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Operational discipline in practice
Article in Process Safety Progress Β· June 2021
DOI: 10.1002/prs.12207
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O R I G I N A L A R T I C L E
Operational discipline in practice
Muhammad Imran Rashid1
| Chaudhry Haider Ali1
| Kashif Mukhtar1
|
Emad Benhelal2
| Muhammad Athar3,4
1
Department of Chemical, Polymer and
Composite Materials Engineering, University
of Engineering and Technology (KSK Campus),
Lahore, Pakistan
2
Discipline of Chemical Engineering, The
University of Newcastle, Newcastle, Australia
3
Centre for Advanced Process Safety (CAPS),
Chemical Engineering Department, Universiti
Tecknologi Petronas, Seri Iskandar, Malaysia
4
Department of Chemical Engineering, Khwaja
Fareed University of Engineering and
Information Technology, Rahim Yar Khan,
Pakistan
Correspondence
Muhammad Imran Rashid, Department of
Chemical, Polymer and Composite Materials
Engineering, University of Engineering and
Technology (KSK Campus), 39021, Lahore,
Pakistan.
Email: imranrashid@uet.edu.pk
Abstract
A general guideline to improve operational discipline is required. Operational disci-
pline can be improved with simple things such as floor level meeting (FLM), job cycle
check (JCC), risk assessment (RA), daily safety audit (DSA), consequence analysis
(CA), mechanical integrity (MI), incident investigation (II), management of change
(MOC), behavior observation (BO), pre-start up safety reviews (PSSR), process hazard
analysis (PHA), job risk assessment (JRA), quantitative risk assessment (QRA), and
process safety management (PSM) implementation. This article presents risks identi-
fied from floor level meetings, steps for job cycle check and risk sensitivity and proce-
dure for daily safety audit and behavior observation audit. Consequence analysis,
pre-start up safety review and why tree analysis are discussed for improving opera-
tional discipline. Inclusion of consequence analysis in work instructions is discussed.
Procedure for accident investigation is elaborated by investigating trainee unit shift
engineer (USE) burning injury accident and why tree diagram is constructed and find-
ings and recommendations are provided. PHA techniques (HAZOP, Failure Mode and
Effect Analysis) methodology is presented to enhance operational discipline. This
article is especially for those industries which are located in countries where PSM
implementation is not mandatory and they are lacking in operational discipline.
K E Y W O R D S
burn injury, consequence analysis, daily safety audit, floor level meetings, incident
investigation, job cycle check, operational discipline, PHA techniques, risk sensitivity
1 | INTRODUCTION
Operational discipline can be defined as a commitment and dedication
to perform each task in a right way, each time and shows strength of
the company's safety culture.1
Three effective process safety program
foundations are safety culture and leadership, process safety systems
and operational discipline.2
Operational discipline is important for all
safety management systems especially process safety management
(PSM) programs.3
Vaughen and Klein have discussed how poor opera-
tional discipline leads to loss of containment incidents and escalates
process safety risk.4
Klein has demonstrated that effectiveness and
improvement of operational discipline can be judged through 11 char-
acteristics.3
Klein and Vaughen have simplified these 11 organizational
characteristics into four primary characteristics including leadership
focus, employee involvement, practice consistent with procedures
and excellent housekeeping.5
They have demonstrated why opera-
tional discipline is important and its implementation for organizations
and individuals. Klein et al has also demonstrated concept of opera-
tional discipline, its key attributes and steps an organization can take
to enhance its operational discipline and conduct of operations.6
Vaughen et al has demonstrated that implementation of a behavior
based safety program has improved operational discipline of a
manufacturing site.7
Klein and Francisco have discussed personal
involvement required in enhancing operational discipline and
DuPont's operational discipline program.8
Forest has introduced a
model to facilitate operational discipline, engineering discipline and
Received: 18 July 2020 Revised: 4 September 2020 Accepted: 30 September 2020
DOI: 10.1002/prs.12207
Proc Safety Prog. 2020;e12207. wileyonlinelibrary.com/journal/prs Β© 2020 American Institute of Chemical Engineers 1 of 14
https://doi.org/10.1002/prs.12207
management discipline.9
A general guideline to improve and imple-
ment operational discipline for practicing industries is missing in the
literature. This article provides guideline and a procedure to imple-
ment operational discipline to enhance industrial process safety and
safety culture and especially how operations departments can
contribute in improving process safety. Here it is demonstrated that
operational discipline excellence can be achieved through different
acts which include process hazard analysis, task risk assessment, daily
safety audit, floor level meetings, incident investigations, job cycle
check, mechanical integrity and risk sensitivity.
TABLE 1 Example of FLM meeting form completed after meeting for communication
Floor level meeting of operation department
Scope: To conduct safety meeting
Participants: ----------------------------------------------------------------------------
HSE topics/issues discussed: Safety issues of ammonia, urea, utility plants
ACTIONABLE POINTS
Sr. No. Recommendations Responsibility Target
Status (Open/
Close)
Ammonia unit
1. PICe-8-789. Valve proper approach to be provided
2. ID-789-Fan, Barring door to be fixed with hinges.
3. 575# steam silencer, internal inspection is needed,
because broken and corroded piece fall from it
during start up.
4. 789-101-B Furnace, auxiliary burners peep holes
proper approach to be provided.
Urea unit
5. E-219-789-ABC Exchangers, Local drain lines are
under capacity. During draining, urea splash out.
Procedure modified, with P-987 urea solution will be
recycled to TK-987.
6. Reactor B: main angle valve east side railing is not
strong enough.
7. E-789-AF: NH3 Inlet lines missing chain valves to be
provided.
8. TP-789B/789B Steam turbine: Proper approach
(monkey ladder  platform) to be provided for
operating inlet/outlet steam isolating valves.
9. Definition or function of the Equipment/Instrument/
Machine should be mentioned in documents.
Utility unit
10. Instrument air valve to ammonia/urea unit to be
relocated for better approach.
11. 600#/55# steam valves at TCB-789-B needs a
platform for better approach.
12. B-789-AB, Silencer to be provided for super heater
vent line.
Bagging and shipping unit
13. CV-789 (1-85): mesh to be provided on roller safeguard
to cover the gaps
14. CV-789 (A to L): mesh to be provided on roller
safeguard to cover the gaps
15. Warehouse-A-789: west side on floor grouted amaber
bolts are to be removed on edge of platform
16. Ammonia filling open drain pit is to be covered with
metal sheets (East-South corner of empty cylinder
yards)
2 of 14 RASHID ET AL.
2 | RISKS FROM FLOOR LEVEL MEETINGS
Floor level meetings can be conducted during night or day shifts
including senior engineer in charge, unit shift engineers, board panel
supervisors and area process operators of each ammonia, urea, utility
and bagging and shipping areas. In group meetings each participant
from each facility highlights safety progress of their respective sec-
tions. Employees individually pinpoint risks and hazards present on
their plants or sections or sub-sections. One employee note down
minutes of these meetings and these minutes are conveyed to the
management for implementation and action or follow up. Highlighted
risks from one floor level meeting are presented in Table 1. Chemical
process industries which are not covered under PSM rule can conduct
these floor level meetings to identify different risks and improve oper-
ational discipline. It is recommended that each department (operation
department, engineering department, process department, safety
department and inspection department) conduct these meetings sepa-
rately (because of the expertise in each area by each specific depart-
ment) and convey identified risks and hazards to management for
remedial action. Floor level meetings are useful in identifying risk situ-
ations and operability issues. Addressing these issues immediately will
improve conduct of operations.
3 | JOB CYCLE CHECK
Klein et al has described that if operator does not use specific check-
list needed for performing a given task, he has violated operational
discipline.6
Job cycle check is an important task to do in each process
industry. Sometimes people do same job again and again and usually
get used to it or bored or fed up and do it carelessly or consider it a
routine. JCC is in place for these kind of jobs for example, dissolving
urea from waste urea powder in a dedicated tank. A filled JCC form
for urea prill tower bucket change over is shown in Table 2. It is rec-
ommended that each area operator complete this form to have better
understanding of the steps involved in a task and get awareness about
the risks associated with procedure deviation. Job cycle checks are
useful for evaluating standard operating procedures implementation
gap. JCC audits are usually performed by experienced management.
JCC audits improve machines reliability and ensure smooth operation
of plant. These audits make sure that operators follow standard and
approved practices for their routine tasks.
4 | RISK ASSESSMENT: EXAMPLE FROM
UREA UNIT
Risk sensitivity can be measured by examining work instructions or
standard operating procedures. Standard risk assessment form is
shown in Table 3. It is better that risk sensitivity forms are completed
for all work instructions or standard operating procedures and are
available for unit shift engineers, trainee engineers, area operators
and trainee operators. Everyone should play his role in reducing
operational risks.2,10,11
Indicating risks present in day-to-day activities
will reduce the accidents and improve operational discipline. Risk
assessments are useful in identifying risks, hazardous situations and
operability issues for tasks described in work instructions or standard
operating procedures. These will be a quick source of information
regarding risks before performing any task.
