need for greater effort in compliance with safety rules and procedures, better management of employee actions, and, possibly, increase in staffing. Display of trends in lagging indicators can assist corporate and site managers in determining the effectiveness of safety policies and programs, and also in determining the effectiveness of managers and supervisors in ensuring compliance with those policies and programs.

Introduction Implementing an effective process safety management program on a chemical weapons demilitarization facility is challenging. Accomplishing the mission and maintaining effective risk reduction requires a strong commitment to safety, a well-written program, a dedicated and competent team, and proven processes. On U.S. military contracts, MIL STD 882D is implemented as System Safety Engineering and complies with process safety requirements. This presentation provides an overview of the Blue Grass Chemical Agent Demilitarization Pilot Plant System Safety Program. A brief overview of the chemical weapon demilitarization program and the Blue Grass Facility will be provided followed by a short video of the Rocket Cutting and Rocket Shear Machines.

Introduction The safety of highly hazardous processes has been dramatically affected by the implementation of process safety management principals. Implementation of process safety standards by OSHA and EPA, as well as preceding state standards, have helped to apply rigorous management principals to control hazards for processes that use large quantities of flammable or toxic substances. However, the concepts of process safety can, and should be, more broadly applied to manufacturing processes, which may not be subject to strict regulatory requirements, to minimize the potential for catastrophic incidents. Recent examples of incidents that could have been prevented through the implementation of process safety elements include the CAI/Arnel explosion in 2006 and the Kleen Energy explosion in 2010. These incidents reflect the common threads of any significant incident: lack of hazard awareness, lack of adequate process controls, and the inability to recognize the potential for multiple infrequent events to cause a catastrophic loss. Safety professionals have a number of formal tools at their disposal to help identify and communicate hazards; some more involved than others. One of the most involved and comprehensive tools is the Process Hazard Analysis (PHA). The process hazard analysis is an element of process safety, used to dissect and identify elements of process hazards incorporating both the engineering (structural) and human factors (operational) elements that can have both a positive or negative impact on the overall safety of the process. Facilities covered by OSHA Process Safety Management are required to conduct PHAs every five years, or more frequently in situations where the process changes. PHAs are conducted during process changes to analyze the consequences of these changes and verify that the changes do not impact the overall safety of the system.

Facilities governed by the OSHA Process Safety Management Standard, 29 CFR 1910.119, are required to implement a Mechanical Integrity Program. Equipment used to process, store or handle highly hazardous chemicals covered under the standard must be designed, constructed, installed and maintained to minimize the releases of such chemicals. The Mechanical Integrity Program must include the following types of PSM-covered equipment: Pressure vessels and storage tanks Piping systems and components such as valves Relief and vents systems and devices Emergency Shutdown systems Controls (monitoring devices, sensors, alarms and interlocks) Pumps Elements of a Mechanical Integrity Program include: Identifying and categorizing PSM-critical equipment and instrumentation Equipment manufacturers' recommendations and mean time to failure rates Inspection and test methods and rationale for inspection frequencies Criteria for acceptable inspection and test results Maintenance procedures Training of maintenance personnel Recordkeeping In this session we will focus on techniques for improving the quality of Mechanical Integrity audits. Good audits "peel the onion" several layers deep to identify strengths and weaknesses of the program. The goal is to drive continuous improvement.

