Risk-Based Process Safety and API 754... Is this the best practice for process safety?

Risk-Based Process Safety is a holistic approach that establishes a fully functional process safety program. This is in contrast to OSHA's CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (OSHA PSM), which is a regulation where program sustainability is not addressed. For example, the following critical PSM program elements are not an express part of OSHA PSM:

• Process Safety Culture – Does top management create and manage a Process Safety Culture? If so, it will be seen in line employees (Operators, Maintenance Tech).
• Process Safety Competency – Are process safety duties part of job descriptions? Engineer training? Operator certification? Maintenance / Craft training? PHA team participants?
• Stakeholder Outreach – Have you initiated a dialogue with those potentially impacted by company operations?
• Conduct of Operations – Are operations and maintenance tasks done in a structured manner with minimal variability (consistency)?
• Measures & Metrics – Is Recommended Practice API-754 (identifies leading and lagging process safety indicators) used at your company?
• Management Review – Continuous Improvement – Are management systems functioning as intended? Do you know because they are routinely evaluated and not just after a PSM Compliance Audit?

API-754 was issued in 2010 and has since helped the process industries redefine what constitutes a process safety incident. When OSHA PSM was promulgated in the early 90s, little guidance existed regarding PSM incidents and both understanding and interpretation varied across industry. API-754 provides guidelines for the development of metrics that are not just lagging, but also predictive in nature. API-754 describes process safety events in terms of tiers per the following structure (abbreviated):

• Tier 1 Process Safety Event – unplanned or uncontrolled release of any material, resulting in the highest/most severe consequences.
• Tier 2 Process Safety Event – unplanned or uncontrolled release of any material; with less than Tier 1 consequences.
• Tier 3 Process Safety Event – demands on safety systems with no loss of containment (PSV discharge to flare – contained; safe operating limit excursions. Predictive of Tier 1 and Tier 2 events.
• Tier 4 Process Safety Event – self-styled to reflect site-specific performance.

In conclusion, Risk-Based Process Safety provides a framework to further identify the necessary components of a process safety program. It also provides further details on what is required, although there are few prescriptive guidelines. While it's still a performance-based methodology, Risk-Based Process Safety coupled with API-754 for program health monitoring is the best available guidance to implement process safety for the process industries.