5 | DAILY SAFETY AUDITS
Daily safety audit must be conducted daily by all employees. DSA
helps to identify unsafe acts and unsafe conditions and how to avoid
near miss reports. If a certain employee is busy, DSAs may be deferred
for 2 or 3 days or a week but must be after consulting the area super-
vision. Daily safety audits can be used to check damaged insulation,
damaged earth cables of exchanger, damaged asbestos sheets, motor
fan covers, motors coupling guards, steam condensate leakages, steam
tracing lines insulation, drain channel covers, rain protection covers,
uncovered pits, extended pipes of scaffolding in the walkways,
TABLE 2 Example of JCC form to produce excellence in different
routine jobs
Job cycle check to control work method
Section: Urea Prill Tower
USE Name: __________
Trainee Operator: __________
Mentor/Evaluator/Section in Charge: _________
Tasks/Sub Tasks of Job: SB-241 change over
Prepare the stand by bucket β–‘
heck the stand by bucket for free rotation β–‘
Close the flushing steam in reflux line β–‘
Ask board supervisor to divert the valve SV-789 to tank TK-789 β–‘
Operator will divert the local; selection to reflux line β–‘
Check SV-789 that indication has turned from yellow to red β–‘
Open flushing steam for 2 to 3 minutes for bucket flushing β–‘
Reduce bucket speed to 120 RPM β–‘
Check that selection at local panel is at local position β–‘
Stop bucket from local panel and ensure that speed has become
zero β–‘
Close flushing steam valve to bucket and isolate jacketing steam β–‘
Also de-pressurize the jacketing steam and disconnect steam/
condensate hose pipe β–‘
Unlock the flexible flange of urea hose pipe and raise bucket β–‘
Unlock and revolve the prilling device and put stand by bucket into
prilling hole β–‘
Turn selection to local position and turn lock to OFF position β–‘
Lower the bucket in operating position and connect the steam and
condensate flexible hoses β–‘
Lock flexible urea hose flange and take jacketing steam in service β–‘
Start the bucket and raise the speed up to 220 RPM β–‘
Turn on flushing steam for 2-3 minutes to pre-heat the bucket and
turn switch to feed position β–‘
Ask board supervisor to start prilling and flush reflux line β–‘
Open the flushing steam into reflux line and clean the stand by bucket
β–‘
Evaluation: OK/Not OK.
If Not OK, Then Reasons from Mentor/Section in Charge:
_______________
RASHID ET AL. 3 of 14
hanging sheets (metallic or asbestos), discharge lines leaky valves or
bleeders and missing monkey ladder cages.12
A completed daily safety
audit form is shown in Table 4. Daily safety audits are useful in identi-
fying potential hazards (hanging cables, naked wires, trip/slip hazards,
burn injury potentials, damaged supports, hot surfaces, ergonomics
hazards, biological hazards, occupational illness hazards, industrial
hygiene etc) and mark observations to responsible person for timely
close out. These audits if performed effectively improve site's safety
culture and operational discipline.
6 | CONDUCTING CONSEQUENCE
ANALYSIS AND ADDITION IN WORK
INSTRUCTIONS
Klein et al has described that effective operational discipline include
safe operating limits of the process and limiting conditions of opera-
tion.6
This type of consequence analyses identifies safe operating
limits and limiting conditions of a process and operation. Conse-
quence analysis is very important for each and every equipment, com-
pressor, pump, vessel, exchanger or any piece of instrument or parts
of the instruments (eg, transmitters). Consequence analysis identifies
potential emergency scenarios which may encounter during plant
operation, their risk level, existing safeguards, and mitigation actions.
CA enhances emergency handling and trouble shooting skills of opera-
tions team and helps in improving plant reliability and safe/smooth
operation. Consequence analysis form is shown in Table 5. These
kinds of analyses should and must have been incorporated in operat-
ing procedures.
7 | MECHANICAL INTEGRITY TESTING
FORMS
Equipment failure will be a result of poor operational discipline and
weaknesses in mechanical integrity programs.4
Mechanical integrity of
TABLE 3 Example of risk assessment completed form
Risk assessment
Sr No. Work instruction No. Risk Actionable points
1. PROD/666
Change over of urea reactor MOTOYAMA valve from
Manual to Auto
Engaging device can damage the hand if the valve does
not put on auto, if operator feels its on auto.
Wheel can hurt the hand during rotation
Gland leakage
2. PROD/666
C-789A/B Compressor start up
Back flow from reactor can cause blockage in CO2 line
Operator can fall during closing of unloaders
Operator can slip during closing bypass valves of auto
drainers
3. PROD/666
Startup of High Pressure Ammonia Feed Pumps
Exposure to NH3 gas during priming toward sump
Plunger packing  O-ring leakage during increasing
pump pressure
Pump can trip during pressuring
4. Continue ------------ Continue------------------------------
TABLE 4 Example of DSA form to find unsafe conditions or unsafe acts
Daily safety audit
Unsafe situation/audit hour
Auditor: ___________________ Date: ------------------------
Sr. No. Area Description Responsibility Target date Status
1. Urea Chromate drum to be removed from synthesis section I/C Urea and Chief Process Engineer Open
2. Urea A structure girder is hindering to barring device at the time
of compressor C-2111 barring, which can cause safety
hazard
I/C Urea, I/C Equipment and I/C Machinery Open
3. Urea Air Mask an air mask should be present near overhead
condenser E-2233 in case of any leakage
I/C Urea and HSE Engineer Open
Note: Unit Engineer In charges (UEIC(s) to send feedback within 48 hours. With target date to HSE Office. Status will be closed when UEIC(s) will send job
completion report to HSE Office.
4 of 14 RASHID ET AL.
T
A
B
L
E
5
Example
of
performa
for
consequence
analysis
Consequence
analysis
Work
instruction:
Operation
Date:
-----------------
Unit:
Urea
Prepared
by:
---------------------
Section:
Synthesis
Approved
by:
--------------------
Equipment/vessel/process:
C-987
Sr.
No.
Deviation
Display
range
Alarm/tripping
Normal
operating
range
Causes
Consequence
Control
measures
1.
C-987
Compressor
Trip
NA
-
Lube
oil
PSLL-23253
22#
-55-65#
-Low
lube
oil
pressure
-E-209
level
decreases
-LT-2711
-SIC-November
12,
2010/13
-High
discharge
temperature
of
first,
second
and
third
stages
TSHH-21255B/21258B/
21261B
-first
stage
250-300

F
second
stage
230-300

F
third
stage
185-260

F
-High
discharge
temperature
of
first,
second
and
third
stages
-E-209
CO
2
concentration
decrease
-AIC-29114
-C-201
A/B
suction
pressure
increases.
-PIC-23200/201
-Reactor
temperature
increases
-E-2152
manual
heating
adjustment
-TIC-21109/10
-Increase
the
load
on
C-201
A/B
and
adjust
MP-CO2
if
possible.
-Adjust
NH
3
flow
to
Rxs
to
maintain
Ξ”T.
-PSHH
third
stage
390#
290-350#
-High
discharge
pressure
of
third
stage
-High
level
in
first
K.O.D
LSHH-27252
-High
level
in
first
K.O.D
-PSLL-23254
suction
12
00
Water
column
-0.5-4.0#
-Low
suction
pressure
-High
vibration
VSH-29300
-High
vibration
-Power
failure
-P-202
speed
decrease
RASHID ET AL. 5 of 14
vessels and exchangers must be intact at all times of the plant opera-
tion and is difficult to do, as plant undergo many changes with time
and there are many modifications and usually costly modifications are
not always welcomed.12
A completed mechanical integrity testing
form is presented in Table 6 which can be used to determine
mechanical integrity of all process equipment. Ensuring mechanical
integrity of all process vessels will contribute in enhancing operational
discipline of the organization. Ensuring mechanical integrity will save
operations team from emergencies arising from leakages from flanges,
level glasses, PSVs, vent valves, drain valves and transmitters.
TABLE 6 Example of mechanical integrity testing performa
Mechanical integrity of vessels/exchangers
Vessel
conditions V987 E987 V789 E789 V666
Level glass √ NA √ NA √
Flanges √ Not o.k. √ Not
o.k.
H-6102 not o.k.
PSV/bleeder √
PSV setting 75#
NA √
PSV setting 35#0
NA NA
Vent valve NA NA NA NA NA
Drain valve √ √ √ √ √
Vessel
insulation
√ √ √ √ √
Lines
insulation
Damage urea inlet line HIC-29112 line damage
near NRV
√ √ Weak solution bottle(H-6102)
lines not o.k.
