Risk Management – Global Approach, Local Solutions Rodney Azevedo Chevron Oronite Company Maua, Sao Paulo Brazil AZEV@chevron.com Neuza Ferreira Chevron Oronite Company Maua, Sao Paulo Brazil NeuzaFerreira@chevron.com Anne O’Neal Chevron Oronite Company San Ramon, California AnneONeal@chevron.com ABSTRACT Systematically and consistently identifying risks is the critical first step in managing Process Safety. In designing a new processing facility, or managing risk in an existing facility, ranking of the relative risks allows companies to focus their resources on the changes which could have the biggest impact on reducing their overall risk. Chevron’s approach evaluates risks to safety, the environment and health. Relative prioritization of these risks within a plant, within a business segment or across the enterprise has provided a sound basis for Process Safety improvement. This paper will present an overview of this global approach, a comparison to Brazilian regulatory requirements and some examples of risk reduction in the specialty chemicals business. A more comprehensive description of the Chevron HES Risk Management approach was presented at the 2008 SPE International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production held in Nice, France, 15–17 April 2008. SPE 111769 Meeting the Challenge of Technology Advancement: Innovative Strategies for Health, Environment and Safety Risk Management J.M. Bruney and D.W. Jones, Chevron Energy Technology Company 1 1. GLOBAL APPROACH 1.1 Managing Risks in Our Daily Lives Each of us manages risk in every aspect of our daily lives. As we move from place to place as pedestrians, drivers or passengers we face the deadly hazard of a traffic accident. In many countries, today’s roads are markedly safer than the roads of yesteryear. As a society we manage this risk in fundamentally two ways: reduce the likelihood and reduce the potential consequences. We minimize the likelihood through a mix of engineering controls (speed limits, traffic signs, controlled intersections, divided roads, headlights and road lighting, mirrors, sidewalks and crosswalks, anti-lock brakes, “black box” driving monitors on commercial vehicles, fences to keep animals off roads, all-weather tires, etc.) and administrative controls (tested and licensed drivers, adults holding the hands of children as they learn to safely cross streets, alert pedestrians, bright and reflective clothing for roadway workers, defensive driving skills, rested and alert drivers, alcohol/drug-free drivers, road safety laws, public safety officers, checking tire pressure). We reduce the potential consequences through things like air bags, seat belts, crumple zones and roll bars. Countries that have implemented a structured approach and put a public emphasis on Road Safety have greatly reduced the risk of road deaths around the world. They’ve taken a complex system of roadways, vehicles and people – identified the highest risks first and systematically added better and better controls. In the early 1960s, car buyers had to pay extra for seat belts in the back seat. Since that time seat belts have become standard. Many other safeguards, such as anti-lock brakes or air bags were also once considered optional. Today these safeguards are also often considered standard. 1.2 Managing Industrial Risks Managing risk in the chemical process industry is, in principle, no different. In practice, however, it can be even more complicated. The chemical plants, oil production facilities, refineries, power plants and food processing plants operating today have been built over a number of years, innovating and adapting to the changing needs of our customers and along the way adopting new and innovative engineering and administrative controls to continually reduce the risk these operations pose to workers, the public and the environment. For a plant manager, deciding where to make the next investment in risk reduction can be a tough challenge. For the manager with several facilities that manufacture a variety of products in a variety of countries the challenge is tougher still. To meet the challenge of protecting workers, communities and the environment, Chevron has adapted an approach to draw upon best practices, experience, and science across a range of technical specialty areas within the health, environment and safety (HES) fields, and integrate this knowledge into a single, structured comprehensive procedure we call RiskMan2. Within the context of a corporate-wide risk management process, the RiskMan2 procedure helps to ensure rational and consistent HES risk management. 2 A key to RiskMan2 is the recognition that HES risks do not act as independent variables, but they are highly interdependent. A holistic view of risk with clearly defined mechanisms for assessment, prioritization and action is critical. RiskMan2 provides the structure and tools to achieve this integrated picture and to understand risk trade-offs. RiskMan2 also provides a framework for identifying and appropriately applying continually advancing HES science and technology. More than ever, it is critical to have a robust decision framework to guide the use of HES tools so that they can be optimally applied in a business context. 