Introduction The number of both undergraduate and graduate degree programs in Safety, Health and Environmental (SH&E) has enjoyed strong growth for the past 30 years as evidenced by the growth in the number of academic degree programs. ASSE reports the number of academic programs in SH&E to be approximately 200. As an academic discipline, in contrast, homeland security (HS) is relatively new, with the "older" programs now in their fifth or sixth years. In 2006 the Center for Homeland Defense and Security, housed in the Naval Post Graduate School, reported approximately 22 academic programs in HS at both the undergraduate and graduate levels. Today that count is reportedly in excess of 300 programs nationwide (CHDS, 2011). Such growth indicates that students and universities seem to be increasingly interested in developing and supporting academic HS programs. Both programs share many interesting traits and characteristics such as: both are broad field applied social sciences; both utilize principles and concepts of risk management as the core of their intellectual underpinnings to detect and deter and to mitigate wherever possible; effectiveness for both is centered on continuous quality improvement processes; both are interested in public health and pandemic planning as well as emergency management; both are interested chemical process safety management, etc. Based on the authors' recent experience in designing and implementing an outcomes-based undergraduate degree program, and 15 years experience in designing accreditation criteria in safety, this presentation will discuss the nature of homeland security as a growing academic enterprise; the outcomes that currently define most HS programs; and how safety academics may construct dual (or joint) degree program options that leverage the intellectual crossovers that exist between the two fields. and thereby positively impact enrollments, job and internship possibilities for students, and funding and research possibilities for faculty. Online delivery options for the joint program will also be explored.

Introduction On July 27, 2007, the U.S. Department of Labor, through the Occupational Safety and Health Administration (OSHA), issued Directive Number CPL-03-00-004, which was entitled Petroleum Refinery Process Safety Management National Emphasis Program. On August 18, 2009, OSHA issued a second updated Directive CPL-03-00-010 for the petroleum refining industry, replacing the initial National Emphasis Program (NEP). With the exception of some minor editing changes, the only significant change to the second Directive was to extend the time for completing inspections under the former NEP for two of OSHA's Regions – Region VI and Region VIII. The purpose of this new, updated Directive is the same as with the initial Directive; to reduce or eliminate the workplace hazards associated with the catastrophic release of highly hazardous chemicals from petroleum refineries. The Directive applies to all OSHA regions and contains instructions for inspecting petroleum refineries included in Standard Industrial Classification (SIC) 2911 (North American Industrial Classification System (NAICS) 324110) and contains policies and procedures to verify employers' compliance with OSHA's Process Safety Management (PSM) of Highly Hazardous Chemicals standard, 29 CFR 1910.119. This paper will focus on several aspects of the NEP including why OSHA implemented a NEP for the petroleum refining industry, a discussion of some of the events that lead up to issuing the NEP, and a review of the latest inspection data that has resulted from inspections conducted to date.

Background Information Following tragic events such as the 1984 Bhopal, India incident as well as several high-profile industrial accidents around the United States in the late 1980's and early 1990's, amendments to the Clean Air Act (CAA) were enacted into law on November 15, 1990. Section 304 of the CAA required the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), to promulgate, pursuant to the Occupational Safety and Health Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals that could pose a threat to employees. On May 26, 1992, 29 CFR Part 1910.119 – Process Safety Management (PSM) of Highly Hazardous Chemicals, became effective. The purpose of this Occupational Safety and Health Administration (OSHA) standard is to establish requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. To protect the public and environment beyond the regulated facilities' property lines, the EPA promulgated the Risk Management Rule (49 CFR Part 68) in 1996. The EPA and OSHA standards are performance based and are very similar in nature but have some differences. In simple terms, the OSHA PSM Standard is intended to protect employees. The EPA Risk Management Program (RMP) regulation is intended to protect the public and the environment. Both standards require a compliance audit at least once every three (3) years.