Instrumentation conditions
Control
valve
√ NA √ NA √
PI/PT √/√
PI shown in PIDs but not in
field present)
NA √/√
PI present in field but not
shown in PIDs
NA √/√
H-6102 vapor line PI not shown
in PIDs
TI/TT β€”/√ β€”/√ β€”/√ β€”/√ β€”/√
LI/LT β€”/√ NA β€”/√ β€”/√ β€”/√
Abbreviations: LI, level indicator; LT, level transmitter; PSV, pressure safety valve; NRV, non-return valve; PI, pressure indicator; PT, pressure transmitter;
TI, temperature indicator; TT, temperature transmitter.
TABLE 7 Example of detailed incident report form for trainee USE burning injury
6 of 14 RASHID ET AL.
TABLE 7 (Continued)
(Continues)
RASHID ET AL. 7 of 14
TABLE 7 (Continued)
8 of 14 RASHID ET AL.
TABLE 7 (Continued)
(Continues)
RASHID ET AL. 9 of 14
8 | INCIDENT INVESTIGATION AND
CONSTRUCTING WHY TREE DIAGRAM
Human error is responsible for each accident13
and improvement in
operational discipline can reduce loss of containment incidents.4
Inci-
dent investigation has a very direct connection with operational disci-
pline of the organization. Poor operational discipline cause more risks
and incidents having extreme consequences.1
Poor operational disci-
pline was responsible for many accidents such as Flixborough (1974),
Seveso (1976), Piper Alpha (1988), Texas City (2005), Buncefield
(2005), Deepwater Horizon (2010), Amuay (2012), West Fertilizer
(2013) and Airgas (2017).14-20
Incident investigation is essential to
determine the underlying causes of an incident/accident and take
necessary measures to prevent its reoccurrence.
Rashid et al has shown that its very important to construct why
tree diagrams for occurred accidents to identify the safety management
systems failure.21
Improvement in these safety management systems
will prevent future incidents and enhance operational discipline. First
step to construct a why tree diagram is to complete a detailed incident
report form. An example is presented here to demonstrate how a
detailed incident report form can be completed. An engineer burning
injury example is considered here to demonstrate how a detailed inci-
dent report form is completed (Table 7) followed by a construction of
the why tree diagram (Figure 1). Which safety management systems
failed in this accident are highlighted on the diagram (Figure 1).
9 | MANAGEMENT OF CHANGE
(PERMANENT/TEMPORARY)
Management of change has been described as one of the attributes of
management systems for effective operational discipline.6
Requisites
for management of change (MOC) are explained in our earlier publication
with the help of a diagram.12
An example is shown here how to complete
a management of change form for permanent change (Table 8). Purpose
of management of change is that management approve the changes
occurring in the process plant and these changes are also documented
for future use. This will improve operational discipline as no inappropriate
change will be made which affect the plant operation at later stage.
10 | BEHAVIOR OBSERVATION AUDIT
REPORTS
Behavior observation audits are very important to observe at-risk/
unsafe behaviors and reduce chances of near miss, incidents or
TABLE 7 (Continued)
10 of 14 RASHID ET AL.
accidents. In behavior observation forms, unsafe acts and behavior of
working employees and personnel are observed. Different observation
categories can be used such as reaction of people, position of people,
tools used, procedure, personal protective equipment etc. These audits
can be performed on daily, weekly, fortnightly or monthly basis. These
completed B.O. audit forms are collected and analyzed on monthly
basis. Vaughen et al has presented a behavior based safety observation
form which can be used for auditing purpose.7
During this audit, audi-
tor focuses on behavioral safety of person working in field (wearing
safety harness, PPEs compliance, PTW compliance, hiding or dodging
attitude, stopping the work by seeing auditor etc) and reports unsafe
behavior/unsafe conditions along with injury risk potential.
11 | EXISTENCE OF WORK INSTRUCTIONS
OR OPERATING PROCEDURES AND PRE
START-UP SAFETY REVIEWS (PSSR)
Up-to-date documentation is one of the 11 characteristics of opera-
tional discipline.3
Existence of work instructions and or operating
procedures and their correctness is very important for an organization
or corporation. It was observed that flaws in operating procedures
were responsible as a root or contributing cause for 13% of the
occurred accidents or incidents.21
Existence of work instructions
improve operational discipline as they enlist step wise procedure for
routine jobs and chance of errors minimize. Pre start-up safety review
must be performed before the start-up of the normal facility or before
the start-up of a newly installed facility or part of the facility. BP
Texas City refinery incident occurred because they did not perform
pre start-up safety review and there were deficiencies in work permit
system and job safety analysis.2
PSSR are useful to operate newly installed and running facilities
safely, each and every time. PSSR may be performed before starting
big compressors, pumps, generators, cooling towers, condensers,
exchangers, evaporators and or reactors but must not be confused
with normal start-up check lists. There must be check list for each dif-
ficult task or operation and its necessary to keep a tracking record of
all the check lists and their timely completion. It is recommended that
before normal and simple jobs, job risk assessment is performed and
for difficult and dangerous jobs, task risk analysis is performed.
Feb 1, 2010
1520 hrs TK-214
Urea Unit near
On Feb 1, 2010 at 1520 hrs trainee USE got
injured due to hot condensates splashing
from TK-214 at urea unit
Trainee USE
Startup
Stop
Trainee USE injured due to Hot
condensate splashing
Stop
Line up activity
Valve from P-2171 into TK-214
was opened
USE did not confirm
that line was
depressurized
capacity
Overflow line of less
Pressurized line
opened in the tank
solution
below the level of
No Line up checklist
Line pressurized due to
steam
leakage from jacketing
Line did not increased
TK-214
after height increase of
MOC procedure not in
place at that time
PHA base line or after
MOC not done
Risk Analysis
Failure
MOC Failure
Failure of MIQA
Failure of
Procedure
Get training
USE
To assist Senior
plant
Stop
Normal practice at
up
Prepare line
the
checklist for
section
Plan and rectify
TK-214 inlet line
jacket leakage
TK-214 Vent Line
opens at height
Now carry out
MOC procedure
dia
and increase
of overflow line
design
As per original
Failure of
equipment
design base
Study and
correct inlet line
to TK-214
location
TK-214 head cover
gasket damaged
Plan and rectify
TK-214 top cover
gasket leakage
Study and
correct top over
line to TK-209
vent line
Carry ou risk
as
assessment
part of MOC
Legend
Cause
Contributory
Root Cause
FIGURE 1 Example of why tree diagram of trainee USE injury [Color figure can be viewed at wileyonlinelibrary.com]
RASHID ET AL. 11 of 14
12 | PHA TECHNIQUES FOR ENHANCING
OPERATIONAL DISCIPLINE
PHA focuses on operational problems, environment pollution prob-
lems and risks associated with operating parameters deviations. PHAs
are normally performed for existing facilities, new facilities, old equip-
ment dismantling and transportation and during equipment design.
PHA has different steps such as hazard identification, hazard evalua-
tion and mitigation and incident investigation as well as planning and
preparation and consequence analysis. Hazards can be identified using
previous PHAs, previous accidental or incidental reports or near mis-
ses or field tours or SDS and chemical interaction matrix. Most com-
mon PHA techniques are check list, what-If and hazop analyses.
Check list analysis use different check lists to identify all hazards.
Check list analysis use well documented list for hazards evaluations
and thus have pros and cons. Their usage is easier, most available,
cheap, requires less skilled staff and can identify all hazards at any
stage of process plant.22
Check lists have limitations as they will cover
only those hazards which are known by the author and are not a
detailed or thorough PHA. What-If technique is based on questions to
determine effect of occurrences on the environment, process, people
and personnel and equipment. This is brain storming technique based
on question answer sessions.22
Hazop technique methodology is
shown in Figure 2.22
Failure mode and effect analysis technique meth-
odology is shown in Figure 3.22
PHA may need to be revalidated after 3 years as some changes
occur due to changes in process safety information, equipment
changes, or changes in the design of newly installed equipment or
process lines.