1.3 Introduction Chevron has developed and implemented a risk management process to provide a corporate-level framework for the management of HES risks. The process addresses risks from incidents (events), activities and ongoing practices. The process has been developed in a manner consistent with all processes within Chevron’s Operational Excellence Management System. As such, it is a structured process that contains a stated purpose, objectives, and scope. Roles, resources and requirements have been agreed and clearly defined. Measurement and verification as well as continuous improvement mechanisms have been put in place. Most critically, the process has established a single, common risk assessment and management procedure – RiskMan2. 1.4 Methodology The RiskMan2 Procedure (Figure 1) is comprised of the following five major steps: Step 1: Identify and Prioritize – Identify and rank all facilities and activities such that higher priority assets are addressed first. Step 2: High-Level Risk Assessment – Conduct a high-level risk assessment based on established hazard identification techniques which we refer to as an Integrated Hazard Identification or “IHAZID.” Step 3: Further Risk Assessment – Identify and appropriately applying HES risk assessment science and risk mitigation technologies. Ultimately, the goal is to improve understanding of risk while optimizing application of risk assessment tools in a business context. Step 4: Risk Reduction and Closure – Ensure that closure of risk reduction items is timely, documented and aligned with the Chevron Way. Criteria for determination of whether a risk is actionable are key components of this step. Actionable risks require mitigation and are subsequently incorporated into a mandatory risk reduction plan. Action items within the risk reduction plan are tracked to verify that mitigation measures meet closure criteria. Step 5: Periodic Revalidation – Step 5 ensures that prior risk assessments are reviewed and updated, as necessary, at specified intervals or with significant facility changes. 3 1 2 Starting Point Asset/Project With Widely Varying Types of Facilities and Hazards Sub-Procedure 5 Periodically Revalidate E H S Risk Following Mitigation Sub-Procedure 1 Identify, Group and Prioritize Sub-Procedure 2 Perform High Level Risk Assessment to Identify HES Risks and Determine Further Risk Assessment needs SubProcedure 4 Develop Risk Reduction Plan and Document Closure of Sub-Procedure 3 Actions Perform Targeted Detailed Risk Assessments Health 3 Environment E H Safety S High Level HES Risk Profile Figure 1. RiskMan2 – A five-step risk management procedure. 1.5 Integrated Hazard Identification Study (IHAZID) The IHAZID concurrently evaluates health, environment and safety (HES) and certain asset risks in a high-level qualitative risk assessment, which is facilitated by a Qualified Facilitator with expertise in major hazards analysis and co-facilitated by an Environmental/Health/Social Facilitator. The objectives of the IHAZID are to identify major HES risks and determine the additional assessments that will be conducted to fully understand and address the risks. The IHAZID study may also identify areas where initial risk reduction should be implemented. The IHAZID process utilizes standard hazard identification methodologies to: identify hazards; brainstorm possible events of concern; determine potential consequences; identify safeguards or controls in place; risk rank the event using a corporate-wide 6x6 risk matrix and apply it sequentially for HES and asset risk, as applicable (Figure 2). This structured approach identifies initial areas where risk reduction should be considered and initial recommendations are developed. 4 Qu a lit at ive Ri sk To ler an c e Cr ite ria Figure 2. Qualitative 6x6 risk ranking matrix for health, environment, safety and asset risk. The results of an IHAZID can be represented in a three dimensional 6x6 matrix which provides a summary of the risks posed by the various activities, and a basis for prioritizing detailed risk assessment called a risk profile. Setting expectations for reducing elevated risks becomes the basis for company level resource and capital planning. As risk reduction plans are developed and implemented, facility profiles can be further aggregated to provide a risk profile for a group of facilities and graphically represent the reduction of the risk profile over time to track the impact of facility action plans are implemented as risks are mitigated. (Figure 3) 1 1 4 2 2 Li ke l e ns Co Seldom Moderate c en qu Occasional 0 Major Likely Catastrophic Seldom 0 0 Severe Unlikely 0 0 0 Remote 0 0 0 0 Unlikely 1 2 0 0 0 0 0 Minor 1 2 Rare Incidental Remote 1 1 Minor 5 Rare 4 Incidental Co Moderate ns 1 Major eq ue Severe nc e Catastrophic 4 4 5 3 3 2 9 12 5 8 2 5 6 8 6 2 Occasional iho od 5 2 6 4 4 6 3 2 7 5 5 2 5 iho od 3 4 13 3 6 2 ke l 2 6 8 2 Li 3 7 5 0 Likely e Figure 3. Conceptual representation of change in risk profile after mitigation. 