Lessons from a Management of Change incident utilizing AcciMap to identify causes to address including: Management of change system, Utilitiy connections to process, regulatory oversight and training
Paired Comparison Analysis: A Practical Tool for Evaluating Options and Prior...
N cann haz aus 2013 mo c final
1. Lessons from a Management of Change
Incident
Nigel Cann, Arup
FIChemE, CEng, CEnv, RPEQ
Nigel.cann@arup.com
2. 2
What we will cover…
• Timing of incident
• Plant process
• Plant Layout
• Incident Event
• AcciMap of Incident
• Actions that followed
• What questions do you have?
Agenda
9. 9
AcciMap – Modification Control Incident
AcciMap of Modification Control Incident
Accident
Sequence
Governance /
Organisational
Regulatory
Outcomes
3500kg VCM LoC
via steam trapsVCM is in Utility
Steam System
Operator
missed
H2O/VCM
interface
Disperses in
atmosphere
or absorbed
in water
spray
Human and
Environmental
Factors Was Operator
present?
Liquid VCM in
Receiver
Reliance on NRV
Cold weather –
autumn night
1. Poor Mod Control
paper based system
Lower SEPP VCM
boundary limits
1. HAZOP boundary
not including
existing plant when
additional capacity
added
3. Poor Regulatory
Oversight
Back pressure in
Receiver
Orifice Plate
inserted when
additional
production stream
added
Equipment and Design
Steam used to
scrub Receiver
Water
Orifice Plate
blocked by ice
Block in VCM
vapour line to
Recovery
Water mostly
in other
Recovery
Tank
Operator observation of
difficult venting not addressed
4. Loss of
Plant learning
culture
2. Utilities connected
to Process
Organisation
focus on
Environmental
Improvements
10. 10 AcciMap of Modification Control Incident
Accident
Sequence
Governance /
Organisational
Regulatory
Outcomes
3500kg VCM LoC
via steam trapsVCM is in Utility
Steam System
Operator
missed
H2O/VCM
interface
Disperses in
atmosphere
or absorbed
in water
spray
Human and
Environmental
Factors Was Operator
present?
Liquid VCM in
Receiver
Reliance on NRV
Cold weather –
autumn night
1. Poor Mod Control
paper based system
Lower SEPP VCM
boundary limits
1. HAZOP boundary
not including
existing plant when
additional capacity
added
3. Poor Regulatory
Oversight
Back pressure in
Receiver
Orifice Plate
inserted when
additional
production stream
added
Equipment and Design
Steam used to
scrub Receiver
Water
Orifice Plate
blocked by ice
Block in VCM
vapour line to
Recovery
Water mostly
in other
Recovery
Tank
Operator observation of
difficult venting not addressed
4. Loss of
Plant learning
culture
2. Utilities connected
to Process
Organisation
focus on
Environmental
Improvements
11. 1. Modification Control System
• Development of Electronic system
• Checksheet and reviewer inputs requiring comments
• Authoriser provided details of comments, usually assigned
conditions
• Details of HAZOP and Review actions assigned and
followed up via Actions Review
• Notifications via email
• Pre-commissioning and Post commissioning checks.
• OH&S signoff
1. Poor Mod Control
paper based system
1. HAZOP boundary
not including
existing plant when
additional capacity
added
11 Modification Control System
12. 12 AcciMap of Modification Control Incident
Accident
Sequence
Governance /
Organisational
Regulatory
Outcomes
3500kg VCM LoC
via steam trapsVCM is in Utility
Steam System
Operator
missed
H2O/VCM
interface
Disperses in
atmosphere
or absorbed
in water
spray
Human and
Environmental
Factors Was Operator
present?
Liquid VCM in
Receiver
Reliance on NRV
Cold weather –
autumn night
1. Poor Mod Control
paper based system
Lower SEPP VCM
boundary limits
1. HAZOP boundary
not including
existing plant when
additional capacity
added
3. Poor Regulatory
Oversight
Back pressure in
Receiver
Orifice Plate
inserted when
additional
production stream
added
Equipment and Design
Steam used to
scrub Receiver
Water
Orifice Plate
blocked by ice
Block in VCM
vapour line to
Recovery
Water mostly
in other
Recovery
Tank
Operator observation of
difficult venting not addressed
4. Loss of
Plant learning
culture
2. Utilities connected
to Process
Organisation
focus on
Environmental
Improvements
13. 13
2. Remove Utilities from Process
• Utility steam and air not intended for connection to
process streams
• Generally lower pressure than process units can get
• Process streams need proper pressure and or flow
control – NRV’s fail
• (This was another indicator of loss of integrity
originally designed in).
