“Don’t cross the streams.” -Egon from Ghostbusters
It doesn’t take much for two tasks to interfere with one another out in general industry. Work environments can be quite hectic as the end of a fiscal year approaches, where multiple goals and tasks are being wrapped up. Plant life is not much different, except some of the busiest times are tied to turnarounds of a process or slow periods of production. These times can lead to additional work being done around normal operations. Without proper communication, hazards can arise for those who are unexpectedly present in areas who are not used to being near the process.
Catch a Whiff
On one of my previous audits for a PSM-covered site, our team performed a routine facility walkthrough of a process. What was not routine was that the auditors were not made aware of a sampling operation that was occurring just as we were passing by the facility’s ammonia tanks. It was just our luck that the wind changed towards our direction, and while our site contact was able to escape unscathed, the rest of the team was unable to. The inhalation hazard was not significant to the point of causing any lingering injuries outside of weird tastes at lunch, so we were able to laugh about it after our site contact submitted a near-miss report. As safety-conscious people, we were aware of the potential hazards on site, and we were not even immune to a hazardous event. A mistake like this can occur within operations as well, parts of production of a single or multiple products could be taking place at the same time near each other.
Any Process.. Anytime
Both batch and continuous processes usually run with multiple steps or stages occurring at the same time. Batch process facilities can have areas where multiple batches are being made back-to-back or multiple products are being made. In comparison, continuous processes may be making only one product but can have different hazards present at different stages of production. In either case, plant life does not only subsist of production, as maintenance and quality control teams make rounds through the process and can be present for extended periods if there is any upset to their tasks. If there is going to be a disruption to production or a quality/maintenance task, communication between personnel performing the work and the operators who are normally present is essential. Operators will need to be made aware of those arriving on-site, potential additional hazards to the area, and whether or not they may need to vacate or supervise the area for the work to be performed. Those performing the supplemental work, however, may require information about how the area is performing at the moment, current hazardous conditions where work is planned to be done, and confirmation from those responsible for the area where work can proceed. If information is not delivered to either side, it can lead to a misrepresentation of field conditions with the work being done, resulting in ill-equipped individuals nearby for the potential hazards. No hazardous process is impervious to miscommunication if multiple personnel are present. While verbal communication can be sufficient in specific situations, there are potential procedural controls that can provide a confirmation and record to confirm these items are discussed.
Safe-Work Permits are A Start
The PSM standard, in addition to the Hot Work or Confined Space subsection of the OSHA standard for general industries, requires a system to be in place to permit specific work to be done around hazardous facilities (e.g. potential combustible/flammable hazards). These permits can take multiple forms, as long as certain fields are listed and completed when used. Many of the facilities we work with have an all-encompassing form that includes the necessary fields for hot work, confined space, and line entry called Safe-Work permits. The intention behind these forms is to confirm the review of potential hazards before work begins and confirm the proper precautions and safeguards are in place to ensure the safety of those performing the work. Once the permit has been issued the responsible party will confirm that the correct precautions are in place and that the permit is legible and posted outside the area so that others may know that hazardous work is being performed. This process is a necessary step not just to meet regulations, but to act as another form of communication alerting the site of unique hazards of the operation. But what about work that doesn’t require a safe work permit? Audits and other reviews may take personnel outside of their normal day jobs and into the field with little notice.
Situational Awareness At Its Finest
OSHA standards for various industries require training for process operations. Like the PSM standard, the training involves reviewing the hazards present on site and then following procedures and programs in place to prevent exposure or to provide a defined response in the event of an incident. The training can take place and be recorded in multiple forms. While some may find the shadowing approach with written approval of competency works well, other sites may not have the resources and prefer a briefing with a quiz afterward. In any case, this type of training is required for operators who normally operate in the hazardous environment, but not all employees may attend. When someone from the office area needs to run an errand to the production area, are they knowledgeable about the current state and hazards of the process? Some employers may take the escorted approach for those who are not normally in the facility. Even then the escort has to communicate to the area that those unfamiliar with the operations are entering the facility. The error was clear in this tank farm case, as there was a lack of communication between the employee who collected the sample and our team who would be in the tank farm at the same time.
Communication is Key
Even operators are not immune to the hazards of simultaneous operations. Unless the permit issuer for safe work is the same, it is very possible to have multiple work permits issued for the same area. Hot-work and line-entry may not always mix, for example, especially if unintended flammables or combustibles may cross over to each other’s area. Having an efficient administrative procedure where permits can be cross-referenced with active permits before being issued can cut down on potential double-jeopardy scenarios, even if they are rare. It doesn’t take much for a crew tackling one type of hazard to be exposed to another. If two or more different types of hazardous work must be done on a process simultaneously, the team must know and be prepared to handle both in conjunction with the others. Whether that means additional PPE or specialized equipment, it may serve to protect all those nearby from experiencing unintended exposure.
Photo credit: Malachi Brooks via Unsplash
Cross the Streams at Your Own Risk
PSM-awareness training, procedures to ensure escorting of visitor and non-field personnel, safe work programs that include referencing active permits, and proper signage or communication of non-operational personnel entering areas are some of many ways to tackle the simultaneous operations problem. Nothing can truly prepare for every situation, but known hazards compounding should be considered if the likelihood is deemed credible. This may be something to bring up during Management of Change reviews, Process Hazard Analysis, Layers Of Protection Analysis, or other hazard reviews as something to consider in the questions listed in the document. In any case, it’s better to leave crossing the streams to the movies.