5 2. LOCAL SOLUTIONS Like they do for traffic safety, governments around the world are adopting regulations to improve the safety of their chemical and processing industries. The risk management approach taken by a multi-national company has to be simple enough to implement around the world, and applicable enough to help facilities or operations comply with a variety of regulatory approaches around the world. We would like to provide you with an example of how we’ve mapped Chevron’s RiskMan2 approach to risk management regulation in Brazil. We will then provide a few examples of risk mitigation activities from Chevron Oronite’s Maua plant, here in Sao Paulo, to illustrate some of the activities underway throughout Chevron to mitigate risks identified through the process. 2.1 Use of Riskman2 to Meet to Brazilian Regulations The predominant use of the risk analysis study takes place during the environmental licensing of potentially generating sources of environmental accidents. Risk analysis studies for facilities located in the State of Sao Paulo are required by Companhia Ambiental do Estado de Sào Paulo (CETESB) and are intended to prevent environmental accidents that could endanger the health and safety of the people, and the environment. Guidance on study format, content and acceptability criteria is provided through norm P4.261.1 The manual is divided in two parts: Part I - Criteria for the hazard classification of industrial facilities. The hazard classification determines whether or not a risk analysis study is required during the environmental licensing process. Part II - Reference terms for the preparation of the Risk Analysis studies. This provides the basic guidelines for the preparation of the risk analysis studies and presents the vision of CETESB regarding the interpretation and evaluation of results. The RiskMan2 methodology meets the following State requirements: 1. The risk analysis study (RAS) in industrial activities in the State of São Paulo aims the risks assessment to the population outside the enterprise in six steps: a. Characterization of the development and the region b. Hazard identification and consolidation of accidental hypotheses c. Estimation of the physical effects and vulnerability analysis d. Estimation of frequencies e. Estimation and risk assessment f. Risk management The guide also presents a guide for the development of a Risk Management Program (RMP). “Guidance Manual for the Preparation of Risk Analysis Studies, May 2003,” developed by the Working Group of the Environmental Chamber of the Chemical and Petrochemical Industry. 1 6 There is another regulatory norm which requires an Environmental Risks Prevention Program (PPRA - Programa de Prevenção de Riscos Ambientais), which addresses the health and safety of the workers through the anticipation, recognition, evaluation and further control of the environmental risks in the workplace. Ordinance n25 of December 29, 1994, addresses measurement and control of the environmental risks in the workplace, including the methodology of the Risk Map in the Regulatory Norm NR5 – CIPA (Comissão Interna de Prevenção de Acidentes). Riskman2 provides the basis for assessment and classification of major occupational risks. 2.2 Internationally Recognized HES Management Systems RiskMan2 helps to meet elements of a number of internationally recognized HES Management systems. Most recommend a high level assessment of risks, further evaluation of risks identified and actions put in place to appropriately mitigate theses risks. Examples of such system are described below. 2.2.1 Industrial Hygiene – American Industrial Hygiene Association(AIHA)2 The American Industrial Hygiene Association (AIHA) provides guidelines for implementation of an efficient and effective program for managing industrial hygiene risks. RiskMan2 provides the tools for risk assessment and informs plans for health risk exposure assessment. The AIHA guidelines include the following steps: Step 1 – Assess exposure as a component of risk and determine an exposing rating Step 2 – Assess health effects as a component of risk and determine a health effects rating Step 3 – Compute health risk rating Step 4 – Assess uncertainty as a component of risk and determine an uncertainty rating 2.2.2 Responsible Care Responsible Care is a comprehensive HES management system which has been in place in the chemical industry for many years. Use of this management system is a membership requirement for many National Chemical Associations including the American Chemistry Council of which Chevron Oronite LLC is a member. Risk identification and mitigation are integral to Responsible Care as illustrated in some requirements outlined below. Exposure assessments and safety analyses to evaluate health and safety hazards to employees from processes; equipment; potentially hazardous