A RISING TIDE RAISES ALL BOATS:

REGIONAL PROMOTION OF PROCESS SAFETY THROUGH

JOINT GOVERNMENT/INDUSTRY MANAGEMENT

Yewei Ni *, Fereshteh Sattari *, Lianne Lefsrud *, Modusser Tufail †

*
Department of Chemical and Materials Engineering, School of Engineering Safety and Risk
Management, University of Alberta, Edmonton, Alberta T6G 1H9, Canada

†
Fire Prevention and Investigation Division, Strathcona County Emergency Services, Sherwood
Park, Alberta T8H 1S9, Canada

Corresponding Author: (Lianne Lefsrud, lefsrud@ualberta.ca)

Abstract

With the development of increasingly complex processes and technologies in chemical and

manufacturing industries, Process Safety Management (PSM) has been globally recognized as the

primary tool for operating companies to reduce process accidents on their industrial sites and the

risks posed to their employees and surrounding communities. Yet, industrial facilities are often

interdependent and collocated with others. Recognizing this, regional authorities are also applying

PSM principles to reduce the cumulative incidents associated with high density industrial areas

and the multiplicative risks posed to broader communities. This paper compares Strathcona County

Emergency Service (SCES) in Alberta, Contra Costa Health Services Hazardous Materials

Programs (CCHSHMP) in California, and Technical Standards & Safety Authority (TSSA) in

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Ontario and their PSM systems to provide practical recommendations to improve SCES’s system.

Four aspects of PSM are considered: regulation and guidance, auditing and inspection, annual

performance indicators, and public participation. Based on the results of this comparison, we

recommend that SCES develop comprehensive PSM regulations based on CSA Z767-17 PSM

including clear instructions for assessing technologies and methodologies for consequence

analysis. Both worst-case scenarios and alternative scenarios need to be considered as well as the

domino effect of primary accidents. Furthermore, regular audits and inspections will ensure

compliance with PSM regulations while helping the design of planning, performing, and

following-up strategies to ensure effectiveness. In addition, we suggest the use of lagging and

leading performance indicators to evaluate the performance of the PSM program. Finally, we

recommend using advisory councils or commissions to increase public participation and ensure

the representation of stakeholders’ perspectives with the PSM system.

Keywords

Process safety management; Chemical and manufacturing industry; Process accidents; PSM

regulations; Leading and Lagging indicators

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1.0 Introduction

With the advancement of technology increasingly complicated process systems have been used in

industries which have helped the development of human society, but have also resulted in a series

of industrial disasters; the Flixborough explosion in 1974, the Seveso disaster in 1976, and the

Bhopal gas tragedy in 1984 are just some examples. PSM techniques have been developed to

prevent such major chemical and manufacturing industry accidents (Khan et al., 2016).

PSM is the application of management principles and systems for the identification, understanding,

avoidance, and control of process hazards to prevent, mitigate, prepare for, respond to, and recover

from process-related incidents (CSA Group, 2017). It has proven to be effective. Kwon (2006)

evaluated the efficacy of PSM implementation for the chemical industry in Korea. He found that

seven years after the implementation of PSM, there was a 62% reduction of fatalities, 58%

reduction of injuries and 82% reduction of near-miss accidents while quality and productivity

increased 96.3% and 98.2%, respectively.

With the ongoing occurrence of significant accidents, PSM regulations have been developed and

promulgated by many countries and industrial associations around the world. Some examples are

the Environmental Protection Agency’s (EPA’s) Risk Management Program and the Occupational

Health and Safety Administration’s (OHSA’s) PSM regulation from the United States, the Seveso

Directive which covers all member states of the European Union, the State Administration of Work

Safety (SAWS) PSM regulation from China, and the Industrial Safety and Health Act from Korea.

These regulations emphasis a comprehensive understanding of hazard identification, risk

assessment evaluation, and control (Halim & Mannan, 2018). Given this, regulations must keep

pace with the development of new chemicals and adapt through continuous learning from accidents.

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For example, the Seveso Directive was developed in 1982 in response to process safety accidents

in the early 1970s such as the ANIC petrochemical company explosion in Manfredonia and the

Dutch State Mines (DSM) ethylene plant explosion in Beek. This regulation only provided a list

of hazardous substances, but did not mention any penalties for noncompliance (Hollá, 2017). The

Seveso Directive was updated in 1996 and 2003 in response to additional process safety accidents.

As a result, a classification of hazardous substances, threshold quantities, and facilities’ maximum

levels have been created, and were followed by an update of new reporting guidelines and public

consultation requirements (Besserman & Mentzer, 2017). The Seveso III Directive was

promulgated in 2012 to update the classification of dangerous chemicals and improve the

information collection system, inspection procedures, and public information accessibility (Peeters

& Vanhoenacker, 2015). However, with the development of increasingly complex technologies

and processes, we must continuously learn from accidents, find loopholes, and update the PSM

regulations accordingly. Regulators later formalized the PSM system into fundamental pillars

(CSA Group, 2017). The Canadian Standards Association (CSA) has proposed four foundational

pillars with 16 elements as shown in Table 1.

Table 1. PSM foundational pillars with its elements (CSA Group, 2017)

Process safety Understanding Review and

Risk management
leadership hazards and risks improvement
Process knowledge and Training and
Accountability Investigation
documentation competency
Regulations, codes, Project review and Management of
Audits process
and standards design procedures change (MOC)
Process risk assessment Process and Enhancement of process
Process safety culture
and risk reduction equipment integrity safety knowledge
Conduct of
Emergency
operations - senior key performance
Human factors management
management indicators
planning
responsibility

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The Energy Institute proposed the same four foundational pillars but with 20 elements as shown

in Figure 1 (Energy Institute, 2016). PSM foundational pillars and elements may vary in countries

and industrial associations, but the framework is similar across jurisdictions.

Figure 1. PSM foundational pillars developed by Energy Institute (Energy Institute, 2016)

Risk identification and assessment (Understanding hazards and risks in Table 1, Pillar 2 in Figure

1) is a critical element in a PSM system as a result of the increasing complexity of plants and

processes, the density of assets, and the proximity of exposed populations (Pasman et al., 2009).

There are many risk analysis techniques: checklists, what-if analysis, HAZOPs, fault tree analysis

(FTA), and failure mode effect analysis (FMEA) (Khan and Abbasi, 1998). They also elaborated

a set of methodologies to improve the effectiveness: hazard identification, screening, and ranking,

modelling consequences, and inherently safer design. These techniques and methodologies are still

recommended by PSM regulators for process hazards analysis. Risk analysis also helps with land-

use planning, and some countries apply these methods for licensing purposes as well (Pasman et

al., 2009).

By studying severe accidents, we have learned of the potential for ‘domino effects’ which refers

to knock-on accidents or secondary accidents where one process unit jeopardizes another process

unit (Abdolhamidzadeh et al., 2011). The most recent ExxonMobil Torrance Refinery explosion

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in 2015 is one example. The accident started with the leak of hydrocarbon, which later mixed with

air and then ignited at the Electro-Static Precipitator (ESP) resulting in a massive explosion at the

refinery. The explosion debris hit equipment near the ESP and caused another two small fires and

multiple leaks of flammable liquids, as well as a potential hazard of vaporization of hydrofluoric

acid (U.S. Chemical Safety and Hazard Investigation Board, 2017). Abdolhamidzadeh et al. (2011)

summarized over 224 major process-industry accidents involving secondary accidents. According

to their findings, a higher number of events proceed beyond the second accident comparing with

the ones which end at the second accident. This potential of domino effects must be recognized

and controlled. The primary accident scenario for a process can be forecasted and controlled by

using various technologies and methodologies as mentioned previously. However, the secondary

accident is more complex and unpredictable, and has the potential to cause more severe damage

and fatalities. It is hypothesized that a fire within the West Fertilizer Company created heat and

soot, which increased the explosivity of the ammonium nitrate stockpile. First responders were

unaware of what materials were being stored onsite and, thus, did not wear self-contained

breathing apparatus, use unmanned fire nozzles, or withdraw when the fire increased (Willey,

2017). While the initial fire killed no one, the resulting ammonium nitrate explosion killed 12 first

responders and 3 nearby residents (Laboureur et al., 2016). A quantitative assessment of escalation

hazard is key to understanding the possibly critical domino scenarios within and between complex

industrial sites (Antonioni et al., 2009).

