How Should We Prepare?
A Chem NEP inspection is a process safety management audit—there may be a higher profile to these audits, there may be a greater probability of being inspected, there may be a more aggressive stance towards fines and citations—but, at the end of the day, it’s still a PSM audit. There is almost two decade’s industry experience in preparing for PSM audits, and a great deal of published information on how to prepare for a PSM audit [25, 26].
Recently, various authors have reviewed Refining NEP citation data and highlighted certain items which may be helpful in an audit:
- leveraging a detailed pre-audit ,
- upgrading specific elements of a PSM program ,
- ensuring that the Process Safety Information adequately covers RAGAGEP ,
- developing a multi-layer plan, which covers all preparation activities from initial planning through hosting the inspection ,
- hosting the actual inspection .
These items have been labeled as “tactical” because all of them are or should be conducted in the normal course of business at a chemical plant. No new strategy is needed, just the time and resources (which is often a challenge) to do what is expected.
In contrast to tactical preparations, strategic preparations require a structured plan and precipitate activities that are not in the normal course of business. Like PSM problems , document management problems tend to be systemic.
Upgrading the plant’s document management system is certainly a candidate for a strategic approach. It has all the hallmarks of an initiative requiring a proper strategy:
- Importance: Table 2 indicates that document deficiencies were the major cause of Refining NEP citations.
- Cross-functionality: Many people in a plant create documents; many more people use them. The creators and users of the documentation are not usually in the same organizational unit (e.g. department, area).
- Duration: Dealing with document deficiencies and upgrading a plant’s document management system both require time—these are not tasks that can be done during the week before an audit. It is important to start early and plan effectively.
The remainder of this paper will focus on understanding document deficiencies relevant to PSM compliance, provide a strategic vision, and conclude with a roadmap to achieving the strategy.
What are the Root Causes of Document Deficiencies?
There was a time, many decades ago, when quality “control” simply consisted of an inspector who checked a shipment on the loading dock to make sure it was “OK”. Since then, progress has been made in the quality movement, following the work of luminaries such as Deming  and Juran , and widely-adopted programs such as Six Sigma and ISO 9000 [32, 33]. All quality programs recognize that quality is a systemic issue and must be addressed at all stages of design, production and delivery.
Similarly, document management is a systemic issue and calls for a comprehensive response.
Document Management – pre-1992
Prior to 1992, plant documentation was largely in paper form. Electronic creation existed, especially for creating drawings, but the archival copy tended to be plotted on velum, and stored in “flat files”. Supporting documentation, such as equipment files, tended to be well organized in stored in filing cabinets. Document storage was often in a locked file room, under the supervision of a “file room” or “drawing vault” administrator. Documents and drawings, when needed, were formally checked out of the file room—late returns were often met with a surly comment.
The file room clerk was unquestionably the document “custodian”—a custodian being the person is looks after the physical well-being of a company asset.
The “ownership” of the information varied depending on the type of document: process engineers owned P&IDs, maintenance owned the equipment files, inspection owned the inspection files.
Everything worked rather well.
The two recessions, in 1981-2 and 1990-1 according to the National Bureau of Economic Research , forced many plants to cut costs. Regrettably, a short-sighted, but common area for cost cutting was to eliminate the staff in the drawing vault. Drawing vaults and records centers across the country turned into “self-service centers” where people could take whatever documents they needed, when they needed them.
Without the discipline of a proper check-out/check-in mechanism, plant documentation quickly deteriorated:
- much of it went missing
- copies were made, as needed, and redlined with changes, without the changes ever being reflected in any “master” set of documents
- arguments ensued about who actually owned the “master” documentation, especially in cases like equipment files where several groups (engineering, maintenance, inspection, capital projects, turnaround planning) use the data
- revision control was suspect because one was never certain what redlines existed for a particular document.
The rise of electronic creation tools, CAD, word processors, spreadsheets, etc., made all of these problems worse, since it became very easy to create copies, modify documents, and store them on personal hard drives, and departmental file shares—again, without any discipline regarding who owns the documents and how information would be consolidated.
The Initial PSM Initiative
When the PSM regulations took effect in 1992, plants were often overwhelmed with the effort needed to get into compliance—PSM was sometimes jokingly referred to as the “Chemical Engineers Full Employment Act”.
The strategy most commonly employed was to “divide and conquer”. As shown in Figure 1, for example:
- Process Engineering was told to get the drawings, especially the P&IDs, updated,
- Operations was told to get the procedures updated, and make sure everyone is trained on them,
- Process Safety was told to pull together the information needed to do PHAs,
- Inspection was told to update all the drawings with inspection points, and ensure wall thickness measurements were up to date,
- Maintenance was told to ensure that equipment files were updated with all the changes that had previously taken place,
- Design Engineering was told to update all the engineering standards in order to demonstrate RAGAGEP,
- Instrumentation and Electrical was told to make sure the instrument data is all updated and put in a database,
- and so on…
Figure 1. Getting information ready for an audit, using “divide and conquer”.
How much did it cost?
Suppose 10 people were taken away from their jobs for a year to conduct this information clean-up. At a burdened cost of $100k/year, this yields a $1 million cost. For even a moderately-sized chemical plant, it’s hard to imagine that PSM prep was done in anything as small as 10 person-years of effort.
A Fragmented Collection of Documents
The initial round of PSM preparation was conducted under extreme time pressure. So, each department looked after their own information, and stored it in whatever medium was convenient for them. As a result, some documents were stored on network file shares (departmental websites came along later, as well), other documents were stored in hardcopy files, tabular data was often put into local databases (such as Access™) or larger applications (like maintenance management applications).
With all this effort, PSM compliance was achieved.
Figure 2. “Divide and conquer” document updates create fragmented document storage, and very complex document access.