Author: Ken Koehler, P.E. Process Plus Senior Process Engineer
February 17, 2014

Industry has made strides in improving Process Safety over the last few decades, but the recent spill in Charleston, West Virginia and last year’s explosion in West, Texas help to illustrate that there is still a long way to go to ensure the health and welfare of workers and the surrounding populations.

As engineers and designers, it is our job to specify and design reliable and efficient processes, but it is also our duty to complete those designs with safety and the environment high on our list of priorities.

We cannot doze off at the beginning of a project when the impact of a critical safety item might be overlooked and cause expensive changes down the road. We should not snooze when the details of the safety items are being crafted into the final construction packages. It would not be prudent to catch 40 winks when pre-start up inspections would reveal improper installations or incorrect equipment deliveries.

With the issuance of Executive Order 13650, the President has lit a fire, ok, maybe not a fire, but at least a smoldering ember under OSHA and other regulatory agencies to improve the efficacy of Process Safety Management (PSM). OSHA has published a Request For Information (RFI) concerning 17 proposed modifications to the current PSM regulations. (OSHA RFI) If many of the proposed improvements had been in effect a few years ago, the plant in West, TX would most likely have been covered under PSM, and the storage tanks in Charleston may have been covered also. It shouldn’t take regulatory action for us to recognize the hazards in the processes we work on and design the safest solutions available.

Comments on the RFI are due to close on March 10, 2014, I’m hopeful that there are no other catastrophic incidents in the years it will likely take our government to craft revised regulations. In the meantime, let’s keep awake to the potential hazards in every process we work on whether they are covered by PSM or not.

In future blogs we plan to discuss the impact and reasoning behind some of the proposed changes; such as Improved Management of Organizational Change, Inclusion of Highly Reactive Chemicals in PSM, and Clarification of the Exemption for Atmospheric Storage Tanks.