Process safety risks in hazardous process facilities due to the COVID-19 pandemic
What is the potential risk?
The COVID-19 pandemic can have an impact on how hazardous process facilities operate and may introduce risks that employers need to consider to ensure their workers’ safety.
This risk advisory will help employers with Step 6 of the COVID-19 Safety Plan: Assess and address risks from resuming operations.
The pandemic may have caused some facilities to shut down or to start up again. Shutdown and startup periods involve many non-routine activities that workers may not have enough experience or knowledge to handle. According to the Center of Chemical Process Safety (CCPS), process safety incidents occur five times more often during startup than during normal operations.
Similarly, operations that have been curtailed or are idling may encounter unusual conditions due to slow-progressing chemical reactions, micro-organism growth, and atypical equipment corrosion/degradation, for example. These unique situations can also create new hazards.
Deferring or delaying preventive maintenance or planned turnarounds because of the pandemic can lead to unexpected equipment failures and unplanned outages. In addition, changing operating conditions, such as extended storage of hazardous chemicals or increasing/decreasing production output, can lead to process upsets including fires, explosions, or releases of hazardous substances.
Which industries may be at risk?
- Oil and gas refineries
- Oil and gas extraction sites
- Chemical manufacturing and storage facilities
- Pulp and paper mills
- Wood pellet facilities
- Power generation plants
- Breweries and distilleries
- Other facilities with hazardous processes and large quantities of flammable, reactive, or toxic chemicals
How can I reduce the risk in my workplace?
As an employer, you’re responsible for assessing risks introduced by the COVID-19 pandemic. Consider these questions before restarting or ramping up your operations:
- Do you have new workers that will require workplace training and orientation?
- Will returning workers need time to refresh their skills after being away from the workplace? Will they need additional training if they are required to adapt their work tasks or are using equipment that is new to them?
- Has anything changed since your operations were last up and running, such as the equipment you use or the products you create?
- Are there any safety hazards posed by restarting machinery, tools, and equipment, or by clearing systems and lines of product that may have been left idle when your operation was closed?
- Have you inspected all critical controls and ensured they are operational?
Also evaluate how technical factors, as well as human and organizational factors, may contribute to health and safety risks. Some considerations include:
- Availability of compatible replacement parts for machinery or equipment
- Operating levels above or below your facility’s normal conditions or design capacity
- Challenges adhering to preventive maintenance and inspectional activity schedules — in particular, the deferrals of major turnarounds
- Loss of skilled workers and/or fewer workers on site
- New shift schedules
- Worker distraction and fatigue due to stress caused by the COVID-19 pandemic
- Availability of technical support personnel (both internal and external)
- Access to procedures and plans for personnel working remotely
Below are some ways to reduce the risk of process safety incidents in your facility. Be sure to involve your workers and to communicate with them about how you’re managing the risks:
- Ensure you have an effective Management of Change (MOC) process in place to review any proposed changes to your facility or your operations
- Conduct a Pre-Startup Safety Review (PSSR) to analyze and control the risks prior to restarting hazardous processes and equipment
- Define safe operating limits and ensure workers know them
- Review Safety Data Sheets (SDS) for chemicals you’re using or storing, and make sure they are readily available and up-to-date
- Implement effective policies and procedures for high-risk activities such as shutdowns, startups, and decommissioning
- Evaluate the impact of preventive COVID-19 measures on your safe work procedures and operations
- Check that safety systems and emergency procedures are in place and adequate
- Conduct or re-validate process hazard analysis (PHA) or risk assessments of hazardous processes to ensure effective controls are in place
- Have procedures for monitoring and maintaining critical safety controls
- Before conducting maintenance and inspections on equipment, ensure the equipment is in a safe state by performing pre-cleaning, de-energization, and lockout activities
- Ensure critical safety devices are in place, functional, and not bypassed
- Maintain asset integrity management, including reviewing appropriate inspection intervals for hazardous processes and equipment
Where can I find more information?
- General duty requirements found in Part 2, Division 4 of the Workers Compensation Act
- Applicable sections of the Occupational Health and Safety Regulation, including those found in Parts 4, 5, 6, and 19
- Health and Safety Executive (HSE) UK: Operating Procedures and Plant Modification and Change Procedures
- Center for Chemical Process Safety (CCPS) Monograph: Risk Based Process Safety During Disruptive Times
- U.S. Chemical Safety Board (CSB): CSB Investigations of Incidents During Startups and Shutdowns (PDF)
Learn more about managing risk.