2. Utilities connected
to Process
Utilities
14. 14 AcciMap of Modification Control Incident
Accident
Sequence
Governance /
Organisational
Regulatory
Outcomes
3500kg VCM LoC
via steam trapsVCM is in Utility
Steam System
Operator
missed
H2O/VCM
interface
Disperses in
atmosphere
or absorbed
in water
spray
Human and
Environmental
Factors Was Operator
present?
Liquid VCM in
Receiver
Reliance on NRV
Cold weather –
autumn night
1. Poor Mod Control
paper based system
Lower SEPP VCM
boundary limits
1. HAZOP boundary
not including
existing plant when
additional capacity
added
3. Poor Regulatory
Oversight
Back pressure in
Receiver
Orifice Plate
inserted when
additional
production stream
added
Equipment and Design
Steam used to
scrub Receiver
Water
Orifice Plate
blocked by ice
Block in VCM
vapour line to
Recovery
Water mostly
in other
Recovery
Tank
Operator observation of
difficult venting not addressed
4. Loss of
Plant learning
culture
2. Utilities connected
to Process
Organisation
focus on
Environmental
Improvements
15. 15
3. Exemplar Safety Case Program
• Recognition needed to do something different
• Would need to do it twice
• Capture corporate knowledge
• Wanted to be a leader
• It was an unknown quantity
• Opportunity to learn and share lessons
Exemplar Safety Case
3. Poor Regulatory
Oversight
16. 16
AcciMap – Modification Control Incident
AcciMap of Modification Control Incident
Accident
Sequence
Governance /
Organisational
Regulatory
Outcomes
3500kg VCM LoC
via steam trapsVCM is in Utility
Steam System
Operator
missed
H2O/VCM
interface
Disperses in
atmosphere
or absorbed
in water
spray
Human and
Environmental
Factors Was Operator
present?
Liquid VCM in
Receiver
Reliance on NRV
Cold weather –
autumn night
1. Poor Mod Control
paper based system
Lower SEPP VCM
boundary limits
1. HAZOP boundary
not including
existing plant when
additional capacity
added
3. Poor Regulatory
Oversight
Back pressure in
Receiver
Orifice Plate
inserted when
additional
production stream
added
Equipment and Design
Steam used to
scrub Receiver
Water
Orifice Plate
blocked by ice
Block in VCM
vapour line to
Recovery
Water mostly
in other
Recovery
Tank
Operator observation of
difficult venting not addressed
4. Loss of
Plant learning
culture
2. Utilities connected
to Process
Organisation
focus on
Environmental
Improvements
17. 17
4. Training and Development
• First Aid
• Emergency
• Chemical
Awareness
• Fire Fighting
• Working at Heights
• Permit to Work
• Critical Systems
Training
4. Loss of
Plant learning
culture
• OH&S Legislation
• Natural Gas, Boilers and
Water Quality
• Project Management
18. 18
Internal Audit - 2007
• 1 months MoCs 6 months previous
• Automated system functioning well and well accepted.
• Mods allocated appropriate process
• Mods allocated to correct personnel for review
• Implementers frustrated at time to close out:
• Procedures, drawings, training materials
• Less concerned at safety checks and hit sheets
• Changes to personnel were going through formal review
processes
• Small number of personnel had not completed training
Internal Audit
19. 19
Summary – Process Safety Control
Process Safety Fundamentals
Process
Safety
Control
Inherent Design Safety
12 May 1999
2nd Paper – 14:15 – Grand Ballroom Nth – Trish Kerin – Session starts 12:30 pm – 4th paper
Layout of plant benefitted from:
Designed early 70’s
Flixborough
Discovery of link between VCM and angiocarcinoma of liver
The late Trevor Kletz left his footprint