13 | CONCLUSION AND
RECOMMENDATIONS
A completed floor level meeting form is presented which indicates
many hidden hazards and risks in ammonia plant, urea plant, utility
plant and bagging and shipping plant. This clearly demonstrated that
floor level meetings are very effective to identify hazards and opera-
bility problems which are faced by area operators. Daily safety audit
also identifies hazards on daily basis and is a quicker way to tackle
them on spot or on urgent basis. Job cycle check form has indicated a
step by step procedure of a routine job and this form must be used by
trainee and senior area operators. Risk sensitivity form has indicated
risks associated with MOTOYAMA valve manual to auto operation
and during high voltage CO2 compressor and ammonia pump start
up. Generally small and medium size industries have not included
TABLE 8 Example of MOC permanent form for permanent change in a facility
Company name: XYZ MOC for permanent change (Technology/Facility/DFM) Document No: ---------------
Effective date: ---------------
Department: Unit/section: Urea Area: 220
Problem definition and proposed solution
To be completed by the originating area and signed by the concerned area incharge
MOC/Project title LIC-27108 by pass line to be provided
MOC No (to be allocated by project section)
PROBLEM DESCRIPTION/PURPOSE OF CHANGE: Define as clearly as possible what the problem is and what difficulties or unnecessary
expenditure it is causing. This section defines the justification so it is essential that some time is spent on the wording. For scope, changes to
authorized projects define why the scope needs to be changed and indicate if possible why this piece of scope was missed from the original scope.
If control valve seat detach then transfer of urea solution will stop from the V-2161 resulting in shut down of urea unit.
*PROPOSED SOLUTION/DESCRIPTION OF CHANGE: Provide a brief outline of the solution proposed by the area initiating the MOC form. This
may not be the solution finally agreed upon but it will provide some guidance to the project lead.
A bypass line to be provided with flushing provision and steam jacketing
*JUSTIFICATION/TECHNICAL BASIS FOR CHANGE: What is the justification for this proposed project? Why should the business allocate funds to
this project? What are the savings or capacity growth delivered?
Shutdown of urea unit and production loss will be saved.
Environmental pollution in case of plant shut down will be saved.
Initiation: Name Designation Signature Date
Originator ------------------------ Assistant Production Engineer -----------------------
Concerned Section In charge ------------------------- UEIC ------------------------
Concerned Deptt. Head ------------------------ Assistant production manager ----------------------
I agree that this proposed change is necessary and approved for study.
Sr. General Manager -------------------------
Note: Secretary to Sr. General Manager is responsible to return the form to: 1. I/C Project/Project Leader (if approved for study). 2. Originator (if not
approved for study). 3. Secretary to Sr. GM to track the record of all the MOC's for study. 4. I/C Project/Project Leader will assign this MOC to Sr. Project
Engineer/Project Liaison Engineer for further proceedings.
12 of 14 RASHID ET AL.
these risk sensitivity sheets in their work instructions or standard
operating procedures. Consequence analysis form is also presented
indicating causes, consequences and control measures for the com-
pressor tripping and generally these consequence analyses for pumps,
compressors, blowers, fans, conveyors, prill tower buckets, scrappers,
analyzers, instruments or switches are missing from standard operat-
ing procedures. It is also necessary to ensure mechanical integrity of
all process equipment for example, vessels, exchangers, etc. Mechani-
cal integrity testing form presented in this study can be used by the
industries and academia.
A completed management of change form is presented which
indicates requirements such as problem description, proposed solu-
tion, justification for change and authorizations form top manage-
ment. Significance of behavior observation audits, standard operating
procedures, PSSR and checklists is briefly highlighted. HAZOP meth-
odology and FEMA methodology is presented in a step-wise pattern.
A detailed incident report form is completed for a trainee USE
burning injury and is used to construct a why tree diagram. This
incident indicates that some hidden hazards are present which can
occur during plant start up or shut down activities which need special
attention. Urea feed line to the tank (open from top) was leaky and
got pressurized by a 33 Psig steam jacketing and resulted in a conden-
sate splashing when inlet valve to tank was opened. An early EWR job
completion will surely has prevented this accident. It is recommended
that after all jobs completed through MOC, PHA should be repeated
on regular basis possible to reassess hazards and high hazardous situa-
tion survey of the area to be performed. It is expected that this article
will help those companies which are not performing this type of ana-
lyses (in understanding what could be used to make their processes
safer).
AUTHOR CONTRIBUTIONS
Dr. Muhammad Imran Rashid: Conceptualization; data curation; for-
mal analysis; investigation; methodology; writing-original draft;
writing-review and editing. Chaudhri Haider Ali: Conceptualization;
formal analysis; investigation; methodology. Kashif Mukhtar:
Select Process Blocks
Divide Process Blocks Prioritize on Hazard
Severity
Appoint PHA Team
Hold PHA Team
Meeting
Appoint Team Leader
Appoint Team Members
Prepare Charter Assign Responsibilities
Establish Meeting
Schedule
Collect Process Safety
Information
MSDS  Chemical
Interaction Matrix
Incident Investigation
Reports
Prior PHA/of Similar
Facility
PIDS
Operating
Parameters/Process
Design Information
Management of change
Documents
Field Tour of Selected
Block
Identify Hazards
Identify Human Factors
Check Facility Issues
Select Process
Parameters
Apply Guide Words
Develop Deviations
List Protections 
Safeguards
List causes of Deviations
 Prevention
Develop
Recommendations
Implement
Recommendations
Consequences if
safeguards fail
FIGURE 2 HAZOP technique
methodology
RASHID ET AL. 13 of 14
Conceptualization; formal analysis; investigation; methodology. Emad
Benhelal: Conceptualization; formal analysis; investigation; methodol-
ogy. Muhammad Athar: Conceptualization; formal analysis; investiga-
tion; methodology.
ORCID
Muhammad Imran Rashid https://orcid.org/0000-0003-2340-4983
Muhammad Athar https://orcid.org/0000-0001-7040-4252
REFERENCES
1. Vaughen BK, Klein JA, Champion JW. Our process safety journey
continues: operational discipline today. Process Saf Prog. 2018;37(4):
478-492.
2. Klein JA, Vaughen BK. Process Safety: Key Concepts and Practical
Approaches. Boca Raton, FL: CRC Press, Taylor and Francis group;
2017.
3. Klein JA. Operational discipline in the workplace. Process Saf Prog.
2005;24(4):228-235.
4. Vaughen BK, Klein JA. Improving operational discipline to prevent
loss of containment incidents. Process Saf Prog. 2011;30(3):216-220.
5. Klein JA, Vaughen BK. A revised program for operational discipline.
Process Saf Prog. 2008;27(1):58-65.
6. Klein JA, Bradshaw WM, Heuvel LNV, Lorenzo DK, Keeports G.
Implementing an effective conduct of operations and operational dis-
cipline program. J Loss Prev Process Ind. 2011;24(1):98-104.
7. Vaughen BK, Lock KJ, Floyd TK. Improving operating discipline
through the successful implementation of a mandated behavior-based
safety program. Process Saf Prog. 2010;29(3):192-200.
8. Klein JA, Francisco EM. Focus on personal operational discipline to
get work done right. Process Saf Prog. 2012;31(2):100-104.
9. Forest JJ. Management discipline. Process Saf Prog. 2012;31(4):334-336.
10. Walter R, Foottit R, Nelson B. PSM system upgrade in response to an
occupational safety and health administration NEP inspection. Process
Saf Prog. 2009;28(4):338-342.
11. Forest JJ. Management discipline: defining a process safety strategy.
Process Saf Prog. 2014;33(2):162-165.
12. Rashid MI, Ramzan N, Iqbal T, Yasin S, Yousaf S. Implementation
issues of PSM in a fertilizer plant: an operations engineer's point of
view. Process Saf Prog. 2013;32(1):59-65.
13. Kletz TA. An Engineer's View of Human Error. Boca Raton, FL: Taylor 
Francis; 2001.
14. The Center for Chemical Process Safety (CCPS). Incidents That Define
Process Safety. New York: John Wiley  Sons; 2008.
15. Kletz TA. What Went Wrong? Case Histories of Process Plant Disasters
and How They Could Have Been Avoided. 5th ed. London: But-
terworth-Heinemann/IChemE; 2009.
16. Sanders RE. Chemical Process Safety: Learning from Case Histories.
Elsevier, New York, NY: Butterworth-Heinemann; 2015.
17. US Chemical Safety and Hazard Investigation Board (CSB), Refinery
explosion and fire. Investigation Report, 2005-04-I-TX, 2007.
18. US Chemical Safety and Hazard Investigation Board (CSB), Drilling
Rig Explosion and Fire at the Macondo Well. Report No. 2010-10-I-
OS, 2014.
19. US Chemical Safety and Hazard Investigation Board (CSB), West fer-
tilizer company fire and explosion. Report No. 2013-02-I-TX, 2016.
20. US Chemical Safety and Hazard Investigation Board (CSB), Nitrous
oxide explosion. Report No. 2016-04-I-FL, 2017.
21. Rashid MI, Ramzan N, Almas Q. Incident investigation in Pakistan's
fertilizer industryβ€”common safety management system failures and
issues. Process Saf Prog. 2014;33(4):399-404.
22. Rashid MI, Ramzan N. Urea Synthesis Hazard Analysisβ€”PHA, HAZOP
and Quantitative Risk Assessment. Saarbrucken, Germany: LAMBERT
Academic Publishing AG  Co. KG; 2012.