PSM regulations have always included the requirements of compliance audits. The EPA’s Risk

Management Program and OSHA’s PSM regulations promulgate requirements for triennial

compliance audits (Birkmire et al., 2007) using to various PSM auditing models. Fernández-Muñiz

et al. (2007) developed a measurement scale for PSM based on the questionnaire results of 455

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Spanish companies. Based on the results of their questionnaires, government inspection has

focused on Implementation & Operation and Policy & Planning of organizations. These two

attributes consist of second-level attributes that are similar to the PSM elements. Chang and Liang

(2009) developed a model based on a three-level multi-attribute value model (MAVT) approach.

Using this model, safety auditors can evaluate the performance of the PSM systems for

manufacturing facilities to provide a Safety Index (SI). The calculations for this safety index

account for Policy & Planning, Implementation & Operation, Checking & Corrective Action, and

Management Review.

An effective compliance audit is essential for identifying program weaknesses, promoting

continuous improvement, ensuring process safety, and protecting personnel and the surrounding

environment. Birkmire et al. (2007) suggest an audit process involving three main steps of

planning, performance, and follow-up. The planning phase includes organizing the audit team,

providing the audit protocol, and establishing the audit schedules. Adequate planning will improve

the efficiency of the audit by having a shorter audit period and a more comprehensive review. The

goal of the audit team’s performance is to evaluate the compliance of representative samples of

the implemented PSM program against the PSM regulation. Conducting meetings, employee and

contractor interviews, documentation spot checks, field spot checks, and close-out meetings are

elements of an effective audit. Follow-up is the last step to ensure that the findings of the audit

have been analyzed, and that the appropriate improvements have been implemented. This process

consists of fact-checking, report finalization, and resolution of findings.

PSM is an integral part of preventing accidents and releases of hazardous materials while

maintaining the safety of facilities and the public. Although Canada has suffered relatively few

catastrophic chemical and manufacturing accidents such as the Flixborough explosion (1974), the

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Seveso disaster (1976) and Bhopal gas tragedy (1984), it is still essential that PSM is properly

implemented. In 2008, Sunrise Propane Industrial Gases propane facility experienced an enormous

blast which caused the death of two people, closure of part of Highway 401, and the evacuation of

thousands of people from their homes. The cause of the accident was identified as a propane leak

that resulted from a hose failure during a “tank to tank” transfer – a prohibited practice in Ontario

(Pontikas, 2010). Operational issues were identified on multiple occasions during inspections of

Sunrise Propane before the accident and appropriated enforcements were claimed to be given;

however, the incident still happened. This illustrates the loopholes in the company’s PSM system.

Figure 2 shows that most incidents involving dangerous good have occurred within facility

boundaries and almost two-thirds were in Alberta. This is likely related to the oil and gas industry

activities (Statistics Canada, 2017).Further analysis of the control of major accident hazards for

the Canadian Chemical Producers Association (CCPA) concluded that Canada has behind in

reducing major accidents as compared to other nations’ PSM policies (O’Neill et al., 2009). Further,

there is neither a body that audits, verifies, and generally conducts inspections for Canadian

chemical and manufacturing industries nor anyfederal or provincial PSM regulatory codes or

legislation (O’Neill et al., 2009). A voluntary management system that covers some of the PSM

elements is suggested, but not as a mandatory requirement.

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Figure 2. Dangerous good reportable incidents by type in Canada (Statistics Canada, 2017)
Strathcona County Emergency Service (SCES) — near Edmonton Alberta — has led PSM

implementation through its land-use bylaws that require quantitative risk assessment, risk controls,

and maintenance of a 3 km buffer zone to allow emergency response. There is a large amount of

heavy industry and hazardous materials located inside the county. To increase process safety and

prevent toxic releases and fires/explosions from affecting the public and the environment, SCES

has developed a PSM related program called the Industrial Engagement Program. This program

has the following objectives:

Phase 1 (completed): the objectives are to document release incidents in the county, complete a

Community Emergency Response Plan which is called Industrial Response Worksheet (IRW), and

finish fire inspections.

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Phase 2 (in progress): this phase focuses on PSM education and implementation for small to

medium size businesses. The fire department has been involved in helping to attract more

industries and providing a platform to have PSM communication.

Phase 3 (to be determined): the detailed objective has not been determined, but its focus is on

PSM auditing.

Combining the key components of the PSM system mentioned earlier in the section as well as

recommendations for CCPA, twofold objectives are developed for this paper. First, we compare

SCES with other mature, local PSM organizations on their methods of regulation and guidance,

auditing and inspection, annual performance indicators, and public participation. Second, we

provide recommendations to improve the performance of the existing Industrial Engagement

Program of SCES.

2.0 Methodology

Two regional authorities are selected as comparators for this study: Contra Costa Health Services

Hazardous Materials Programs (CCHSHMP) in California and the Technical Standards & Safety

Authority (TSSA) in Ontario. CCHSHMP is the regional authority that enforces PSM regulations

from OSHA, EPA, and local ordinance. It serves as the local Certified Unified Program Agency

(CUPA), protects human health and the environment by promoting pollution prevention, increases

process safety knowledge and environmental awareness, responds to incidents, and implements

consistent regulatory compliance and enforcement programs (CCHSHMP About Us, 2020). TSSA

is a not-for-profit and self-funded authority that promotes and enforces public safety on behalf of

the Government of Ontario’s fire marshal. TSSA provides training, certification, licensing,

registration, audits, quality assurance, inspection, investigation, and enforcement.

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PSM system data for CCHHSHMP and TSSA are collected from the websites, presentations and

annual reports of these authorities, and documentary data that contains relevant PSM system data

are collected from trusted academic databases such as Science Direct, Wiley Online Library, and

Google Scholar. Interviews are also conducted with experts and academics to understand the

current status of local PSM and develop the comparative framework.

3.0 Existing PSM in SCES, CCHSHMP and TSSA

The current PSM system information for SCES, CCHSHMP, and TSSA are collected and

compared by focusing on regulation and guidance, auditing and inspection, annual performance

indicators, and public participation. Since SCES does not have a complete PSM system, some of

these sections are omitted for SCES.

3.1 Regulation and Guidance

Regulation and guidance are the essential elements for a PSM system. In this section, information

regarding regulation and guidance associated with hazardous material lists and PSM elements used

by these three local PSM authorities, their hazard assessment methodologies, and their risk

tolerance are summarized.

3.1.1 SCES’s PSM regulation

Requirements for Heavy Industrial Developments is the PSM related document that has been used

by SCES. This document is designed for the industrial businesses that deal with hazardous

substances near or more than the threshold quantities defined in the hazardous materials list of

Environment Canada. Environment Canada developed the hazardous materials list with 234

substances and 15 solutions. Table 2 shows the requirements for development projects in

Strathcona County.

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Table 2. Requirements for heavy industrial development project (SCES, 2019)
Stage Documents
Development Risk Assessment
Fire Protection Plans
Fire protection Design Basis
Construction Construction Site Fire Safety Plan
Pre-Occupancy / Start-up Pre-Fire Plan
Fire Safety Plan
Pre-Start-up Safety Review (PSSR)
Bow Tie Analysis
Emergency Response Plan
Industrial Response Worksheet
Spill, Impairments and Notifications
Emergency Preparedness Exercise
Occupancy Risk Management Programs

In this document, SCES recommends that local heavy industries follow the guidance of CSA Z767-

17 Process Safety Management and other PSM publications to manage process safety for as part

of their organizational risk management program. The PSM elements are those shown previously

in Table 1. No specific instruction regarding risk management, such as consequence analysis

techniques and performance calculation methodologies including assumptions and parameters, is

mentioned and no penalty associated with noncompliance is mentioned in this document.

