"Evergreening" has been a buzzword in the domain of process safety information (PSI) for over a decade, yet we are still challenged trying to accomplish this seemingly simple concept. OSHA's 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals requires documenting the relief system design and design basis, correcting
Zubin Kamara, Principal Engineer, PE, PMP, Smith & Burgess
deficiencies in a timely manner to ensure safe operation and keeping the PSI up-to-date. Evergreening is a significant investment of time and resources, and though we recognize having available, on-demand, accurate, up-todate PSI is a best practice, process safety professionals are all too familiar with the obstacles and pitfalls of implementing and maintaining this process. This is especially challenging today, when uncertainty on multiple fronts can result in tightened pursestrings, limiting resources and options.
I am going to highlight three failure points that can hamper your efforts to maintain an evergreen PSI system and how to forestall them. The three failure points are:
- Failure to transition away from legacy systems.
- Failure to provide the right expertise to identify the impact to pressure relief systems.
- Failure to institutionally learn from individual lessons learned.
The first failure point typically presents as an obstacle to ever-greening in that either the effort is duplicated in new and legacy systems, or that one or both systems becomes an incomplete (and therefore inaccurate and unreliable) record, leading to a lack of trust in the information in one or both systems. The causes range from incomplete mapping between the systems, which prompts a subset of users to still require use of the legacy systems; to inadequate training on the new systems, resulting in users reverting to old habits when under stress; to insufficient direction and/or emphasis from management on the mandate to migrate from the old systems to the new.
The second failure point typically presents in the Management of Change (MOC) process. A proper MOC procedure will prompt the user to identify whether the considered change has any impact on the design of the pressure relief system, and if so, what changes may be required and how they may affect other aspects of the system design. This often appears as part of a checklist or form for the process, but the point of failure is the knowledge and experience of the person answering the questions. The impact of the change on the design of the pressure relief system is too often overlooked due to a lack of expertise. This is especially true in cases where there is no dedicated pressure relief systems engineer included in the discussion, but fortunately, most companies have realized the added value of their input at this point in the process. Since pressure relief systems are designed to be the last line of defense in safety and based on the worst-case assumptions, and the opportunity to "see" the full fruits of our labor in action is rare, the downside is often a gap in younger engineers' knowledge of how systems behave during an overpressure event in both theory and practice.
The third point, while not unique to PSI, can have a significant impact on the effectiveness of the overall evergreening program. The obstacle typically presents under the broad banner of "communication issues," but can also present as a repeated inability to learn from experience within the same group, whether due to inadequate knowledge transfer during team turnover, or insufficient time and resources spent training the team on the actual lesson. As a result, the knowledge must be paid for again and again until the lesson sets in.
The solutions may seem obvious: renewed focus, more training, implementing monitoring systems, stronger support from management, etc. The key takeaway here is the laws of conservation apply to evergreening as they do with everything else: You get out of it what you put into it. If we want to deliver on the promise of best-in-class PSI that is accurate, up-to-date and available to be delivered on demand, we must build, execute and monitor the process with our best knowledge, effort and experience.
For more information, visit www.smithburgess.com or call (713) 802-2647.