In the implementation of Process Safety Management (PSM) to a highly hazardous process, those who implement or lead this effort need good feedback to ensure that development and continuous improvement of the managing systems do occur and that the desired results are achieved. This feedback can come in more than one form. One important feedback method is the use of metrics. A second valuable and often more detailed feedback system is the periodic and robust process of auditing. As such, I am going to discuss "Process Safety Management, What Is the Right Audit Approach for You?" I will share my perspectives as one who has been involved in thousands of audits. I have worked primarily in operations management at eight different plant locations, on three continents, and with two different companies. In addition, I have held various regional and global positions which required travel to many other sites. Most of my experience has been in conducting First Party Audits and I have also been audited by both Second and Third Party Audit teams. And now, as the Global Process Safety Management Leader for DuPont Safety Resources, I conduct what amounts to third party assessments (or audits) for current and potential clients around the world. Universally, I have found auditing to be critical to the successful implementation of Process Safety Management. The same could also be said of just about any managing process that is being implemented--Six Sigma, Lean Manufacturing, Environmental Planning and Product Stewardship. So what is the right audit approach for you? I will organize the balance of my presentation around the simple concept of First Party, Second Party and Third Party Auditing, describing from my experience the pros and cons of each and why each type should be included in your own audit approach. And as I referenced earlier, I also believe strongly that the learnings I will share with respect to PSM auditing have strong relevance to all forms of EHS auditing. First Party Auditing First Party Auditing is a term with various definitions. DuPont's First Party Audit Standard defines five different types: Behavior Based Audits where an employee or employees observe other employees performing work and then provide feedback Layered or Tiered Audits where a manager leads an audit team of individuals from his/her organization. This allows the manager to demonstrate his/her value for safety and establish high standards of compliance and performance Area Audits where the focus is a geographic area of the site Cross Area Audits where an area audit is performed by auditors drawn from other areas within the site Focused Audits where the audit concentrates on a single aspect of the EHS or PSM management system I am a bit of a traditionalist; therefore, for me, a First Party Audit is analogous to writing in the first person when the pronouns "I" (singular) and "we" (plural) are used. Auditing in "first person" is the spirit behind First Party Auditing where managers and workers audit themselves, observing current conditions.

The following three slides from OSHA 1 - Failure to identify PSM-covered equipment Some facilities take the attitude that "anything in the fence line we consider a part of PSM." The problem with this is that once such a policy is formally stated, regulatory inspectors must take the policy at face value. That means that non-process equipment, which has no potential to cause or contribute to an uncontrolled release of hazardous chemicals, must be treated the same as equipment that can cause such a release. This can lead to absurdities such as an inspector asking to see the Process Hazards Analysis (PHA) on systems with no process hazards. To reduce the amount of paperwork required, most owners use a consistent philosophy in determining what equipment belongs in their PSM program and what doesn't. One typical means of identifying PSM-covered equipment is the "two valve rule," which states that any piping that is physically connected to the hazardous chemical process remains a part of the PSM-covered equipment until isolated by two manual block valves. The PSM-covered equipment should be clearly identified and segregated from non-PSM-covered equipment. The usual way of designating this is to use a set of Piping and Instrument diagrams (P&IDs) with the PSM-covered equipment highlighted. Additionally, a written record of what method was used to identify the equipment (two-valve rule or other) should be a part of the site Process Safety Information (PSI). - Failure to consider the carseal program as part of PSM Safety-critical equipment such as pressure relief valves, rupture discs, vent headers, and flare headers will not function if isolated by manual block valves. To ensure safe operation, most such equipment's manual block valves are either chained/locked and/or carsealed in their operational positions. To be effective, a carseal program must be regularly verified, documented, and audited. Any carseal found broken, or any safety-critical manual valve found in an improper position should be treated as a PSM-Near-Miss. A full PSM investigation should be held to determine what happened, why it happened, and what should be done to prevent it from happening again. Carseal programs that are not given this level of attention are usually not effective. - Failure to perform mechanical integrity inspections on schedule Audits usually reveal some overdue percentage of pressure vessel, tank, instrument, and rotating equipment inspections. When an inspection must be delayed, a Management of Change (MOC) procedure should be instigated to determine what, if any, additional safeguards are required in the interval between the original inspection due date and the time of the delayed inspection. illustrate results from the Refinery Special Emphasis Program inspections to date. Note that of the 215 Process Safety Management (PSM) citations listed in the first slide, 48 of them (22%) are either equipment deficiencies or other mechanical integrity issues. The second and third slides list examples of shortcomings identified in the mechanical integrity area. (Figure in full paper) The following Mechanical Integrity shortcomings are typical of those found in third-party PSM audits:

Abstract Due diligence in mergers and acquisitions (M&A) often focuses on environmental issues, both remedial and compliance. Due diligence associated with health and safety (H&S) concerns is not prevalent during transactions. Typically, limited site observations are combined with an assessment of Worker's Compensation trends (injury and illness statistics). Unfortunately, this approach ignores a significant source of potential M&A liability - compliance with the Process Safety Management standard (29 CFR 1910.119). Process safety management issues, especially those of mechanical integrity and adequate hazards analysis, can cost substantial sums of money to correct, and if uncorrected, can lead to catastrophic loss exposures. Recent accidents and subsequent follow-up reports and findings show how important PSM issues can be in managing a company's risk. This article discusses an approach to M&A due diligence that optimizes on-site evaluation time; reduces the uncertainty associated with acquiring PSM-subject facilities; and allows an acquirer to develop a rational approach to implementing a PSM program consistent with their firm's PSM approach and values. Introduction Mergers and acquisitions (M&A) are an increasingly familiar part of life in international business. In 2006, more than $3.6 trillion in transactions were consummated. With increasing activity comes increasing interest in more competitive deals and less ability to complete "leisurely" due diligence. As such, the scope of due diligence is being constantly reduced, and the time allowed for conducting due diligence has nearly evaporated. Within the environmental, health and safety (EHS) arena, due diligence generally focuses on past environmental remedial liability (defined in large part by CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act). However, after experiencing acquisitions with significant environmental compliance liabilities, more proactive companies have increased their emphasis on environmental regulatory compliance. In the realm of H&S, however, little attention has been paid to overall compliance. In general, acquisition due diligence consists of a desk survey of current Worker's Compensation costs and illness and injury statistics (OSHA 300 logs). In some instances, field observers completing environmental due diligence may be asked to make safety observations, but in general they have little competency in the PSM arena and can only spot the most egregious issues. As such, acquiring firms may be subject to liability for potentially catastrophic events resulting from process safety concerns. For example, in 2004, an explosion at the Formosa Plastics Corporation facility in Illiopolis, IL resulted in the death of five employees. The U.S. Chemical Safety and Hazard Investigation Board (CSB, 2007a) found that a root-cause of the explosion was failures in the PSM-required analyses conducted by the prior owner, Borden Chemical.

Introduction In the early morning hours of December 03, 1984, over forty (40) tonnes of methyl isocyanate (MIC) leaked from the Union Carbide India plant in Bhopal, India. More than 3000 people immediately perished from the accidental release of highly toxic MIC gas, and an additional 15 000 deaths, along with numerous health-related claims, were attributed to this event. On July 06, 1988, the Piper Alpha oil production platform, operating in the North Sea, suffered a series of explosions that led to an uncontrollable fire that engulfed the platform and claimed the lives of 167 crewmembers. A leak of natural gas condensate, which had built up beneath the platform was deemed to be the cause of the first explosion that eventually led to the demise and sinking of the platform. Like the Bhopal, India catastrophe, the sudden and unexpected release of a highly hazardous substance initiated a series of events that led to a significant loss of life and assets. These are only two examples of the disasters that have plagued the evolution of industrial processing and manufacturing. While there have been significant advances in technology and control systems, the opportunity for these situations to be repeated continue to exist in the 21st century. It has been recognized that to prevent these critical loss occurrences a systematic approach towards hazard identification and risk analysis is also needed. In 1992, the Occupational Safety and Health Administration (OSHA) formally recognized this vital component for managing high hazard chemical processes within the United States. A company that is involved in high hazard chemical processes or activities is mandated to implement a process safety management system. This system must include the systematic identification of hazards, risk level, and control strategies or corrective actions needed to prevent and/or minimize the consequences of a hazardous substance release. These requirements are defined by the Process Safety Management (PSM) of Highly Hazardous Chemicals, Explosives and Blasting Agents standard; OSHA 29 CFR 1910.119. Process Safety Management Process Hazard Management is also called Safety Systems Management or Process Safety Management. Regardless of the terminology, these are all systems that have been developed to manage the risk to personnel, property, production, the environment and ultimately, the company reputation. The occurrence of major industrial accidents and subsequent implementation of forceful safety and environmental legislation in many countries has made the Process Safety Management (PSM) or Process Hazard Management program an industry standard. The Process Safety Management (PSM) standard (OHSA 29- Part 1910.119) is the regulatory framework for process industries in the USA and is quickly becoming the industry " best practices" standard for responsible companies worldwide. American Petroleum Institute (API) Recommended Practice 750–1990, is the recommended standard for Canadian process industries and includes similar considerations for a PSM program and PHA evaluation.