substances, physical, or biological agents; or other worksite conditions. Periodic assessment and documentation of process hazards and implementation of actions to minimize risks associated with additive operations, including the possibility of human error. Source: A strategy for assessing and managing occupational exposures – second edition John R. Mulhausen and Joseph Damiano ( a publication of the AIHA( American Industrial Hygiene Association) 2 7 2.2.3 International Organization for Standardization (ISO) 14001 The identification, prioritization of “Environmental Aspects” and mitigation of significant are the starting point for ISO 14001. Element 4.3.1 states that an organization shall establish, implement and maintain a procedure(s): To identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and To determine those aspects that have or can have significant impacts on the environment (i.e., significant environmental aspects). 2.2.4 Occupational Health and Safety Assessment Series (OHSAS) 18001 This health and safety management system is intended to help an organization identify and control occupational health and safety risks and to improve overall health and safety performance. It contains elements intended to guide the development of a management system and addresses risk through element 4.3.1. "Hazard identification, risk assessment and controls determination”, where the organization must implement procedures for hazard identification and risk assessment. 2.3 Risk Reduction in Action Oronite manufactures hundreds of fuel and lubricant additive packages for all types of diesel, gasoline and natural gas engines as well as additives for gear oils and hydraulic fluids. It is the worldwide market leader in a number of areas, including Marine, Railroad and Natural Gas Engine Oils and Tractor Hydraulic Fluids. The Maua plant was built in 1978 and started operations in 1980. The manufacture of additives involves a complex set of chemical reactions and a wide variety of raw materials, which may not be particularly relevant to the risks most of you manage in your operations. While we have a variety of risk mitigation efforts underway in our manufacturing area, the examples we want to share with you today are in our finishing, blending and storage activities. 2.3.1 Reducing Risk in Finishing Tanks One of our finishing steps we call air blowing. It involves slowly bubbling a small amount of air into the product in a stirred tank until the product meets what is called a “copper strip specification”. Air blowing has been done safely in tanks for decades, and is performed by trained and qualified operators with procedures describing the limits of safe operation. However, through detailed risk assessments it was determined that there were some unlikely scenarios where failure of some of the safeguards could result in pressure building in the tank. To eliminate this risk we designed a specialized low pressure vessel in which to conduct this air blowing process. With customized improvements to the inside of the vessel and improved instrumentation and controls, this is not only a safer process, it is significantly more efficient and reliable as well. 8 2.3.2 Reducing Risk of Storing Volatile Material Another finishing process we conduct involves stirring product in a tank to remove small amounts of volatile material. This was another tank which we determined that under certain unlikely conditions, larger amounts of volatile material could be introduced and could also result in pressure building in the tank. To eliminate this risk, we designed a wiped film evaporator to remove the trace amounts of material before it is put into the storage tank. This move to pressure vessels not only eliminated the risk of an increased pressure in these tanks, but we were able to capitalize on the changes to make the process more efficient as well. We were also able to put these old tanks to use in storage or blending service, increasing our storage capacity and blending flexibility. 2.3.3 Reducing Corrosion Risk in Tanks In a business like ours, where we manufacture hundreds of additives packages, some of our most important assets are storage and blending tanks. Some of the components we use have a high viscosity and we blend and store them in heated, insulated tanks. Corrosion under this insulation is not easy to see, and presents the risk of spills and business disruption. To avoid this type of corrosion we redesigned our entire approach to insulation, minimizing water ingress and increasing the ability of the insulation to self drain if it does get wet. We also devised an approach to and to measure the effectiveness of the overall protection against water/moisture penetration between metal and covering. By utilizing the structured, risk based assessment we develop an investment approach at each facility which promptly addresses the highest HES risks, while still allowing for smaller but steady investment in the reduction of the lower risks which require multi-year investment programs to complete. 9