Hydrocarbon Processing - March 2022 - 73

Environment
and Safety
B. BLUNDELL, Contributing Editor,
Friendswood, Texas
Safe work permit auditing: Is your system
providing the expected results?
When the challenging position of manager is assumed in
a refinery, one of the first orders of business is to " survive " an
upcoming process safety management (PSM) compliance audit.
The prior audit report has been read and several issues with
work permitting have been noted. The team is called together
and the following question is posed: Can the leading and lagging
metrics for safe work permitting be shown? A moment of
silence, and then the answer, " Metrics? "
This scenario is perhaps more realistic than supposed. While
safe work practices (SWPs) have been a part of PSM regulations
for decades, incidents related to the execution of these elements
still occur. For example, lockout tagout (LOTO) violations have
been among the top five U.S. Occupational Safety and Health
Administration (OSHA) citations for several years. Other safe
work items, such as fall protection and scaffolding, have similarly
remained among the most frequent citations.
Having participated in hundreds of safe work audits, one
of the most common opportunities the author has seen is the
absence of a mature permit auditing process to gauge the effectiveness
of a program. Most refineries and chemical plants
exceed the minimum regulatory expectations for auditing
LOTO, hot work and confined space entry. However, many of
those audit programs lack the rigor that can be found in industry
better practices.
Throughout the author's experience performing audits at
refineries, chemical plants, terminals and midstream facilities,
most shortcomings in audit programs fall into one or more of the
following five categories:
* Overreliance on " paper audits " of completed permits.
These types of " after the fact " reviews of completed work
permits can provide insight into a facility's compliance
with the program's administrative controls (signatures,
etc.). However, they are ineffective in validating whether
risks are being effectively managed while jobs are
in progress. Field audits at job sites are necessary to
determine if work is being executed safely (FIG. 1). A field
audit would cover critical items such as:
Did a fire extinguisher (required in a hot work permit)
meet National Fire Protection Association (NFPA)
inspection requirements?
Were process sewers within 35 ft of hot work sealed
or covered?
FIG. 1. At refineries, chemical plants, terminals and midstream
facilities, field audits are necessary to determine if work is being
executed safely.
Hydrocarbon Processing | MARCH 2022 73
Were isolations in an LOTO at the closest point
relative to the work being conducted?
* Many audit checklists lack the granularity needed
to identify specific gaps in safe work execution.
Comprehensive checklists not only ensure consistent
application of the tool, but may also be an effective
means to educate the auditor and worker (operations or
maintenance) on the requirements.
* The sample size of audits being performed may be
too small. The number of audits completed should
be statistically representative of the overall work being
performed. The majority of audits should focus on
high-risk work, such as LOTO, hot work and confined
space entries.
* Findings from the audits are not being trended over
time to identify common gaps in execution. Most
facilities are good at addressing a specific deficiency seen
in the field at a specific job. However, they are not always
leveraging the benefit of stewarding longer-term " themes "
noted from the audits to help identify systemic issues.
* Many facilities have not established metrics related to
SW permitting. To help gauge the health of programs,
one of the most powerful leading indicators of safe
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