ABSTRACT Unexpected release of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have occurred numerous times in industry. The Occupational Safety and Health Administration (OSHA) estimates that losses can be reduced tremendously if proper safety precautions and preparation at job sites are initiated. Elements of process safety management from both legal and technical viewpoints are discussed. Application of hazard evaluation methodologies to the safe design and operation of potentially hazardous chemical and petroleum processes are demonstrated. These procedures identify the hazards that exist, the consequences that might occur as a result of the hazards, the likelihood that events might take place that would cause an accident with such consequences, and the likelihood that the safety systems and emergency alarms and evaluation plans would function properly and eliminate or reduce the consequences. System application of Preliminary Hazard Analysis, What If Analysis, Fault Tree Analysis and Hazard and Operability Analysis are discussed. Elements of OSHA's Process Safety Management Standard are also discussed. This OSHA standard contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, flammable, reactive, or explosive chemicals. INTRODUCTION The advent of complex and high-energy hazardous processes has made process safety management an integral element of process design and operation. Catastrophic events such as Flixboro explosion, Seveso Dioxin release and Bhopal toxic plume release, and a host of others are examples of disasters which could have been prevented by proper application of process safety management techniques. The Flixboro event showed the importance of proper controls when administering changes in plant design such as engineering verification of changes and effects of vapor cloud explosion. The Bhopal event showed the importance of maintenance and administrative controls. The major objective of process safety management is to prevent unwanted releases of hazardous chemicals especially into locations, which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs and other elements which impact the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment.

Abstract Chemical process related events are often complex in nature, involve multiple simultaneous failures, and sometimes have catastrophic consequences. Bhopal, Seveso, and Flixborough are three examples. A robust root cause incident investigation approach is necessary to understand the event scenario and identify the underlying causes. To meet this need, a team of chemical industry representatives have developed an updated and expanded version of the CCPS Investigation Guidelines that reflect changes in industry practices and expectations since the original 1992 edition. These significantly expanded guidelines provide a practical resource for effective investigation of process related incidents. This paper highlights the content of the new guidelines with special emphasis on what is new and improved. Entirely new chapters address the topics of legal considerations, the near-miss event, and continuous improvement of the investigation system. The objective of the guidelines is to allow chemical process organizations to develop and implement an incident investigation management system effective in identifying underlying root causes and laying the foundation for improvements. CCPS Incident Investigation Guideline, Second Edition Introduction and Overview Chemical process incidents are often complex in nature, usually involve multiple simultaneous failures, and sometimes have catastrophic consequences. Three examples detailed in "Normal Accidents" 1 are Bhopal, Seveso, and Flixborough. A robust root cause incident investigation approach is necessary to understand the event scenario and identify underlying causes for these complex events. Although numerous incident investigation guidelines have been published over the years, specific guidance for investigation of chemical process events was missing. In recognition of this need and of the potential contribution incident investigation can make towards managing process safety, the Center for Chemical Process Safety (CCPS) developed and issued an investigation guidebook in 1992, Guidelines for Investigating Chemical Process Incidents 2 . Since that time, performance standards and best practices for investigations have continued to improve. There is a new and higher level of expectations on the part of regulatory agencies such as the Chemical Safety Board. The Center for Chemical Process Safety (CCPS) was formed in 1985 as a directorate of the American Institute of Chemical Engineers. The objective of CCPS is to develop and disseminate technical information for use in prevention of major chemical accidents (fires, explosions, loss of containment releases, uncontrolled reactions, equipment failures and control system malfunctions). CCPS recognized the role of effective incident investigation and published the original investigation guidelines in 1992. Incident investigation is a component in all recognized Process Safety Management Systems (OSHA 1910.119, EPA RMP, American Petroleum Institute, American Chemical Council, SOCMA, and others).