How to cite this article: Rashid MI, Ali CH, Mukhtar K,
Benhelal E, Athar M. Operational discipline in practice. Proc
Safety Prog. 2020;e12207. https://doi.org/10.1002/prs.12207
Define objective  scope
Select team
Select
system/Component
Split into sub-
components
List failures effects on
system
List failure modes
List safe guards present
Conduct Risk Raking
Develop
recommendations
Implement
recommendations
FIGURE 3 Failure mode and effect analysis technique
methodology
14 of 14 RASHID ET AL.
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Operational discipline in practices - Build the safety culture

  • 1. See discussions, stats, and author profiles for this publication at: https://www.researchgate.net/publication/344809410 Operational discipline in practice Article in Process Safety Progress Β· June 2021 DOI: 10.1002/prs.12207 CITATIONS 6 READS 1,945 5 authors, including: Muhammad Imran Rashid University of Engineering and Technology, Lahore 48 PUBLICATIONS 585 CITATIONS SEE PROFILE Chaudhry Haider Ali University of Engineering and Technology, Lahore 30 PUBLICATIONS 568 CITATIONS SEE PROFILE Muhammad Athar Khwaja Fareed University of Engineering & Information Technology 29 PUBLICATIONS 334 CITATIONS SEE PROFILE All content following this page was uploaded by Muhammad Imran Rashid on 23 October 2020. The user has requested enhancement of the downloaded file.
  • 2. O R I G I N A L A R T I C L E Operational discipline in practice Muhammad Imran Rashid1 | Chaudhry Haider Ali1 | Kashif Mukhtar1 | Emad Benhelal2 | Muhammad Athar3,4 1 Department of Chemical, Polymer and Composite Materials Engineering, University of Engineering and Technology (KSK Campus), Lahore, Pakistan 2 Discipline of Chemical Engineering, The University of Newcastle, Newcastle, Australia 3 Centre for Advanced Process Safety (CAPS), Chemical Engineering Department, Universiti Tecknologi Petronas, Seri Iskandar, Malaysia 4 Department of Chemical Engineering, Khwaja Fareed University of Engineering and Information Technology, Rahim Yar Khan, Pakistan Correspondence Muhammad Imran Rashid, Department of Chemical, Polymer and Composite Materials Engineering, University of Engineering and Technology (KSK Campus), 39021, Lahore, Pakistan. Email: imranrashid@uet.edu.pk Abstract A general guideline to improve operational discipline is required. Operational disci- pline can be improved with simple things such as floor level meeting (FLM), job cycle check (JCC), risk assessment (RA), daily safety audit (DSA), consequence analysis (CA), mechanical integrity (MI), incident investigation (II), management of change (MOC), behavior observation (BO), pre-start up safety reviews (PSSR), process hazard analysis (PHA), job risk assessment (JRA), quantitative risk assessment (QRA), and process safety management (PSM) implementation. This article presents risks identi- fied from floor level meetings, steps for job cycle check and risk sensitivity and proce- dure for daily safety audit and behavior observation audit. Consequence analysis, pre-start up safety review and why tree analysis are discussed for improving opera- tional discipline. Inclusion of consequence analysis in work instructions is discussed. Procedure for accident investigation is elaborated by investigating trainee unit shift engineer (USE) burning injury accident and why tree diagram is constructed and find- ings and recommendations are provided. PHA techniques (HAZOP, Failure Mode and Effect Analysis) methodology is presented to enhance operational discipline. This article is especially for those industries which are located in countries where PSM implementation is not mandatory and they are lacking in operational discipline. K E Y W O R D S burn injury, consequence analysis, daily safety audit, floor level meetings, incident investigation, job cycle check, operational discipline, PHA techniques, risk sensitivity 1 | INTRODUCTION Operational discipline can be defined as a commitment and dedication to perform each task in a right way, each time and shows strength of the company's safety culture.1 Three effective process safety program foundations are safety culture and leadership, process safety systems and operational discipline.2 Operational discipline is important for all safety management systems especially process safety management (PSM) programs.3 Vaughen and Klein have discussed how poor opera- tional discipline leads to loss of containment incidents and escalates process safety risk.4 Klein has demonstrated that effectiveness and improvement of operational discipline can be judged through 11 char- acteristics.3 Klein and Vaughen have simplified these 11 organizational characteristics into four primary characteristics including leadership focus, employee involvement, practice consistent with procedures and excellent housekeeping.5 They have demonstrated why opera- tional discipline is important and its implementation for organizations and individuals. Klein et al has also demonstrated concept of opera- tional discipline, its key attributes and steps an organization can take to enhance its operational discipline and conduct of operations.6 Vaughen et al has demonstrated that implementation of a behavior based safety program has improved operational discipline of a manufacturing site.7 Klein and Francisco have discussed personal involvement required in enhancing operational discipline and DuPont's operational discipline program.8 Forest has introduced a model to facilitate operational discipline, engineering discipline and Received: 18 July 2020 Revised: 4 September 2020 Accepted: 30 September 2020 DOI: 10.1002/prs.12207 Proc Safety Prog. 2020;e12207. wileyonlinelibrary.com/journal/prs Β© 2020 American Institute of Chemical Engineers 1 of 14 https://doi.org/10.1002/prs.12207
  • 3. management discipline.9 A general guideline to improve and imple- ment operational discipline for practicing industries is missing in the literature. This article provides guideline and a procedure to imple- ment operational discipline to enhance industrial process safety and safety culture and especially how operations departments can contribute in improving process safety. Here it is demonstrated that operational discipline excellence can be achieved through different acts which include process hazard analysis, task risk assessment, daily safety audit, floor level meetings, incident investigations, job cycle check, mechanical integrity and risk sensitivity. TABLE 1 Example of FLM meeting form completed after meeting for communication Floor level meeting of operation department Scope: To conduct safety meeting Participants: ---------------------------------------------------------------------------- HSE topics/issues discussed: Safety issues of ammonia, urea, utility plants ACTIONABLE POINTS Sr. No. Recommendations Responsibility Target Status (Open/ Close) Ammonia unit 1. PICe-8-789. Valve proper approach to be provided 2. ID-789-Fan, Barring door to be fixed with hinges. 3. 575# steam silencer, internal inspection is needed, because broken and corroded piece fall from it during start up. 4. 789-101-B Furnace, auxiliary burners peep holes proper approach to be provided. Urea unit 5. E-219-789-ABC Exchangers, Local drain lines are under capacity. During draining, urea splash out. Procedure modified, with P-987 urea solution will be recycled to TK-987. 6. Reactor B: main angle valve east side railing is not strong enough. 7. E-789-AF: NH3 Inlet lines missing chain valves to be provided. 8. TP-789B/789B Steam turbine: Proper approach (monkey ladder platform) to be provided for operating inlet/outlet steam isolating valves. 9. Definition or function of the Equipment/Instrument/ Machine should be mentioned in documents. Utility unit 10. Instrument air valve to ammonia/urea unit to be relocated for better approach. 11. 600#/55# steam valves at TCB-789-B needs a platform for better approach. 12. B-789-AB, Silencer to be provided for super heater vent line. Bagging and shipping unit 13. CV-789 (1-85): mesh to be provided on roller safeguard to cover the gaps 14. CV-789 (A to L): mesh to be provided on roller safeguard to cover the gaps 15. Warehouse-A-789: west side on floor grouted amaber bolts are to be removed on edge of platform 16. Ammonia filling open drain pit is to be covered with metal sheets (East-South corner of empty cylinder yards) 2 of 14 RASHID ET AL.
