Health and Safety Practices and Measures in Refi ning & Petrochemicals
Ian Thorpe
Vice President - Health and Safety
HPCL-Mittal Energy Ltd

Pratik Sharma
Manager - Process Safety
HPCL-Mittal Energy Ltd

The oil and gas industry is vital to our nation and to our nation's economy. With India's oil demand projected to more than double in 25 years, the oil refining industry has tremendous growth opportunities. Health & Safety awareness is a vital constituent of oil and gas activities because most of the operational conditions, chemicals, and end products are known to pose serious threats. All employers, employees, and contractors within the oil and gas industry are responsible for ensuring safe and healthful work sites. This article looks at implementation of good safety systems and its performance measurement, monitoring methods.

To ensure the growth of business, organisation must be committed to continuously improving their safety performance at all of three areas - people, plant and processes. A focus on safety and health puts people first and that is the right thing to do. But it also makes good business sense because a good safety record reduces risk and costs. It enhances productivity. When we care for people, it is reflected in the care employees take for each other, for their equipment, and every aspect of their jobs. An organisation goal should always be safe production with people who are committed to continually improving safety performance every day.

The 3P's approach (Figure 1) which is focussing on below mentioned three key interlinked and overlapping areas is adopted by many of the industries -
1. People Safety - Driven by strong safety culture
2. Plant Safety - Driven by Process Safety Management system
3. Processes - Driven by Safety Management systems

For the 'People' area a programme of safety culture activities should be developed to provide improved safety culture in both occupational and process safety.

For the 'Plant' area, a defined PSM road map with milestones to achieve should be developed, it may be based on good process safety management (PSM) standard like USA OSHA process safety management (PSM) standard which is based on 14 PSM elements.

Figure 1

For the 'Processes' area the good Safety management system like OHSAS 18001 and associated continuous improvement process should be used.
1. People Safety -It is driven by strong safety culture and commitment of the management. To build and sustain any system like safety, reliability,operational excellence, the foundation must be strong safety culture .

What is Safety Culture?
A commonly quoted definition of safety culture is "The safety culture of an organisation is the product of individual and group values, attitudes, perceptions, competencies, and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation's health and safety management. Organisations with a positive safety culture are characterised by communications founded on mutual trust, by shared perceptions of the importance of safety and by confidence in the efficacy of preventive measures." (Reference - ACSNI Human Factors Study Group: Third report - Organising for safety HSE Books 1993)

Or in simpler terms "the way things are done in the organization"

Because safety culture is mainly about values, perceptions, attitudes and behaviours it is difficult to see and is often likened to an iceberg floating in water - the bit you can see above the water is only a small part of the whole iceberg. With safety culture values, perceptions and attitudes can't be seen but the resulting behaviours can be seen which is why behavioural observation programmes are used in organisations as part of a cultural change initiative.

Importance of Safety Culture
Good technical and management systems, procedures provide important structure for safety but without good safety culture, these do not produce required results. Many accident investigation reports identified poor safety culture as one of the major root cause of accidents. A good safety culture works like linkage and lubrication between the different technical and management systems to result in an effective outcome.

Safety Culture Measurement and Benchmarking
There is a saying "what gets measured gets improved". Eight focus areas are identified for improvement, measurement and benchmarking with international standards. The focus areas are:
1. Organisational commitment
2. Health and safety oriented behaviours
3. Health and safety trust
4. Usability of procedures
5. Engagement in health and safety
6. Peer group attitudes
7. Resources for health and safety
8. Accident and near miss reporting

Based on these eight focus areas, organisation can conduct annual survey of all its employees and contractors.

Actions to Improve Safety Culture
Elements of safety culture development must be started at the earliest in the organisations. It is also advisable that attributes of good safety culture is imparted from top leadership to future leaders and all employees of the organisation.

Attributes of a good safety culture:
  • Good safet y leadership -
    • Clear safety vision and senior level commitment
    • Leadership starts at the top but includes all levels of management
  • Visible management - "Walk the talk"
  • High levels of accountability & ownership for safety
  • Engagement and involvement of people at all levels
  • Good understanding and assessment of hazards
  • Clear and well understood procedures, rules and systems
  • Good safety communications
    • Has to be two way and must include all levels of the organisation
    • Listening skills are very important
    • How we say it, what we don't say and our body language are very important
  • Trust between management and frontline staff
  • High level of care for own safety and for that of others
  • Intolerance to unsafe acts / conditions
  • Clear and consistent rewards and punishments for safety - "Just culture"
  • Learning organisation
    • Uses every oppor tunity for learning & continuous improvement
  • Organizational pride
Some key actions followed by safety culture trainings and surveys are:-
  • Start of recorded safety walks for all employees at manager and above levels
  • Focus on senior management leading by example and always challenging anything unsafe
  • Monthly recorded housekeeping inspections in all areas - to generate 'pride in the workplace'
  • Star t of monthly safety briefing on the first day of each month - delivered at site by senior management and attended by all employees and contractors
  • Focus on improving local safety teams to give higher employee participation
  • Reward and recognition for safety must include ground level workforce
  • Focus on quality of accident / incident investigation - major training exercise on root cause analysis for investigations and adoption of good root cause analysis methodology and software as company standard.
  • Focus on ensuring strict compliance with basic safety rules
  • Launching of initiatives by which employee will think and review about hazards of activity before execution and provide feedback. Few examples are STAR (Stop, Think, Act, Review), STOP (Safety, Training, Observation ,Program) initiatives.
  • Focus on near miss reporting and identifying areas for improvement.
  • Focus on eliminating short cuts
2. Plant Safety - This approach include implementation of strong Process Safety Management System to ensure safety during refinery operation and maintenance activities, safety of equipment and stringent quality assurance criteria for equipment and contractor selection processes.

