CCB4633

1. An employee in a chemical plant makes the following statement:

“I came to work here almost 15 years ago. This was a good job with good
pay and benefits. I’ve seen a lot of change, some for the better, some worse.
Some good people left but we have new people joining this company. Some new
equipment has been bought to replace the older one.
I just heard a supervisor talking about new challenges for our plant from
OSHA enforcement of the Process Safety Management standards. He said there
is really no need for more government regulation or enforcement, that this will just
hurt our industry. He questioned the PSM standards, asking why it was so
important and why – years after it was issued – OSHA is increasing its attention to
PSM.
I think the PSM Standard was a good change for our industry, but I’d like
some facts to back that up.”

Convince the employee that the Process Safety Management standard is

important and required for the industry.
[20 marks]

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2. In 16th-century London, a statement that described impossibility was referred to

as a “black swan” because all historical records of swans up to that time had
reported that swans only had white feathers. The term "black swan" was derived
from a poet characterization of something being "a rare bird in the lands and very
much like a black swan"1. When the phrase was coined, the black swan was
presumed not to exist.

a. Discuss the relation between the term “black swan” with specific challenge
of implementing PSM Standards effectively.
[10 marks]

b. Suggest ideas for preventing the “black swans”.

[10 marks]

1
Puhvel, J., “The Origin of Etruscan tusna ("Swan")”, The American Journal of Philology, Vol. 105, No. 2 (Summer,
1984), pp. 209-212.

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3. a. A chemical processing plant had replaced hundreds of valves during a

shutdown, because of performance issues with the current brand of valve.
The new valves installed were an exact match as far as the design
specifications required such as operation, installation method, pressure and
temperature rating and materials of construction. However, these valves
had a much higher down-time frequency. Management of the plant
categorized these changes as replacement-in-kind and hence avoided the
initiation of the Management of Change (MOC) process.

i. Compare and contrast the term ‘change’ and ‘replacement-in-kind’

as described in the CFR1910.119 Process Safety Management
standards.
[6 marks]

ii. As a process safety engineer of the plant, you disagreed with the
management. Justify your disagreement towards the decision made.
[6 marks]

b. Correct the following misconceptions of MOC.

i. “But I am not making a real modification. I am just making it a little

better.”
[4 marks]

ii. “I don’t have time to wait for the MOC evaluation. This is an
emergency!”
[4 marks]

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4. The following statements are the description of accidents that occurred before the
implementation of the CFR1910.119 Process Safety Management standards.
Identify relevant elements of the PSM standards which might have prevented the
accident. Justify your answer.

a. On July 23, 1984, an explosion and fire occurred at the oil refinery owned
by Union Oil Company. Propane escaped from a crack in an amine
absorber of the refinery and formed a gas cloud which then ignited. This led
to an explosion and fire in the alkylation unit and a fire in the Uni-firing area.
Occupational Safety and Health Agency (OSHA) cited and fined Union Oil
$21,000 for willful and serious violations including inadequate preventive
maintenance and lack of personal protective equipment. It was later
determined that the crack in the process tower was due to improper
contractor welding procedures.
[10 marks]

b. An explosion and fire accidents occurred at the Amoco Oil Co.’s refinery on
October 30, 1988. The oxidizer, a 22-meter-high, 10-meter diameter vessel
went up like a rocket 12 to 15 meter when it blew. OSHA cited and fined
Amoco more than $300,000 for a wide variety of violations. The unit began
to malfunction several days earlier but the company kept it running in order
to maintain production. Two similar explosions had occurred earlier in 1988
that injured 18 employees.
[10 marks]

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