3.1.2 CCHSHMP’s PSM regulation

Among the many different programs developed by CCHSHMP, the California Accidental Release

Prevention (CalARP) program and Industrial Safety Ordinance (ISO) focus on the process safety

of chemical and manufacturing industries. The CalARP program is a state program that replaced

the United States EPA’s Risk Management Program in 1997. It is similar to the Risk Management

Program, but includes a more extensive toxic chemicals list, smaller threshold quantities, and an

external events analysis. The CalARP program uses a hazardous materials list containing 276

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substances while EPA’s Risk Management Program’s hazardous materials list only contains 77

toxic chemicals and 63 flammable substances. ISO was established and adopted in 2002 by Contra

Costa County. It uses the same hazardous materials list of CalARP, but expands the requirements

for some specific petroleum refinery and chemical plants (CCHSHMP, 2020f, 2020d).

Under CalARP regulation, CCHSHMP separates industrial processes into three levels (Program 1,

Program 2 and Program 3) based on their complexity, accident history, and potential offsite

consequence. In 2017, CCHSHMP added an additional Program 4 for refineries as a result of the

fire and chemical release at the Chevron Richmond oil refinery in 2012 (CCHSHMP, 2020b). The

PSM elements for each are different and increase with the complexity of the program. CalARP

Program 1 only requires a Hazard Assessment and an Emergency Response Program from the

facilities to verify the implementation of PSM. However, CalARP Program 2 contains more PSM

elements as in the following:

1. Hazard Assessment including: Worst-Case Scenario(s), Alternative Release Scenarios

(more likely to occur), and Five-Year Accident History.
2. Prevention Program covering: Process Safety Information, Process Hazard Analysis,
Operating Procedures, Training, Maintenance, Incident Investigations, Compliance
Audits, and Management System.
3. Emergency response program

Many petroleum refineries and chemical manufacturing plants are under CalARP Program 3,

which requires additional documents from the facilities to verify the implementation of PSM

regarding to prevention program. These additional requirements are: Mechanical Integrity,

Management of Change, Pre-Startup Reviews, Employee Participation, Hot Work Permits, and

Contractors (CCHSHMP, 1998).

Program 4 expands the requirements of Program 3 to strengthen the existing CalARP regulation.

Facilities complying with Program 4 include: Chevron Richmond Refinery, the Marathon

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Petroleum Corporation, the Philips 66 Rodeo Refinery, and the Shell Oil Products U.S. Martinez

Refinery These facilities must provide the most recent Hierarchy of Hazard Control Analysis,

Process Safety Culture Assessment, evaluation of the Accidental Release Prevention Management

policies and procedures, evaluation of the Human Factors Program, Safeguard Protection Analysis,

and the date of completion of the most recent Damage Mechanism Review or update to

CCHSHMP (Rahmah, 2017).

Contra Costa County establishes ISO for chemical facilities and petroleum refineries that have at

least one CalARP Program 3 process and are within an unincorporated area of the county

(CCHSHMP, 2020d). Six facilities are under the regulation of this ordinance. ISO adds more

prevention elements including: Safety Program Management, Line and Equipment Opening,

Lockout/Tagout, and Confined Space Entry. The last three elements were added to ensure safe

work practices regarding maintenance (CCHSHMP, 2014).

Since most petroleum and chemical industries are under CalARP Program 3, PSM regulation of

Program 3 is selected as the representative of the CCHSHMP PSM system and is used for this

comparative study.

3.1.3 TSSA’s PSM regulation

Based on the Technical Standards & Safety Act (TSS Act), TSSA focuses on the following three

key sectors (About TSSA, 2020):

1. Boilers and Pressure Vessels and Operating Engineers

2. Elevating Devices, Amusement Devices, and Ski Lifts
3. Fuels
PSM is enhanced under the fuels sector by regulating the transportation, storage, handling

according to the TSS Act. It also recommends CSA Z767-17 as a reference, so the PSM elements

14
are the same as shown in Table 1. Propane facilities are divided into two levels. Level 1 is for a

facility with a total propane storage capacity of 5000 USWG (US water gallons) or less, or a facility

with a fixed propane storage capacity of exactly 5000 USWG of portable propane storage capacity

on-site (TSSA, 2017b). Level 2 is for other propane facilities which do not satisfy the requirements

for Level 1 propane storage capacity. When developing a risk management program, Level 1

facilities are required to fill a Risk and Safety Management Plan provided by TSSA. It asks for

general facility information and an Emergency and Preparedness Response Plan including contacts

for emergency response, additional safety measures, the record of emergency training provided,

emergency training plan for the coming year, emergency response communication plan, building

and site security and procedures, water supply, and license holder of local Fire Services Reviews

site (TSSA, 2017b). For Level 2 propane facilities, the following Facility Safety documentations

is required (TSSA, 2010a):

 Hazard Analysis
 Hazard Distance (HD) Calculation for Worst Case Release Scenario
 Probabilistic risk assessment
 Risk Mitigation and Control plan
 Emergency response and preparedness

3.1.4 Hazard Assessments of SCES, CCHSHMP and TSSA

Based on the Emergency Services Requirements for Heavy Industrial Developments, SCES

requires companies to consider worst credible scenarios for release of toxic chemicals, explosion

or fire and the effects on people and the environment (SCES, 2019). A worst credible scenario is

the event scenario that has the highest consequences and can be used to compare with the facility

risk threshold (CSA Group, 2017). In the requirements for heavy industrial facilities, the hazard

assessment methods, models, parameters and assumptions are not specified.

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CalARP regulation requires offsite consequence analysis which includes worst-case scenarios and

alternative scenarios for regulated substances (toxic gases, toxic liquids, and flammable substances)

depending on the program level of the process. Although the CalARP program replaces EPA’s

Risk Management Program, EPA’s guidance for offsite consequence analysis is still recommended

to be followed. Worst-case scenarios are those of the largest quantity of a regulated substance

releasing from a single vessel or process line failure which results in the greatest distance to an

endpoint. Alternative scenarios are the scenarios that are more likely to occur than the worst-case

scenarios (U.S. EPA, 2009). Seven types of parameters that could be used in this consequence

analysis model are listed in the regulation as shown in Table 3.

Table 3. Parameters for EPA consequence analysis model (U.S. EPA, 2009)

Worst-Case Scenario Alternative Scenario

Endpoint
For flammable substances, endpoint is:
- Overpressure of 1 psi for vapor cloud
explosions, or
Endpoint is overpressure of 1 pound per square - Radiant heat level of 5 kilowatts per square
inch (psi) for vapor cloud explosion for meter for 40 seconds for heat from fires (or
flammable substances equivalent dose), or
- Lower flammability limit (LFL) as specified
in NFPA documents or other generally
recognized sources
Wind speed/stability
Assume 1.5 meters per second and F stability Assume 3.0 meters per second and D stability
Ambient temperature/humidity
Assume 25 degree Celsius and 50 percent Assume 25 degree Celsius and 50 percent
humidity humidity
Height of release
For toxic substances, a ground-level release is
Assume a ground-level release for this guidance
assumed
Surface roughness
Urban (obstructed terrain) or rural (flat terrain) Urban (obstructed terrain) or rural (flat terrain)
topography topography
Dense or neutrally buoyant gases
Dispersion tables or models must appropriately Dispersion tables or models must appropriately
account for gas density account for gas density

16
 Temperature of released substance
Consider liquids (other than gases liquefied by
refrigeration) to be released at the highest
temperature between daily maximum Consider substances to be released at a process
temperature (from data for the previous three or ambient temperature that is appropriate for
years) and process temperature. Assume gases the scenario
liquefied by refrigeration at atmospheric
pressure to be released at their boiling point
For toxic gas and liquid, a procedure is recommended as in the following for both worst-case

scenarios and alternative scenarios:

1. Define Worst Case/Alternative Scenario

2. Select Scenario
3. Calculate Release rate
4. Find toxic Endpoint
5. Determine Reference Table and Distance

The reference tables for the distance to endpoint are developed after taking into consideration the

type of gas/liquid, release time, and urban/rural condition based on the Gaussian model and the

SLAB model. A specific distance to endpoint can be found by using the release rate divided by the

endpoint.