What is Process Safety?
Process Safety is preventing the release of hazardous materials or energies from operating facilities. Failure in Process safety may result in Industrial disaster and huge damage to both company and community such as Bhopal, BP Texas incidents. Process safety works on principle of different layers of protection from inherent safety features in plant design to handling of offsite emergency plans.

Importance of Process Safety
A strong Process safety management system prevents major process incident and boost up employees moral for working. It ensures that plant will run safely and reliably. After Bhopal incident in India, on 2nd December 1984, many countries understood that it is not only the personal safety, the process safety is equally important because, though the frequency of process safety incidents is low but their consequence is huge in terms of loss to community, loss of business and company's reputation. Many countries like USA (OSHA CFR 1910.119) and European Union (Seveso directive) made law for minimum compliance of process safety management system and are following very strictly.

Focus areas for improvement in process safety, its measurement and Benchmarking
Though there is no legal obligation to implement Process Safety in India but refinery and petro-chemical sector is going beyond the legal requirement and initiated implementation of process safety management system in their organisations. A dedicated PSM team frames a defined road map to implement Process safety management system in organisations. The scope of PSM road map is mainly based on OSHA CFR 1910.119 which includes 14 PSM elements. In Figure 2, PSM element organisation is shown under four different pillars.

Figure 2

Actions Taken to Improve Process Safety
To sustain a system, employees must participate and involve in that system implementation. Hence a PSM organogram should be framed such that it ensures participation of top management to bottom most employee of company and contractor. Roles, responsibility and accountability should be assigned to the persons involved in PSM organogram, and implementation progress should be monitored from different levels. A sample PSM organogram is shown as Figure 3 .

Some key actions suggested in PSM road map were as follows:-
  • PSM sensitization workshop for senior management.
  • PSM awareness training to all company and contractor employees.
  • Initiated senior management PSM walk through in process units to motivate, sensitize and explain the vulnerability of process activities to plant O & M persons.
  • Identification of PSM key activities where all employees can participate and provide an online portal for monitoring their participation.
  • Ensuring availability and accessibility of process safety information documents like PID, PFD, MSDS to plant operation and maintenance persons
  • Permit audits by plant operation and maintenance persons –like one permit audit per person per month.
  • Standard procedure for wr iting procedures.
  • Ensuring training, re-training, and validation of all O & M person for plant O & M pr ocedures. Mandatory PSM induc tion training for new joiners.
  • Standardisation of differ ent forms / check list formats.
  • Identification of PSM critical equipment and ensuring their inspection, testing and preventive maintenance as per schedule.
  • Identification of PSM critical activities and stringent selection and evaluation criteria for PSM critical contractors.
  • Strict monitoring and control over 'Management of change' process.
  • Better investigation of PSM incidents to get the human aspect in root cause identification through trained professional
  • HAZOP and QRA study for the company in minimum 5 year period.
  • Development of in ternal leaders for HAZ OP and PSM audits .
  • PSM dashboard for measurement of PSM leading and lagging indicators and monthly review of it.
  • PSM external audit based on some good PSM standard like OSHA CFR 191 .119
  • PSM gap assessment by 3rd party for analysis of it's effectiveness up to the shop floor.
  • Presentation and communication of PSM issues and highlights in monthly townhall meetings.
  • Observing important days like B hopal incident and shar e PSM lear ning.
  • Declaration of 'video of the month' from The US Chemical Safety Board (CSB) videos and conducting monthly competition on those videos.
  • Circulation of CCPS beacons and learning from incident (LFI) for employee awareness and ensuring these are being discussed and displayed in departments.
PSM Assessment Results
Process Safety Management System will be effective only if it is understood and followed by each and every employee in the organisation. Gap assessments and audits should be used to identify areas of improvement.

3. Processes (System, standards, procedures) - Safety Management systems is driven by high level of commitment to safety by all and should be framed based on best national and international practices.

Figure 3

Effect on Incidents
The ultimate aim of any safety management system is to prevent incidents and to reduce their severity. Organisations believe that "All injuries are Preventable" and "Any number beyond ZERO on incident rate, is basically a human who got affected at workplace". There are generally two key measures of injury accidents,are lost time accidents (LTA) and total recordable injury rate (TRIR ).

Actions to improve Safety Management System
  • Implement OHSAS 18001 safety management system standard with a program for continual improvement.
  • Software systems for manag ing and tr acking data
    • Dashboards
    • Safety portal / PSM portal
    • All incidents and audits are entered into SAP
    • Tracking of all actions from incidents and audits in SAP
  • Development and improvement of procedures
  • Improvement of risk assessments / Job Safety Analysis
  • Root cause analysis / learning from accidents
  • Training and ensuring competency for safety methods and systems
  • Internal and External Audit
    • Annual internal audit of all units / areas by multi-function team
    • 6 monthly OHSAS 18001 external audit
    • Oil Industry Safety Directorate (OISD) external safety audit
    • British Safety Council 5 Star audit
Organisation should follow a safety strategy of focussing on three key areas - Process safety management (Plant), Safety management systems (Processes), and safety culture (People). The first two of these provide the essential foundations of good safety but a good safety culture is equally important.

Use different tools like external audit, assessments and surveys to measure performance in these three areas of safety and to drive improvements.

Results from various companies have shown that following a structured process such as the one described can bring significant improvements in both injury rates and in the number of process incidents. This will make refining and petro-chemical sector a best place to work.