  • 4. 2 | RISKS FROM FLOOR LEVEL MEETINGS Floor level meetings can be conducted during night or day shifts including senior engineer in charge, unit shift engineers, board panel supervisors and area process operators of each ammonia, urea, utility and bagging and shipping areas. In group meetings each participant from each facility highlights safety progress of their respective sec- tions. Employees individually pinpoint risks and hazards present on their plants or sections or sub-sections. One employee note down minutes of these meetings and these minutes are conveyed to the management for implementation and action or follow up. Highlighted risks from one floor level meeting are presented in Table 1. Chemical process industries which are not covered under PSM rule can conduct these floor level meetings to identify different risks and improve oper- ational discipline. It is recommended that each department (operation department, engineering department, process department, safety department and inspection department) conduct these meetings sepa- rately (because of the expertise in each area by each specific depart- ment) and convey identified risks and hazards to management for remedial action. Floor level meetings are useful in identifying risk situ- ations and operability issues. Addressing these issues immediately will improve conduct of operations. 3 | JOB CYCLE CHECK Klein et al has described that if operator does not use specific check- list needed for performing a given task, he has violated operational discipline.6 Job cycle check is an important task to do in each process industry. Sometimes people do same job again and again and usually get used to it or bored or fed up and do it carelessly or consider it a routine. JCC is in place for these kind of jobs for example, dissolving urea from waste urea powder in a dedicated tank. A filled JCC form for urea prill tower bucket change over is shown in Table 2. It is rec- ommended that each area operator complete this form to have better understanding of the steps involved in a task and get awareness about the risks associated with procedure deviation. Job cycle checks are useful for evaluating standard operating procedures implementation gap. JCC audits are usually performed by experienced management. JCC audits improve machines reliability and ensure smooth operation of plant. These audits make sure that operators follow standard and approved practices for their routine tasks. 4 | RISK ASSESSMENT: EXAMPLE FROM UREA UNIT Risk sensitivity can be measured by examining work instructions or standard operating procedures. Standard risk assessment form is shown in Table 3. It is better that risk sensitivity forms are completed for all work instructions or standard operating procedures and are available for unit shift engineers, trainee engineers, area operators and trainee operators. Everyone should play his role in reducing operational risks.2,10,11 Indicating risks present in day-to-day activities will reduce the accidents and improve operational discipline. Risk assessments are useful in identifying risks, hazardous situations and operability issues for tasks described in work instructions or standard operating procedures. These will be a quick source of information regarding risks before performing any task. 5 | DAILY SAFETY AUDITS Daily safety audit must be conducted daily by all employees. DSA helps to identify unsafe acts and unsafe conditions and how to avoid near miss reports. If a certain employee is busy, DSAs may be deferred for 2 or 3 days or a week but must be after consulting the area super- vision. Daily safety audits can be used to check damaged insulation, damaged earth cables of exchanger, damaged asbestos sheets, motor fan covers, motors coupling guards, steam condensate leakages, steam tracing lines insulation, drain channel covers, rain protection covers, uncovered pits, extended pipes of scaffolding in the walkways, TABLE 2 Example of JCC form to produce excellence in different routine jobs Job cycle check to control work method Section: Urea Prill Tower USE Name: __________ Trainee Operator: __________ Mentor/Evaluator/Section in Charge: _________ Tasks/Sub Tasks of Job: SB-241 change over Prepare the stand by bucket β–‘ heck the stand by bucket for free rotation β–‘ Close the flushing steam in reflux line β–‘ Ask board supervisor to divert the valve SV-789 to tank TK-789 β–‘ Operator will divert the local; selection to reflux line β–‘ Check SV-789 that indication has turned from yellow to red β–‘ Open flushing steam for 2 to 3 minutes for bucket flushing β–‘ Reduce bucket speed to 120 RPM β–‘ Check that selection at local panel is at local position β–‘ Stop bucket from local panel and ensure that speed has become zero β–‘ Close flushing steam valve to bucket and isolate jacketing steam β–‘ Also de-pressurize the jacketing steam and disconnect steam/ condensate hose pipe β–‘ Unlock the flexible flange of urea hose pipe and raise bucket β–‘ Unlock and revolve the prilling device and put stand by bucket into prilling hole β–‘ Turn selection to local position and turn lock to OFF position β–‘ Lower the bucket in operating position and connect the steam and condensate flexible hoses β–‘ Lock flexible urea hose flange and take jacketing steam in service β–‘ Start the bucket and raise the speed up to 220 RPM β–‘ Turn on flushing steam for 2-3 minutes to pre-heat the bucket and turn switch to feed position β–‘ Ask board supervisor to start prilling and flush reflux line β–‘ Open the flushing steam into reflux line and clean the stand by bucket β–‘ Evaluation: OK/Not OK. If Not OK, Then Reasons from Mentor/Section in Charge: _______________ RASHID ET AL. 3 of 14
  • 5. hanging sheets (metallic or asbestos), discharge lines leaky valves or bleeders and missing monkey ladder cages.12 A completed daily safety audit form is shown in Table 4. Daily safety audits are useful in identi- fying potential hazards (hanging cables, naked wires, trip/slip hazards, burn injury potentials, damaged supports, hot surfaces, ergonomics hazards, biological hazards, occupational illness hazards, industrial hygiene etc) and mark observations to responsible person for timely close out. These audits if performed effectively improve site's safety culture and operational discipline. 6 | CONDUCTING CONSEQUENCE ANALYSIS AND ADDITION IN WORK INSTRUCTIONS Klein et al has described that effective operational discipline include safe operating limits of the process and limiting conditions of opera- tion.6 This type of consequence analyses identifies safe operating limits and limiting conditions of a process and operation. Conse- quence analysis is very important for each and every equipment, com- pressor, pump, vessel, exchanger or any piece of instrument or parts of the instruments (eg, transmitters). Consequence analysis identifies potential emergency scenarios which may encounter during plant operation, their risk level, existing safeguards, and mitigation actions. CA enhances emergency handling and trouble shooting skills of opera- tions team and helps in improving plant reliability and safe/smooth operation. Consequence analysis form is shown in Table 5. These kinds of analyses should and must have been incorporated in operat- ing procedures. 7 | MECHANICAL INTEGRITY TESTING FORMS Equipment failure will be a result of poor operational discipline and weaknesses in mechanical integrity programs.4 Mechanical integrity of TABLE 3 Example of risk assessment completed form Risk assessment Sr No. Work instruction No. Risk Actionable points 1. PROD/666 Change over of urea reactor MOTOYAMA valve from Manual to Auto Engaging device can damage the hand if the valve does not put on auto, if operator feels its on auto. Wheel can hurt the hand during rotation Gland leakage 2. PROD/666 C-789A/B Compressor start up Back flow from reactor can cause blockage in CO2 line Operator can fall during closing of unloaders Operator can slip during closing bypass valves of auto drainers 3. PROD/666 Startup of High Pressure Ammonia Feed Pumps Exposure to NH3 gas during priming toward sump Plunger packing O-ring leakage during increasing pump pressure Pump can trip during pressuring 4. Continue ------------ Continue------------------------------ TABLE 4 Example of DSA form to find unsafe conditions or unsafe acts Daily safety audit Unsafe situation/audit hour Auditor: ___________________ Date: ------------------------ Sr. No. Area Description Responsibility Target date Status 1. Urea Chromate drum to be removed from synthesis section I/C Urea and Chief Process Engineer Open 2. Urea A structure girder is hindering to barring device at the time of compressor C-2111 barring, which can cause safety hazard I/C Urea, I/C Equipment and I/C Machinery Open 3. Urea Air Mask an air mask should be present near overhead condenser E-2233 in case of any leakage I/C Urea and HSE Engineer Open Note: Unit Engineer In charges (UEIC(s) to send feedback within 48 hours. With target date to HSE Office. Status will be closed when UEIC(s) will send job completion report to HSE Office. 4 of 14 RASHID ET AL.
  • 6. T A B L E 5 Example of performa for consequence analysis Consequence analysis Work instruction: Operation Date: ----------------- Unit: Urea Prepared by: --------------------- Section: Synthesis Approved by: -------------------- Equipment/vessel/process: C-987 Sr. No. Deviation Display range Alarm/tripping Normal operating range Causes Consequence Control measures 1. C-987 Compressor Trip NA - Lube oil PSLL-23253 22# -55-65# -Low lube oil pressure -E-209 level decreases -LT-2711 -SIC-November 12, 2010/13 -High discharge temperature of first, second and third stages TSHH-21255B/21258B/ 21261B -first stage 250-300 F second stage 230-300 F third stage 185-260 F -High discharge temperature of first, second and third stages -E-209 CO 2 concentration decrease -AIC-29114 -C-201 A/B suction pressure increases. -PIC-23200/201 -Reactor temperature increases -E-2152 manual heating adjustment -TIC-21109/10 -Increase the load on C-201 A/B and adjust MP-CO2 if possible. -Adjust NH 3 flow to Rxs to maintain Ξ”T. -PSHH third stage 390# 290-350# -High discharge pressure of third stage -High level in first K.O.D LSHH-27252 -High level in first K.O.D -PSLL-23254 suction 12 00 Water column -0.5-4.0# -Low suction pressure -High vibration VSH-29300 -High vibration -Power failure -P-202 speed decrease RASHID ET AL. 5 of 14
  • 7. vessels and exchangers must be intact at all times of the plant opera- tion and is difficult to do, as plant undergo many changes with time and there are many modifications and usually costly modifications are not always welcomed.12 A completed mechanical integrity testing form is presented in Table 6 which can be used to determine mechanical integrity of all process equipment. Ensuring mechanical integrity of all process vessels will contribute in enhancing operational discipline of the organization. Ensuring mechanical integrity will save operations team from emergencies arising from leakages from flanges, level glasses, PSVs, vent valves, drain valves and transmitters. TABLE 6 Example of mechanical integrity testing performa Mechanical integrity of vessels/exchangers Vessel conditions V987 E987 V789 E789 V666 Level glass √ NA √ NA √ Flanges √ Not o.k. √ Not o.k. H-6102 not o.k. PSV/bleeder √ PSV setting 75# NA √ PSV setting 35#0 NA NA Vent valve NA NA NA NA NA Drain valve √ √ √ √ √ Vessel insulation √ √ √ √ √ Lines insulation Damage urea inlet line HIC-29112 line damage near NRV √ √ Weak solution bottle(H-6102) lines not o.k. Instrumentation conditions Control valve √ NA √ NA √ PI/PT √/√ PI shown in PIDs but not in field present) NA √/√ PI present in field but not shown in PIDs NA √/√ H-6102 vapor line PI not shown in PIDs TI/TT β€”/√ β€”/√ β€”/√ β€”/√ β€”/√ LI/LT β€”/√ NA β€”/√ β€”/√ β€”/√ Abbreviations: LI, level indicator; LT, level transmitter; PSV, pressure safety valve; NRV, non-return valve; PI, pressure indicator; PT, pressure transmitter; TI, temperature indicator; TT, temperature transmitter. TABLE 7 Example of detailed incident report form for trainee USE burning injury 6 of 14 RASHID ET AL.
