With respect to how it audits and assesses its process safety practices on the release of highly toxic materials, Chevron Phillips Chemical Co. (CPChem) is currently doing something different from what has been done historically.
"There's a lot of focus in our industry, and definitely within our company, on trying to reduce risk," noted Michelle Pritchard, process safety technology manager for Chevron Phillips Chemical. "Fortunately, we don't have nearly as many events these days, but as a result, people don't necessarily understand the particular consequences of what releases really can mean."
Regardless of severity, no toxic release incident is ever safe, Pritchard said, addressing industry safety leaders at the 30th Annual Texas/Louisiana Environmental, Health & Safety Seminar held recently in Galveston, Texas.
The number of people impacted in toxic release incidents can be huge, previously numbering in the thousands.
"There were fatalities and serious injuries," she said. "In some cases, hundreds of people from the site itself and from the community got medical treatment."
More than 10 percent of incidents reported involve toxic materials, Pritchard said.
"I think that's a clue that more work can be done in that area. Our senior leadership challenged the folks who are in official process safety leadership roles for the company to answer the question, 'Are we really certain that our programs are robust enough that we would not have a serious event as a result of a toxic release?'" Pritchard said.
In early 2015, Chevron Phillips leadership responded with the Toxic Inhalation Hazard (TIH) Assessment.
The TIH Assessment method requires managers to conduct pre-assessment activities, including scope and protocol development, documentation requests, assessment team training and site team training.
They must also develop and manage assessment outputs and report risk-prioritized recommendations. Once site action plans are developed, action plans must be tracked to closure and verified by corporate environmental, health and safety personnel.
A review team made up of highly experienced subject matter experts (SMEs) external to the facility are required to partner with facility personnel for assessment team training and site team training.
Finally, the on-site assessment consists of standard auditing and sampling techniques, utilizing transparency and active communication. The assessment must be highly interactive with front-line operations and maintenance employees.
Pritchard noted TIH Assessment results were far-reaching, prompting improved deluge designs, removal of small bore pipe, increased mutual-aid outreach and performance of additional hazard reviews, improvement of unloading controls to reduce human error potential, and the demolition of infrequently used truck unloading racks. Further, shift communications and emergency response drills were enhanced and revised, line-labeling egress from unloading location was improved, and unloading procedures were updated.
Pritchard observed TIH Assessment successes included the realization identified risks differed from those identified in traditional audits. Further, she said, process chemistry hazard knowledge increased both organizationally and individually, as did the visibility of normalized deviations. Value was added by corporate and facility personnel as well.
Significantly, senior leadership supports the continuance of TIH Assessments.
"If we really want to get to zero incidents and zero injuries, we really have to get to zero loss of containment," Pritchard concluded. "But I think even if we do get to zero, if we lose that sense of vulnerability, we won't stay there."
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