For flammable substances, procedures for worst-case scenarios and alternative scenarios are

recommended as follows:

Worst-case scenario

6. Define worst case

7. Select scenario
8. Determine distance to overpressure endpoint
The distance to the endpoint of a vapor cloud explosion of regulated substances is calculated based

on a TNT-equivalent model with a yield factor of 10 percent.

𝐻𝐶𝑓 1/3
𝐷 = 17 × (0.1 × 𝑊𝑓 × 𝐻𝐶 ) Equation (1)
𝑇𝑁𝑇

17
Where D is the distance to an overpressure of 1 psi, 𝑊𝑓 is the weight of flammable substance, 𝐻𝐶𝑓

is the heat of combustion of flammable substance and 𝐻𝐶𝑇𝑁𝑇 is the heat of explosion of

trinitrotoluene (TNT). The factor 17 is a constant for damages associated with 1.0 psi

overpressures and 0.1 is the assumption of 10 percent participation of the flammable vapor.

Alternative scenario

1. Define alternative scenario

2. Select scenario
3. For vapor cloud fires
- Calculate release rates
- Find Lower Flammability Limit (LFL)
- Dense or neutrally buoyant
- Urban or rural
- Release duration
- Determine distance
4. For pool fires
For liquid pools of substances with boiling points above ambient temperature:

0.0010 𝐴
( )
𝑥 = 𝐻𝑐 √0.4
𝐻𝑣 +𝐶𝑝 (𝑇𝑏−𝑇𝑎 )
Equation (2)
4𝜋𝑞

or

0.0001 𝐴
𝑥 = 𝐻𝑐 √5000𝜋 (𝐻 Equation (3)
𝑣 +𝐶𝑝 (𝑇𝑏 −𝑇𝑎 ))

Where x is the distance from point source to receptor, q is the radiation per unit area received by

the receptor, 𝐻𝑐 is heat of combustion, 𝐻𝑣 is heat of vaporization, 𝐴 is pool area, 𝐶𝑝 is liquid heat

capacity, 𝑇𝑏 is boiling temperature, and 𝑇𝑎 is ambient temperature.

18
For liquid pools of substances with boiling points below ambient temperature:

0.0001 𝐴
𝑥 = 𝐻𝑐 √5000𝜋 𝐻 Equation (4)
𝑣

Where x is the distance from point source to receptor, 𝐻𝑐 is heat of combustion, 𝐻𝑣 is heat of

vaporization, and 𝐴 is pool area

5. For BLEVEs

2.2𝜏𝑎 𝑅𝐻𝑐 𝑚𝑓 0.67

𝐿=√ 3420000 3/4 Equation (5)
4𝜋[ ]
𝑡

Where L is the distance from fireball center to receptor, 𝑚𝑓 is mass of fuel in the fireball, 𝜏𝑎 is

atmospheric transmissivity, 𝐻𝑐 is the hear of combustion, R is radiative fraction of heat of

combustion, and t is duration of the fireball.

6. For vapor cloud explosions

The method of analyzing the worst-case scenario is recommended to be used for the scenario of

vapor cloud explosions. A smaller total quantity of a flammable substance is assumed in the cloud

comparing to the worst-case scenario (U.S. EPA, 2009).

TSSA only mentions the consequence analysis with propane in the fuel sector. They use the same

vapour cloud explosion equation with CCHSHMP as shown in Equation (1) with the same

assumptions of a constant 17 for damages associated with 1.0 psi overpressures and 0.1for 10

percent participation of the flammable vapor (TSSA, 2010a).

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3.1.5 Risk Tolerance and land-use planning

Figure 3 presents the risk acceptability criteria for SCES land-use planning. This acceptable level

was modified from MIACC guideline and adopted by Canadian Society for Chemical Engineering

(CSChE) PSM Division in 2007 (Alp, 2007). The acceptable level is measured as the annual

probability of fatality to an individual located at a certain distance from the risk source. A land

buffer, which separates residents from the risk source, is established by SCES by combining this

acceptable level with the modeled consequences for different types of incidents, for all industrial

activities (McCutcheon, 2017). SCES sets a fixed separation distance of 1.5 kilometers for the first

buffer where they do not allow any commercial constructions and another 1.5 kilometers for the

second buffer beyond which residential development can occur.

Figure 3. Risk acceptability criteria for land-use planning (Alp, 2007)

In Contra Costa County, there is a General Plan which includes information regarding land use

planning. Maximum site coverage, maximum building height, maximum floor area ratio and

20
average employees per gross acre are mentioned for different designations (Contra Costa County,

2005). Table 4 shows the requirements for light industry and heavy industry. Associated with this

General Plan, CCHSHMP uses a hazard score formula as shown in Equation (6) to evaluate a

development project regarding hazardous material and hazardous waste management. The hazard

score formula considers transportation risks, community risks including distance to various

receptor types, project risks concerning the total amount of the hazardous material and hazardous

waste and percent change of a hazard category, and hazard category of hazardous material or waste.

A point is assigned to each scenario for every category. A hazard score calculation is required for

every hazardous material or hazardous waste that is present at the facility / project. The higher

score is used when evaluating the project if more than one hazardous material or hazardous waste

(Contra Costa County, 2011).

[(𝑇 + 𝐶 + 𝑃) × 𝐻] + 𝐷 + 𝐴 Equation (6)

Where T is the point assignment for “Transportation Risk”, D is the point assignment for

“Community Risk – Distance from Receptor”, C is the point assignment for “Community Risk –

Type of Receptor”, A is the point assignment for “Facility Risk – Size of Project – Total Amount”

, P is the point assignment for “Facility Risk – Size of Project – Percent Change”, and H is the

point assignment for “Hazard Category of Material or Waste”.

Table 4. Land use requirement for light industry and heavy industry in Contra Costa County

Designations Light Industry Heavy Industry

Maximum site coverage 50 percent 30 percent
Maximum building
height 50 feet
Maximum floor area
ratio 0.67 0.67
Average employees per
gross acre 60 employees 45 employees

21
Conversely, TSSA determines risk tolerance according to a risk matrix, as shown in Figure 4. A

criterion of 1.00 fatality or equivalents per million people per year (FE/mpy) is used for evaluating

risk to the general population, and a criterion of 0.30 FE/mpy is used for evaluating risk to sensitive

sub-populations. Sensitive sub-populations are persons who are less able to respond to an

occurrence such as persons in schools, retirement homes, and long-term care homes and are more

vulnerable than the general population. As for the types of risk, TSSA classifies risks into three

categories based upon its risk matrix: actionable, enhanced monitoring, and core activities. Any

risk that exceeds the risk tolerance is considered as an actionable risk, which needs immediate

mitigation. When a risk approaches the risk tolerance level (without exceeding it), TSSA classifies

this risk as a risk requiring enhanced monitoring. The identified risks in this region have the

potential to become actionable risks and are required to be monitored continuously with the

application of mitigation strategies when needed. Finally, those risks that are much under the

acceptable risk level are identified in the region of core activities. These risks do not require an

immediate response, and TSSA continues routine monitoring (TSSA, 2019).

