Process Safety Management Boot Camp Training

Oil & Gas Skills (OGS)

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Module 24
Element 20 – Management review and continuous improvement

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Accident (from CCPS RBPS)

 On 17 July 2001, an explosion occurred in a spent sulfuric acid storage tank at a refinery in
Delaware
 Welding work to repair tank leaks ignited hydrocarbon vapors in the vapor space of the tank. One
contract maintenance worker was killed, and eight others were injured
 The accident resulted from a confluence of several factors:
– (1) the corrosivity and flammability hazards associated with changing the tank from fresh acid
service to spent acid service were not identified and controlled,
– (2) repeated requests for tank inspections and repairs were deferred or ignored
– (3) the hot work permit failed to specify atmospheric monitoring despite previous permit
denials because of toxic and flammable gas concentrations
 Each of these contributing factors was the result of a management system breakdown
(management of change, asset integrity, and safe work) that could have been identified and
corrected by timely management review

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What is an management review?

 Management review is the routine evaluation of whether management systems are performing as
intended and producing the desired results as efficiently as possible
 It is the ongoing "due diligence" review by management that fills the gap between day-to-day
work activities and periodic formal audits

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What is the difference with an audit?

 Management reviews are conducted with the same underlying intent as an audit - to evaluate the
effectiveness of the implementation of an entire PSM element or a particular element task
 However, because the objective of a management review is to spot current or incipient
deficiencies, the reviews are more broadly focused and more frequent than audits, and they
are typically conducted in a less formal manner
 Note: management reviews still require a similar system for scheduling, staffing, and effectively
evaluating all PSM elements, and a system should be in place for implementing any resulting
plans for improvement or corrective action and verifying their effectiveness

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Typical O&G company HSE management system

Policy & Strategic Objectives

Organisation, Resources & Competence

Risk Evaluation & Management

Leadership Corrective Actions

& Commitment Planning Standards & Procedures

Implementation & Monitoring

Audit

Management Review Continuous improvement

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Texas City Refinery - PSM deficiencies

 Management response and follow-up to audits,

Leadership & Commitment
surveys etc. was inadequate

Policy & Strategic Objectives

Organisation, Resources & Competence

Risk Evaluation & Management

Planning Standards & Procedures

Implementation & Monitoring

Audit

Management Review

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References

 CCPS, “Guidelines for Auditing Process Safety Management Systems, 2nd Edition”, ISBN: 978-0-
470-28235-9, February 2011
 Energy Institute, “Guidance on meeting expectations of EI Process safety management
framework - Element 20: Audit, assurance, management review and intervention”, 1st edition,
July 2016

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