  • 9. TABLE 7 (Continued) 8 of 14 RASHID ET AL.
  • 11. 8 | INCIDENT INVESTIGATION AND CONSTRUCTING WHY TREE DIAGRAM Human error is responsible for each accident13 and improvement in operational discipline can reduce loss of containment incidents.4 Inci- dent investigation has a very direct connection with operational disci- pline of the organization. Poor operational discipline cause more risks and incidents having extreme consequences.1 Poor operational disci- pline was responsible for many accidents such as Flixborough (1974), Seveso (1976), Piper Alpha (1988), Texas City (2005), Buncefield (2005), Deepwater Horizon (2010), Amuay (2012), West Fertilizer (2013) and Airgas (2017).14-20 Incident investigation is essential to determine the underlying causes of an incident/accident and take necessary measures to prevent its reoccurrence. Rashid et al has shown that its very important to construct why tree diagrams for occurred accidents to identify the safety management systems failure.21 Improvement in these safety management systems will prevent future incidents and enhance operational discipline. First step to construct a why tree diagram is to complete a detailed incident report form. An example is presented here to demonstrate how a detailed incident report form can be completed. An engineer burning injury example is considered here to demonstrate how a detailed inci- dent report form is completed (Table 7) followed by a construction of the why tree diagram (Figure 1). Which safety management systems failed in this accident are highlighted on the diagram (Figure 1). 9 | MANAGEMENT OF CHANGE (PERMANENT/TEMPORARY) Management of change has been described as one of the attributes of management systems for effective operational discipline.6 Requisites for management of change (MOC) are explained in our earlier publication with the help of a diagram.12 An example is shown here how to complete a management of change form for permanent change (Table 8). Purpose of management of change is that management approve the changes occurring in the process plant and these changes are also documented for future use. This will improve operational discipline as no inappropriate change will be made which affect the plant operation at later stage. 10 | BEHAVIOR OBSERVATION AUDIT REPORTS Behavior observation audits are very important to observe at-risk/ unsafe behaviors and reduce chances of near miss, incidents or TABLE 7 (Continued) 10 of 14 RASHID ET AL.
  • 12. accidents. In behavior observation forms, unsafe acts and behavior of working employees and personnel are observed. Different observation categories can be used such as reaction of people, position of people, tools used, procedure, personal protective equipment etc. These audits can be performed on daily, weekly, fortnightly or monthly basis. These completed B.O. audit forms are collected and analyzed on monthly basis. Vaughen et al has presented a behavior based safety observation form which can be used for auditing purpose.7 During this audit, audi- tor focuses on behavioral safety of person working in field (wearing safety harness, PPEs compliance, PTW compliance, hiding or dodging attitude, stopping the work by seeing auditor etc) and reports unsafe behavior/unsafe conditions along with injury risk potential. 11 | EXISTENCE OF WORK INSTRUCTIONS OR OPERATING PROCEDURES AND PRE START-UP SAFETY REVIEWS (PSSR) Up-to-date documentation is one of the 11 characteristics of opera- tional discipline.3 Existence of work instructions and or operating procedures and their correctness is very important for an organization or corporation. It was observed that flaws in operating procedures were responsible as a root or contributing cause for 13% of the occurred accidents or incidents.21 Existence of work instructions improve operational discipline as they enlist step wise procedure for routine jobs and chance of errors minimize. Pre start-up safety review must be performed before the start-up of the normal facility or before the start-up of a newly installed facility or part of the facility. BP Texas City refinery incident occurred because they did not perform pre start-up safety review and there were deficiencies in work permit system and job safety analysis.2 PSSR are useful to operate newly installed and running facilities safely, each and every time. PSSR may be performed before starting big compressors, pumps, generators, cooling towers, condensers, exchangers, evaporators and or reactors but must not be confused with normal start-up check lists. There must be check list for each dif- ficult task or operation and its necessary to keep a tracking record of all the check lists and their timely completion. It is recommended that before normal and simple jobs, job risk assessment is performed and for difficult and dangerous jobs, task risk analysis is performed. Feb 1, 2010 1520 hrs TK-214 Urea Unit near On Feb 1, 2010 at 1520 hrs trainee USE got injured due to hot condensates splashing from TK-214 at urea unit Trainee USE Startup Stop Trainee USE injured due to Hot condensate splashing Stop Line up activity Valve from P-2171 into TK-214 was opened USE did not confirm that line was depressurized capacity Overflow line of less Pressurized line opened in the tank solution below the level of No Line up checklist Line pressurized due to steam leakage from jacketing Line did not increased TK-214 after height increase of MOC procedure not in place at that time PHA base line or after MOC not done Risk Analysis Failure MOC Failure Failure of MIQA Failure of Procedure Get training USE To assist Senior plant Stop Normal practice at up Prepare line the checklist for section Plan and rectify TK-214 inlet line jacket leakage TK-214 Vent Line opens at height Now carry out MOC procedure dia and increase of overflow line design As per original Failure of equipment design base Study and correct inlet line to TK-214 location TK-214 head cover gasket damaged Plan and rectify TK-214 top cover gasket leakage Study and correct top over line to TK-209 vent line Carry ou risk as assessment part of MOC Legend Cause Contributory Root Cause FIGURE 1 Example of why tree diagram of trainee USE injury [Color figure can be viewed at wileyonlinelibrary.com] RASHID ET AL. 11 of 14
  • 13. 12 | PHA TECHNIQUES FOR ENHANCING OPERATIONAL DISCIPLINE PHA focuses on operational problems, environment pollution prob- lems and risks associated with operating parameters deviations. PHAs are normally performed for existing facilities, new facilities, old equip- ment dismantling and transportation and during equipment design. PHA has different steps such as hazard identification, hazard evalua- tion and mitigation and incident investigation as well as planning and preparation and consequence analysis. Hazards can be identified using previous PHAs, previous accidental or incidental reports or near mis- ses or field tours or SDS and chemical interaction matrix. Most com- mon PHA techniques are check list, what-If and hazop analyses. Check list analysis use different check lists to identify all hazards. Check list analysis use well documented list for hazards evaluations and thus have pros and cons. Their usage is easier, most available, cheap, requires less skilled staff and can identify all hazards at any stage of process plant.22 Check lists have limitations as they will cover only those hazards which are known by the author and are not a detailed or thorough PHA. What-If technique is based on questions to determine effect of occurrences on the environment, process, people and personnel and equipment. This is brain storming technique based on question answer sessions.22 Hazop technique methodology is shown in Figure 2.22 Failure mode and effect analysis technique meth- odology is shown in Figure 3.22 PHA may need to be revalidated after 3 years as some changes occur due to changes in process safety information, equipment changes, or changes in the design of newly installed equipment or process lines. 13 | CONCLUSION AND RECOMMENDATIONS A completed floor level meeting form is presented which indicates many hidden hazards and risks in ammonia plant, urea plant, utility plant and bagging and shipping plant. This clearly demonstrated that floor level meetings are very effective to identify hazards and opera- bility problems which are faced by area operators. Daily safety audit also identifies hazards on daily basis and is a quicker way to tackle them on spot or on urgent basis. Job cycle check form has indicated a step by step procedure of a routine job and this form must be used by trainee and senior area operators. Risk sensitivity form has indicated risks associated with MOTOYAMA valve manual to auto operation and during high voltage CO2 compressor and ammonia pump start up. Generally small and medium size industries have not included TABLE 8 Example of MOC permanent form for permanent change in a facility Company name: XYZ MOC for permanent change (Technology/Facility/DFM) Document No: --------------- Effective date: --------------- Department: Unit/section: Urea Area: 220 Problem definition and proposed solution To be completed by the originating area and signed by the concerned area incharge MOC/Project title LIC-27108 by pass line to be provided MOC No (to be allocated by project section) PROBLEM DESCRIPTION/PURPOSE OF CHANGE: Define as clearly as possible what the problem is and what difficulties or unnecessary expenditure it is causing. This section defines the justification so it is essential that some time is spent on the wording. For scope, changes to authorized projects define why the scope needs to be changed and indicate if possible why this piece of scope was missed from the original scope. If control valve seat detach then transfer of urea solution will stop from the V-2161 resulting in shut down of urea unit. *PROPOSED SOLUTION/DESCRIPTION OF CHANGE: Provide a brief outline of the solution proposed by the area initiating the MOC form. This may not be the solution finally agreed upon but it will provide some guidance to the project lead. A bypass line to be provided with flushing provision and steam jacketing *JUSTIFICATION/TECHNICAL BASIS FOR CHANGE: What is the justification for this proposed project? Why should the business allocate funds to this project? What are the savings or capacity growth delivered? Shutdown of urea unit and production loss will be saved. Environmental pollution in case of plant shut down will be saved. Initiation: Name Designation Signature Date Originator ------------------------ Assistant Production Engineer ----------------------- Concerned Section In charge ------------------------- UEIC ------------------------ Concerned Deptt. Head ------------------------ Assistant production manager ---------------------- I agree that this proposed change is necessary and approved for study. Sr. General Manager ------------------------- Note: Secretary to Sr. General Manager is responsible to return the form to: 1. I/C Project/Project Leader (if approved for study). 2. Originator (if not approved for study). 3. Secretary to Sr. GM to track the record of all the MOC's for study. 4. I/C Project/Project Leader will assign this MOC to Sr. Project Engineer/Project Liaison Engineer for further proceedings. 12 of 14 RASHID ET AL.