Figure 4. TSSA’s risk sources (TSSA, 2019)

22
3.2 Auditing and Inspection

It is very important to have an audit or inspection system to ensure the compliance of the PSM

program relative to the authority’s regulatory requirements. SCES does not have auditing and

inspection authority themselves. In Strathcona County, these inspections are conducted under

provincial legislation — Safety Codes Act — and associated regulations, by officers of various

disciplines, including (a) buildings, (b) electrical systems, (c) elevating devices, (d) gas systems,

(e) plumbing systems, (f) pressure equipment, and (g) private sewage disposal systems. Given this

delegation of authority, in this section we focus on the auditing and inspection programs, goals,

procedures and frequency for CCHSHMP and TSSA.

3.2.1 CCHSHMP

CCHSHMP performs both audits and inspection. An audit is periodically performed on the

facilities’ Risk Management Plan (RMP) to review the adequacy. The frequency of the audit is not

defined in the guideline of the PSM program, but is defined by the following criteria related to the

facility (Cal EMA, 2005):

 Accident history
 Accident history of other facilities in the same industry
 Quantity of chemicals present
 Location of the facility with respect to public and environmental receptors
 Presence of specific chemicals
 Hazards identified in the RMP; and
 Random selection

Audit notification is given to the facility 12 months in advance. During the RMP audit, an inspector

from CCHSHMP has access to all accident-related locations of the facility and supporting

documentation (Cal EMA, 2005). The inspector follows the following procedure:

23
 1. Pre-audit coordination meeting: this meeting will be held at the facility to review the
supporting documentation related to RMP and takes photographs to document the safety
practices and accidental release mitigation systems on-site.
2. Pre-planning facility tours: these tours involve fire department personnel who are likely
to respond to any chemical emergency.
3. Preliminary determination: this step includes revision of the RMP and develops a
timetable for implementation.

A compliance audit is a self-audit that is performed by facilities themselves to evaluate their

compliance with the requirements of the assigned program. This self-audit is required to be

performed at least once every three years by a person who is knowledgeable in the process. The

two most recent reports are required to be kept as documentation in the facility (Cal EMA, 2005).

The purpose of inspection is to check on the accuracy of the RMP data and the implementation of

all CalARP Program elements. Inspection is usually a site visit and can lead to penalties or other

enforcement action if violations are documented. The frequency of inspection is determined by

CCHSHMP and considers the result of the RMP audit; however, facilities must be inspected at

least once every three years (Cal EMA, 2005). If violations are found during an inspection,

enforcement action is taken depending on the severity of the violation. Figure 5 shows the general

enforcement procedures and Table 5 shows different types of enforcement tools. Sanctions such

as fines, penalties, and other tangible obligations are considered as formal enforcement; and letters,

notices of violations, and verbal warnings or notices are considered as informal enforcement. A

responsible party with minor violations is usually given up to 30 days to comply and is re-inspected

to ensure the compliance. All other non-minor violations would initiate a formal enforcement and

may constitute an additional violation if compliance is not achieved in the required timeframe

(Adams & Sawyer, 2008).

24
Figure 5. General enforcement procedures (Adams & Sawyer, 2008)

25
Table 5. Enforcement tools for noncompliance

Informal Formal
1. Notice of Violation 1. Notice of Significant Violations
(Also classified as a class I violation)
2. Summary of
2. Permit Revocation
Violations
3. Notice to Comply 3. Facility Closure
4. Office Meeting 4. Business License Revocation
5. Administrative Enforcement Orders
6. Quarantine Hazardous Waste
Generators/Tiered Permitting Facilities
7. Referral to State Agency
8. Referral to U.S. EPA
9. Civil Case
9. Criminal Case
3.2.2 TSSA

Mandatory inspections (which are called compliance audits) are conducted by TSSA to ensure the

compliance of work and practices of all registered contractors with the TSS Act, and periodic

inspections are conducted for all devices and facilities under TSS Act as well. The frequency of

inspection is prescribed in the regulation or set by the statutory Director who is responsible for the

specific regulations by using the Director’s powers for some devices and facilities. For devices

and facilities without a prescribed inspection interval, patented Risk-Based Scheduling (RBS) is

used to determine the inspection frequency. Contractors are required to demonstrate their

compliance by their processes, procedures and records. The procedure of a compliance audit

includes (TSSA, 2020c, 2020b):

1. Appointment is made between contractor and inspector before a site visit.

2. Ontario registration of the contractor is verified by inspector.
3. Inspector reviews the nature of work for all employees and sub-contractors and the
photocopies of their certificates or registration.
4. Inspector performs a visual inspection on a randomly selected vehicle which used for
either installation or service work, as well as the associated equipment.

26
3.3 Annual Performance Indicators

Performance indicators are used evaluate the efficacy of a PSM program. Only the CCHSHMP

Industrial Safety Ordinance (ISO) performance indicators are discussed in this section as this is

the only performance information available from CCHSHMP. ISO is a local PSM program that

covers three oil refineries and three chemical facilities. The performance of this program is defined

by the number of Major Chemical Accidents or Releases (MCARs). The severity of accidents or

releases is categorized into three levels: Severity Level I, Severity Level II and Severity Level III.

Each severity level is assigned to a weighted score of 1 point, 3 points, and 9 points, respectively.

Figure 6 (a, b) shows an example of using MCARs and the weighted score for ISO performance

evaluations. The total number of MCARs and the associated severity levels are reported from 1999

until 2019. The decreasing number of MCARs and severity level of the accidents or releases

indicate that the application of ISO has improved the overall safety. Also, Figure 6 (b) presents

MCARs with the weighted score reported from 1999 to 2019 to show the trend of the severity level

of overall accidents or releases. Moreover, ISO also requires the attachment of the process safety

performance report of each facility at the end of the annual report which includes overdue

inspections, past due PHAs, and past due investigation recommended actions (CCHSHMP, 2020e).

27
 a. MCARs from 1999 to 2019 b. MCARs with weighted score from
1999 to 2019

Figure 6. Annual performance of ISO, 2019 (CCHSHMP, 2020e)

TSSA determines public safety and risk based on two main criteria: Injury Burden and the Risk of

Injury or Fatality (RIF). While Injury Burden summarizes past incidents in terms of FE/myp, the

RIF predicts the future in terms of FE/myp by using past data and taking into consideration the

uncertainties and variability inherent in the involved parameters. Figure 7 shows the status of

public safety in Ontario in 2019. Since there are more facilities under TSS Act compared to ISO, it

is impossible to report the safety performance of every facility. Inspection risk spectrum and

inventory risk profile are also used when evaluating TSSA’s annual performance. The inspection

risk spectrum shows the potential safety risks associated with non-compliances found during the

inspection, and inventory risk profile indicates the level of compliance with the TSS Act (TSSA,

2019).

28
Figure 7. State of public safety in Ontario in 2019 (TSSA, 2019)

3.4 Public Participation

Public participation plays a critical role when designing and implementing a PSM program. SCES

does not have a related program considering public participation due to the relative recency of its

PSM program. For Contra Costa County, a hazardous materials commission was set up in 1983 to

provide and promote a common understanding of environmental issues related to hazardous

materials and hazardous waste. Recommendations regarding policies, storage, use, and

management of hazardous materials and hazardous waste are also provided by the commission

(CCHSHMP, 2020c). The commission consists of members from various parties to gather opinions

from different perspectives, such as local businesses, the city, environmental engineers,

environmental organizations, etc. Also, CCHSHMP provides public outreach information booths,

presentations, and public meetings to interested groups to increase public participation, in addition

to offering audit reports to the public online (CCHSHMP, 2020e).

29
TSSA works with industry experts through advisory councils to collect information and make more

informed decisions regarding public safety (TSSA, 2017a). There are two types of councils:

Industry Advisory Councils and Consumer Advisory Councils. The Industry Advisory Council

includes senior representatives from organizations/associations who can represent their industry

sector’s perspectives on various issues (TSSA, 2010b). For Consumer Advisory Councils,

qualified members are selected from individuals with diverse backgrounds in public safety and

consumer representation, as well as representatives of consumer organizations operating in Ontario

and nationally (TSSA, 2016).

4.0 Discussion and Recommendation

In this section, we discuss PSM enabling regulations, guidelines for auditing and inspections,

annual performance indicators, and public participation. Based on these discussions, we give

recommendations for further enhancing SCES’s PSM efforts.

4.1 PSM regulation

Comparing the PSM related regulation from SCES with CCHSHMP and TSSA, CCHSHMP has

the most comprehensive scope followed by TSSA and then SCES. SCES does not have its own

PSM regulation, enabling it to perform enforcement activities and penalties. While a basic outline

of each PSM section is provided, discussing the specific methodologies and technologies for each

is beyond the scope of the article. CCHSHMP and TSSA have fully developed PSM regulations

which clearly state the requirements for regulated companies associated with recommended

methodologies and technologies, and enforcement activities for noncompliance. These regulations

provide a benchmark to the regulated industries about how to maintain overall process safety in

their facilities.

30
PSM elements are clearly stated in the CCHSHMP regulation. Since the only PSM regulation for

TSSA is regarding fuel, the PSM elements in the regulation are more specific for fuel but not for

general process safety regarding toxic release and fire or explosion. SCES and TSSA recommend

CSA Z767-17 PSM as a reference, which is mentioned previously. This PSM guidance was

developed by the concerted effort of PSM specialists from all over Canada and is the most

recognized PSM guidance among the chemical and manufacturing industries in Canada. Table 6

shows a comparison of PSM elements between CCHSHMP and SCES. It is modified from the

comparison conducted by Brouillard (2017). As mentioned earlier, most chemical and petroleum-

related companies are under program 3 of CalARP regulation. Therefore, PSM elements of

program 3 regulation are used in this comparison.

Table 6. Comparison between CSA Z767 - 17 and CalARP program

CSA Z767 – 17 CalARP Program
Accountability
Process Safety Regulations, codes, and standards Process Safety Information
Leadership Process Safety Culture Employee participation
Conduct of operations
Process knowledge and Process Safety Information/
documentation Operating procedures
Understanding Project review and design
hazards and procedures
risks Process risk assessment and Process Hazard Analysis / Pre-
reduction Startup Safety Review
Human factors Process Hazard Analysis
Training and competency Training / Contractors
Risk Management of Change (MOC) Management of Change
management Process and equipment integrity Mechanical integrity
Emergency management planning Emergency response program
Investigation Incident Investigation
Audit Process Compliance Audits
Review and
Enhancement of process safety
improvement
knowledge
Key performance indicators Contractors

31
Table 6 illustrates that CalARP regulation does not have elements that consider accountability,

conduct of operations, and enhancement of process safety knowledge. Also, there is no specific

project requirements for CalARP regulation. On the other hand, CSA Z767-17 does not consider

hot work permits and trade secrets, as considered by the CalARP program. Maher et al. (2016)

presented a PSM/RMP Modernization Program in California at the 12th Global Congress on

Process Safety. They summarized some key elements from various Safety Management Systems

and formed a subset to include new elements or changes that were judged as having a potential

significant effort needed for compliance: Process Safety Culture Assessment, Human Factors, and

Management of Organizational Change. All these new elements are already included in CSA Z767

– 17 reflecting modern, complex Safety Management Systems.

Hazards assessment is mandatory requirement for all three local PSM authorities to ensure the

safety of industrial processes, people, and the environment. However, the scope is different for the

three local PSM authorities, as shown in Table 7. SCES focuses on the worst credible scenarios

with no technologies and methodologies specified in the regulation. TSSA’s hazard assessment

requirement is only for propane facilities. Worst credible scenarios are also being focused on and

only simple technologies and methodologies are provided for vapor cloud explosions. Alternative

scenarios, such as thermal radiation effects, flash fires, and BLEVE are mentioned in the document

but without any possible simple calculation models. CCHSHMP’s PSM regulation has the most

comprehensive scope among the three. Both worst-case scenarios and alternative scenarios are

required in the regulation with clear guidance of technologies and methodologies provided. It is

natural to focus on the hazard scenarios with the most intense impact on people and the

environment, but the scenarios that have a higher probability of occurrence should also be analyzed.

Examples of alternative scenarios for toxic substances and flammable substances are shown in

32
Table 8. None of these PSM authorities consider the domino effects; primary accidents are

considered to be more critical.

Table 7. Consequence analysis scope for SCES, CCHSHMP and TSSA

SCES CCHSHMP TSSA

Worst credible scenarios Worst-case scenarios Worst-case scenarios
Alternative scenarios Alternative scenarios
No parameters provided Provide seven types of parameters A few parameters provided
Simple calculation models are
Simple calculation models are
No calculation model provided for toxic release, vapor
provided for vapor cloud
provided cloud fires, vapor cloud explosion,
explosion
pool fires and BLEVEs
No mention of domino
No mention of domino effects No mention of domino effects
effects

Table 8. Sample alternative scenarios (U.S. EPA, 2009)

Toxic substances (releases) Flammable substances

Vapor cloud fires (flash fires) may result from the
Transfer hose releases due to splits or
dispersion of a cloud of flammable vapor and ignition
sudden hose uncoupling
of the cloud following dispersion
Process piping releases from failures at
A pool fire, with potential radiant heat effects, may
flanges, joints, welds, valves and valve
result from a spill of a flammable liquid.
seals, and drains or bleeds
A boiling liquid, expanding vapor explosion (BLEVE),
Process vessel or pump releases due to
leading to a fireball that may produce intense heat, may
cracks, seal failure or drain, bleed, or
occur if a vessel containing flammable material
plug failure
ruptures explosively as a result of exposure to fire.
For a vapor cloud explosion to occur, rapid release of a
Vessel overfilling and spill, or over large quantity, turbulent conditions (caused by a
pressurization and venting through relief turbulent release or congested conditions in the area of
valves or ruptured disks the release, or both), and other factors are generally
necessary.
A jet fire may result from the puncture or rupture of a
Shipping container mishandling or
tank or pipeline containing a compressed or liquefied
puncturing leading to a spill
gas under pressure.

As for risk tolerance and land-use planning, SCES and TSSA have a relatively similar risk

tolerance criterion. SCES allows the risk of 1.00 FE/mpy for commercial land-use such as high-

33
density residential, office towers, etc., and 0.30 FE/mpy for sensitive institutions such as hospitals,

nursing homes, schools, etc. Although the bases of comparison are different between SCES and

TSSA (TSSA uses general population and sub-sensitive population), the examples provided for

the definitions are the same. When developing a land-use plan, CCHSHMP considers more risks

than SCES. Land-use planning is an important method for protecting human health and the

environment from fire, explosion or release of a toxic substance. Unambiguous model outcomes

and a standardized qualitative risk analysis are critical for land-use planning decision making

(Pasman et al., 2009). Despite TSSA’s and CCHSHMP’s methods, we could find no policy

statement in the regulatory documents to stop encroachments towards industrial lands.

SCES’s risk-based land-use planning considers the probabilities of persons exposed, release event,

and wind impact and uses data from reliable references when doing probability calculations

(McCutcheon, 2017). This risk-based method is suitable to evaluate the relative effects of risk

reduction actions compared with other methods such as consequence-based methods and mixed

methods (Cozzani et al., 2006). CCHSHMP utilizes a theoretical number to describe all types of

risk for development projects as mentioned previously. Although the exact method for the points

assigned for each type of risk is less clear, CCHSHMP has a more defined methodology when

issuing a land-use permit. SCES required a development proposal to provide related information,

such as traffic impact analysis and a detailed site plan; however, it does not specify any risk

tolerance or conditions for not issuing a development permit as CCHSHMP (Strathcona County,

2015). Equation (6) and its related risks provide a reference when developing a proposed project.