  • 14. these risk sensitivity sheets in their work instructions or standard operating procedures. Consequence analysis form is also presented indicating causes, consequences and control measures for the com- pressor tripping and generally these consequence analyses for pumps, compressors, blowers, fans, conveyors, prill tower buckets, scrappers, analyzers, instruments or switches are missing from standard operat- ing procedures. It is also necessary to ensure mechanical integrity of all process equipment for example, vessels, exchangers, etc. Mechani- cal integrity testing form presented in this study can be used by the industries and academia. A completed management of change form is presented which indicates requirements such as problem description, proposed solu- tion, justification for change and authorizations form top manage- ment. Significance of behavior observation audits, standard operating procedures, PSSR and checklists is briefly highlighted. HAZOP meth- odology and FEMA methodology is presented in a step-wise pattern. A detailed incident report form is completed for a trainee USE burning injury and is used to construct a why tree diagram. This incident indicates that some hidden hazards are present which can occur during plant start up or shut down activities which need special attention. Urea feed line to the tank (open from top) was leaky and got pressurized by a 33 Psig steam jacketing and resulted in a conden- sate splashing when inlet valve to tank was opened. An early EWR job completion will surely has prevented this accident. It is recommended that after all jobs completed through MOC, PHA should be repeated on regular basis possible to reassess hazards and high hazardous situa- tion survey of the area to be performed. It is expected that this article will help those companies which are not performing this type of ana- lyses (in understanding what could be used to make their processes safer). AUTHOR CONTRIBUTIONS Dr. Muhammad Imran Rashid: Conceptualization; data curation; for- mal analysis; investigation; methodology; writing-original draft; writing-review and editing. Chaudhri Haider Ali: Conceptualization; formal analysis; investigation; methodology. Kashif Mukhtar: Select Process Blocks Divide Process Blocks Prioritize on Hazard Severity Appoint PHA Team Hold PHA Team Meeting Appoint Team Leader Appoint Team Members Prepare Charter Assign Responsibilities Establish Meeting Schedule Collect Process Safety Information MSDS Chemical Interaction Matrix Incident Investigation Reports Prior PHA/of Similar Facility PIDS Operating Parameters/Process Design Information Management of change Documents Field Tour of Selected Block Identify Hazards Identify Human Factors Check Facility Issues Select Process Parameters Apply Guide Words Develop Deviations List Protections Safeguards List causes of Deviations Prevention Develop Recommendations Implement Recommendations Consequences if safeguards fail FIGURE 2 HAZOP technique methodology RASHID ET AL. 13 of 14
  • 15. Conceptualization; formal analysis; investigation; methodology. Emad Benhelal: Conceptualization; formal analysis; investigation; methodol- ogy. Muhammad Athar: Conceptualization; formal analysis; investiga- tion; methodology. ORCID Muhammad Imran Rashid https://orcid.org/0000-0003-2340-4983 Muhammad Athar https://orcid.org/0000-0001-7040-4252 REFERENCES 1. Vaughen BK, Klein JA, Champion JW. Our process safety journey continues: operational discipline today. Process Saf Prog. 2018;37(4): 478-492. 2. Klein JA, Vaughen BK. Process Safety: Key Concepts and Practical Approaches. Boca Raton, FL: CRC Press, Taylor and Francis group; 2017. 3. Klein JA. Operational discipline in the workplace. Process Saf Prog. 2005;24(4):228-235. 4. Vaughen BK, Klein JA. Improving operational discipline to prevent loss of containment incidents. Process Saf Prog. 2011;30(3):216-220. 5. Klein JA, Vaughen BK. A revised program for operational discipline. Process Saf Prog. 2008;27(1):58-65. 6. Klein JA, Bradshaw WM, Heuvel LNV, Lorenzo DK, Keeports G. Implementing an effective conduct of operations and operational dis- cipline program. J Loss Prev Process Ind. 2011;24(1):98-104. 7. Vaughen BK, Lock KJ, Floyd TK. Improving operating discipline through the successful implementation of a mandated behavior-based safety program. Process Saf Prog. 2010;29(3):192-200. 8. Klein JA, Francisco EM. Focus on personal operational discipline to get work done right. Process Saf Prog. 2012;31(2):100-104. 9. Forest JJ. Management discipline. Process Saf Prog. 2012;31(4):334-336. 10. Walter R, Foottit R, Nelson B. PSM system upgrade in response to an occupational safety and health administration NEP inspection. Process Saf Prog. 2009;28(4):338-342. 11. Forest JJ. Management discipline: defining a process safety strategy. Process Saf Prog. 2014;33(2):162-165. 12. Rashid MI, Ramzan N, Iqbal T, Yasin S, Yousaf S. Implementation issues of PSM in a fertilizer plant: an operations engineer's point of view. Process Saf Prog. 2013;32(1):59-65. 13. Kletz TA. An Engineer's View of Human Error. Boca Raton, FL: Taylor Francis; 2001. 14. The Center for Chemical Process Safety (CCPS). Incidents That Define Process Safety. New York: John Wiley Sons; 2008. 15. Kletz TA. What Went Wrong? Case Histories of Process Plant Disasters and How They Could Have Been Avoided. 5th ed. London: But- terworth-Heinemann/IChemE; 2009. 16. Sanders RE. Chemical Process Safety: Learning from Case Histories. Elsevier, New York, NY: Butterworth-Heinemann; 2015. 17. US Chemical Safety and Hazard Investigation Board (CSB), Refinery explosion and fire. Investigation Report, 2005-04-I-TX, 2007. 18. US Chemical Safety and Hazard Investigation Board (CSB), Drilling Rig Explosion and Fire at the Macondo Well. Report No. 2010-10-I- OS, 2014. 19. US Chemical Safety and Hazard Investigation Board (CSB), West fer- tilizer company fire and explosion. Report No. 2013-02-I-TX, 2016. 20. US Chemical Safety and Hazard Investigation Board (CSB), Nitrous oxide explosion. Report No. 2016-04-I-FL, 2017. 21. Rashid MI, Ramzan N, Almas Q. Incident investigation in Pakistan's fertilizer industryβ€”common safety management system failures and issues. Process Saf Prog. 2014;33(4):399-404. 22. Rashid MI, Ramzan N. Urea Synthesis Hazard Analysisβ€”PHA, HAZOP and Quantitative Risk Assessment. Saarbrucken, Germany: LAMBERT Academic Publishing AG Co. KG; 2012. How to cite this article: Rashid MI, Ali CH, Mukhtar K, Benhelal E, Athar M. Operational discipline in practice. Proc Safety Prog. 2020;e12207. https://doi.org/10.1002/prs.12207 Define objective scope Select team Select system/Component Split into sub- components List failures effects on system List failure modes List safe guards present Conduct Risk Raking Develop recommendations Implement recommendations FIGURE 3 Failure mode and effect analysis technique methodology 14 of 14 RASHID ET AL. View publication stats