The proponents must consider the impact of transportation risk, distance from the receptor, type

of receptor, size of the project, percentage change and hazard category of material. This not only

34
saves time for the regulator when reviewing and deciding on proposed projects, but also provides

a persuasive reason for the decision.

Based on the comparison between SCES, CCHSHMP and TSSA, a comprehensive PSM

regulation with specific requirements and guidance associated with enforcement activities and

noncompliance penalties are recommended to be developed by SCES based on CSA Z767-17 PSM

as it reflects most recent PSM systems. Both worst-cases and alternative scenarios must be

considered for hazard assessment in the regulation; furthermore, recommended technologies and

methodologies should be provided. Companies with a mature PSM system would have their own

specific consequence analysis models where it would be more logical for them to use their own

established practices, rather than use other methods. However, recommending simple consequence

models and equations is essential for small to medium size companies who are relatively new to

PSM. Secondary accidents usually cause more irreversible damages, as demonstrated by West

Fertilizer; so, domino effects should also be considered when developing the PSM regulation. The

risk-based land-use planning can be combined with a development proposal land-use permit that

considers different types of risk as shown in CCHSHMP development project land-use permit

regulation. With this, proponents would have a better understanding of SCES’s decision and

develop their projects in a safe manner.

4.2 Auditing/inspection

Both CCHSHMP and TSSA offer compliance audits to regulated businesses to ensure PSM

regulations are being followed. Based on the research of Birkmire (2007) discussed previously,

CCHSHMP and TSSA are proven to be effective. CCHSHMP plans the RMP audit twelve months

ahead and focuses on the actual safety practices and accidental release mitigation systems during

the facility tour which complies with the steps of planning and performance. Recommendations

35
are provided after the audit as well as an implementation timetable for companies. This step

ensures the improvement of PSM regulation compliance and matches the step of follow-up.

Similarly, for TSSA compliance audits, it schedules ahead typically based on the schedule of

contractors. Contractors are asked to demonstrate their compliance by their processes, procedures

and records. Results of noncompliance can lead to penalties and a higher audit frequency.

For SCES, Phase 3 of their Industrial Engagement Program focusses on audit and inspection. We

recommend that this program ensure the compliance of CSA Z767-17 PSM for the regulated

industries inside Strathcona County. As a regulatory authority, it is not practical to evaluate every

detail, but to evaluate representative samples of the program implementation, such as safety

practices, on-site accidental release mitigation system, procedures, records, etc. (Cal EMA, 2005;

TSSA, 2020c). The Canadian Society for Chemical Engineering established an audit protocol to

evaluate if an organization meets the requirements of the PSM standard (CSChE, 2013). This

document provides a clear audit protocol for twelve PSM elements from CSA Z767-17, except

Process Safety Culture, Conduct of Operation, Emergency Management Planning, and Key

Performance Indicator. Process Safety Culture and Conduct of Operation are related to all

personnel in the organization, from the CEO to the front-line supervisors and workers. As it is

difficult to interview all company personnel, Grote and Künzler (2000) developed a questionnaire

to support the diagnosis of safety culture as part of a Safety Management System audit. This

questionnaire contains three sets of items: Operational Safety, Safety and Design Strategies, and

Personal Job Needs. Results from seven petrochemical plants proved the effectiveness of providing

more broadened and detailed information in safety management and allowed auditors to have a

better understanding of the organization’s safety culture. Combining this questionnaire with the

CSA Z767-17 document, this could be used for auditing PSM elements of Process Safety Culture

36
and Conduct of Operation. The detailed requirements of emergency management planning are

shown in the CSA Z767-17. As a regulatory authority, it is important to make sure organizations

consider all the required components for their emergency management planning. Written

emergency response plans should be reviewed along with actual mitigation systems such as on-

site mitigation systems, alarm systems, etc. Key performance indicators are critical for the

development, monitoring, and improved identification of process safety for both organizations and

regulatory authorities. We discuss this is more detail later.

In addition, the procedure of compliance audits and enforcement activities are also essential to

ensure the effectiveness of audits. Compliance audit procedures should be designed following the

steps of planning, performance, and follow-up as mentioned earlier (Birkmire et al., 2007). These

steps increase the working effectiveness. If the compliance audits do not result in enforcement

actions, inspections with noncompliance penalties and enforcement action cannot be implemented.

Both informal and formal enforcement tools, which shown in Table 5, must be used depending on

the severity of the violation, such as notice of violation, permit revocation, facility closure,

business license revocation, civil or criminal case, etc. (Adams & Sawyer, 2008). However, it is

necessary to consider the difficulties in small chemical businesses – a relatively light penalty

should be considered to avoid loss of resources or capital for small chemical businesses (Mannan

et al., 2005). An adequate number of programmed inspections is critical to promote the

standardized implementation among industries and improve standardized enforcement on all

regulated chemical processes (Luo, 2010). When designing the inspection frequency, CCHSHMP

and TSSA regulations can be used as a reference (Cal EMA, 2005). Inspection priorities can also

be used to reduce the workload for a limited number of engineers and prioritize facilities that have

37
more potential risk. The criteria used by CCHSHMP to determine inspection frequency can be

used as a reference.

4.3 Annual performance indicators

As regulatory authority that has implemented a PSM program based on established PSM

regulations, it is imperative to select the key performance indicators to evaluate program efficacy.

Two types of indicators are used to evaluate and track the performance of a PSM program: lagging

indicators and leading indicators. Lagging indicators are collected after an undesired event happens,

such as number of injuries, accidents, near misses, releases of flammable or toxic chemicals, etc.

Leading indicators are collected before an undesired event happens, such as the amount of training,

audits, inspections, etc. (Louvar, 2010). Based on this differentiation, MCARs is a lagging

indicator and the overdue inspection, past due PHA and past due investigation recommended

actions shown in the process safety performance report of ISO are leading indicators. Inspection

risk spectrum, inventory risk profile, and the compliance rate are reported as leading indicators,

and health impact and safety numbers are reported as lagging indicators by TSSA. The Center for

Chemical Process Safety (CCPS) has expanded this list to three types of metrics for chemical and

petroleum industries:

1. Lagging metrics – a backward-looking set of measures that are based on incidents that meet
the severity threshold which should be reported as part of the industry-wide process safety
metric.
2. Leading metrics – a forward-looking set of measures that illustrate the performance of
crucial safety protection layers and operating discipline.
3. Near-miss and other internal lagging metrics – a description for incidents that are below
the threshold of severity that need to be reported in the lagging metric, or unsafe conditions
which activate one or more layers of protection.

These metrics are used as measurements for different tiers in the process safety pyramid as shown

in Figure 8. Tier 1 (the most lagging) is the Loss of Primary Containment (LOPC) which has a

38
greater consequence and Tier 4 (the most leading) is the unsafe behaviors or insufficient operating

discipline which gives an early indication of any LOPC incidents. This process safety pyramid

separates the level of the consequence of an incident based on severity and reflects the idea that

any major or minor accidents would have precursory unsafe actions or behaviors.

Figure 8. Process safety indicator pyramid (CSA Group, 2017)

Based on this safety pyramid, to better prevent both major and minor accidents and identify

weaknesses, leading metrics should be focused on. Maintenance of mechanical integrity, action

items follow-up, management of changes, and process safety training and competency (including

process safety culture) are recommended for leading indicators (CCPS, 2011). Table 9 shows the

potential metrics for each category.

39
Table 9. Potential Leading indicators (CCPS, 2011)

Mechanical a. (Number of inspections of safety critical items of plant and equipment

Integrity due during the measurement period and completed on time/Total
number of inspections of safety critical items of plant and equipment
due during the measurement period) x100%
b. (Length of time plant is in production with items of safety critical
plant or equipment in a failed state, as identified by inspection or as a
result of breakdown/Length of time plant if in production) x100%
Action Items (Number of past due of process safety action items/ Total number of
Follow-up action items currently due) x100%
Management of a. Percentage of sampled MOCs that satisfied all aspects of the site's
change MOC procedure
% of MOCs properly executed = 100 x (# of properly executed
MOCs)/(total # of MOCs)
b. Percentage of identified changes that used the site's MOC procedure
prior to making the change
% of changes using MOC = 100 x (# of MOCs)/ (# of MOCs + # of
changes that bypassed MOC)
Process Safety a. Training for PSM Critical Positions
Training and (Number of Individuals Who Completed a Planned PSM Training
Competency Session On-time)/ (Total Number of Individual PSM Training Sessions
Planned)
b. Training Competency Assessment
(Number of Individuals Who Successfully Complete a Planned PSM
Training Session on the First Try)/ (Total Number of Individual PSM
Training Sessions with Completion Assessment Planned for that time
period)
c. Failure to follow procedures/safe working practices
(Number of safety critical tasks observed where all steps of the relevant
safe working procedure were not followed/ Total number of safety
critical tasks observed) x 100%

As a regulatory authority, it might not be practical to collect and report all data as shown in Figure

8 and Table 9. One possible solution is to ask the regulated organizations to provide the key related

information or to collaborate with other jurisdictions who have the authority to do audits and share

audit results. In this way, it will be more efficient and SCES would have a better understanding

and control of the PSM of all regulated organizations. Another point to keep in mind is that the

direct relationship between all minor and major accidents is a myth. When examining leading

40
indicators, authorities should be aware that the decreasing frequency of minor accidents does not

necessarily indicate a lower frequency for major accidents. Although the general structure and

functioning of management systems for major and minor accidents might be the same, the detailed

actions to prevent accidents must be scenario-specific (Hale, 2002). Based on the 2004 Process-

Related Incidents Measure (PRIM) inspection of 89 incidents, 23.8% of the total occurrences were

due to process and equipment integrity (Lacoursiere, 2006). This demonstrates that not all high-

consequence accidents have the same causes. However, these findings also indicate that about a

quarter of these incidents could be reduced by tracking and managing process safety and equipment

integrity leading indicators.

4.4 Public participation

Both CCHSHMP and TSSA emphasize public participation in their PSM. They take into

consideration the advice and comments from the public on their policies, which shows signals

responsive democracy (ALNabhani et al., 2016). Due to different understandings of public

participation, various participatory processes are recommended. Faircheallaigh (2010) defined

public participation as any form of interaction between government and corporate actors, and the

public in the process of Environmental Impact Assessment (EIA) to consider the potential

environmental consequences of a proposed action during the planning, design, decision-making,

and implementation phases of the proposed action (Morrison-Saunders & Arts, 2004). Public

participation in EIA can be used as a reference when developing a public participation group since

the goal of PSM is to prevent human health loss, environmental damage, asset loss, and loss of

production, which contains environmental aspects as well (Khan et al., 2016). A summary of some

purposes of public participation developed by Faircheallaigh (2010) is presented in Table 10. The

41
stated missions of the hazardous material commission from CCHSHMP and the advisory councils

from TSSA match with the first two broad purposes.

Table 10. Purpose of public participation in EIA (Faircheallaigh. 2010)

Broad purpose Specific purposes and activities

Get public input in decisions made elsewhere 1. provide information to public
2. Fill information gaps
3. Information contestability
4. Problem solving and social learning
Share decision making with public 1. Reflect democratic principles
2. Democracy in practice
3. Pluralist representation
Alert distribution of power and structures 1. Involve marginalized groups
of decision making 2. Shift the locus of decision making
3. Entrench marginalization

The goal of SCES’s Industrial Engagement Program Phase 2 is to increase local industrial

engagement and provide PSM education to small to medium size businesses, and to help them

implement PSM systems in their facilities (Tufail, 2019). Industrial advisory councils or

commissions would improve the efficacy of this phase. Members could be selected from local

heavy industries with thorough knowledge regarding their methods and perspectives on process

safety management as well as other representatives from various backgrounds.

It is important to decide the purpose before engaging the public efficiently. If more purposes need

to be fulfilled, different types of councils or commissions are recommended to be developed like

TSSA. Table 10 could be used as a reference to set the mission of this council or commission.

TSSA has different advisory councils such as Boilers and Pressure Vessels Advisory Council,

Consumers Advisory Council, Natural Gas Advisory Council, Liquid Fuels Advisory Council, etc.

(TSSA, 2017a). For the second part of the Industrial Engagement Program, we recommend that

SCES give presentations and host regular meetings to small businesses and interested groups with

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presenters from the companies which have a mature PSM program. In this way, the SCES can

assist small to medium size businesses with PSM implementation while providing a platform for

communication between the local companies.

5.0 Conclusion

As chemical and manufacturing facilities have adopted increasingly complicated chemical

processes, it is crucial for regulatory authorities to implement and monitor the efficacy of a PSM

system to prevent accidental releases of toxic substances, fire, or explosion. CCHSHMP and TSSA,

as government PSM regulatory authorities, are useful comparators for SCES to consider regulation

and guidance, auditing and inspection, annual performance indicators and public participation and

provide recommendations to the existing Industrial Engagement Program of SCES.

According to the comparative study, we recommend that SCES develop a comprehensive PSM

regulation based on CSA Z767-17 Process Safety Management. Hazard assessment with clear

instructed technologies and methodologies for consequence analysis would provide a reference for

small to medium size companies. Worst-scenarios, alternative scenarios, and domino effects would

examine the range of possible consequences. Audit and inspection with penalties and enforcement

actions would help ensure the compliance with PSM regulations. Audit and inspection procedures

should include planning, performance, and follow-up to ensure the effectiveness. Annual

performance indicators, especially a set of sensitive leading indicators, are recommended to

identify the weaknesses and performance of the implemented PSM program. Finally, public

perspectives regarding PSM decisions should be collected through advisory councils or

commissions to ensure that those who are exposed to potential release events are also involved in

the implementation, management, and evaluation of the PSM system.

43
Developing and implementing a PSM system locally is not an easy process. As one of the leading

PSM provincial governments in Canada, the current PSM Industrial Engagement Program

combined with recommendations would draw a clear path to implement a PSM system locally.

Since the regulatory structures are similar between Canadian provinces our findings are

generalizable to others outside Strathcona County. For example, those from other federal or

provincial government bodies could also develop and enhance their local PSM performance by

focusing on PSM regulation and guidance, auditing and inspection, annual performance indicators,

and public participation. Rather than rely on luck to reduce the potential for chemical and

manufacturing accidents with huge losses and damages, it is our opinion that luck favours the

prepared. A an integrated, local PSM system will further lower the probability and consequences

of accidental releases of toxic substances, fires, or explosions and to ensure a healthy and safe

environment.

Additional research might be done in the future regarding this topic because this study focuses

only on regional bodies from North America (CCHSHMP and TSSA). SCES is in Canada and it

would be more beneficial to learn from better PSM practices within the country or near the region

first. After the essential PSM system has been implemented, more studies should be conducted in

the European Union and the United Kingdom. Both regions have a long history of implementing

PSM, and a mature regulation system to deal with domino effects. Regulations such as the Seveso

III Directive, the European Offshore Directive (DIRECTIVE, 2013/30/EU), and the Control of

Major Accidents Hazards are directed towards preventing accidental releases, fires, or explosions.

Modifications can be made according to the existing PSM system to further enhance the integrality

of the PSM system.

44
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