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7
Process Safety Management at
Bayer CropScience
All safety assessments and practices exist within the context of an organiza -
tion, and as a result, the environment in which a company operates and the safety
culture that it fosters within its walls affect the efficacy of any hazard control
system. This chapter presents process safety management (PSM) from both a
general perspective and with specific reference to the system implemented at
Bayer CropScience (Bayer) and considers the context in which this system oper-
ates in Institute, WV. This chapter also addresses Bayer’s use of inherently safer
process (ISP) assessments conducted by Bayer within their PSM system, as well
as the context in which these assessments were considered.
PSM—GENERAL CONSIDERATIONS
PSM is a concept well familiar to the global chemical engineering community.
These PSM systems, described in Chapter 4, are conceptual and management
frameworks developed to aid in the control of hazards on site. The components
of any given PSM system may vary somewhat between countries and organiza-
tions, but the fundamental structures remain similar. These systems make explicit
the understanding that controlling a hazard—whether physical, toxic, electrical,
etc.—requires a sociotechnical system, and therefore, requires engagement at all
levels of an organization. For example, if ventilation is required to maintain a safe
environment, purchase of the equipment required to provide that ventilation is only
one piece of the sociotechnical system. There must also be adequate training of
personnel so that they know how and when to use the equipment, monitoring
of the equipment’s performance and employee’s compliance with safety protocols,
emergency response protocols in case the equipment fails, periodic auditing of the
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132 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE
protocols regarding ventilation by management to proactively identify and address
any emerging concerns or new understandings about the risk posed by a given
material, etc. These systems have been developed in response to the knowledge
that once a hazard and its risks are brought into an environment, the risk “remains,
waiting for an opportunity to happen unless the management system is actively
monitoring company operations for concerns and taking proactive actions to cor-
rect potential problems” (Amyotte et al., 2007).
Having an effective management system for process-related hazards—fire,
explosion, and toxic release—is therefore considered by many in the chemical
process industries to be a critical corporate objective. Formally, PSM is defined
as the application of management principles to the identification, understanding,
and control of process hazards to prevent process-related incidents OSHA’s PSM
standard, 29 CFR § 1910.119. Various approaches exist for PSM. One example
is the 1989 system developed by the Center for Chemical Process Safety (CCPS,
1989), which served as the basis for a 12-element system recommended by the
Canadian Society for Chemical Engineering (CSChE, 2002). More recently,
the CCPS has developed guidance on a 20-element, risk-based approach to
managing process safety (CCPS, 2007); see Table 7.1. Within the United States,
OSHA administers Process Safety Management of Highly Hazardous Chemicals
standard 29 CFR § 1910.119, which defines requirements for handling of those
materials. It consists of 16 elements, 14 of which are mandatory.
PSM AT BAYER CROPSCIENCE
As most companies do, Bayer CropScience has its own PSM system. Bayer’s
14-element system is shown in Table 7.2, with noted similarities between this
system and the CCPS-developed listing in Table 7.1.
For this discussion, Bayer’s element 4, Process hazard analysis, is most
relevant. This analysis consists of the following steps (Patrick Ragan, Bayer
CropScience unpublished material, August 8, 2011):
1. Hazard identification (using a variety of methods including preliminary
safety analysis; hazard and operability study (HAZOP); what-if review; check -
list review; what-if/checklist review; fault tree analysis; event tree analysis; and
failure modes, effects and criticality analysis (FMECA);
2. Severity determination;
3. Probability determination;
4. Risk assessment (using a risk matrix); and
5. Risk management (including application of risk reduction measures).
Within step five, the list of preventive safety measures given includes pas-
sive, active, and procedural measures for hazard control, but there is no specific
requirement to consider ISP measures.
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PROCESS SAFETY MANAGEMENT AT BAYER CROPSCIENCE
TABLE 7.1 Risk-Based Process Safety Management System
Accident Prevention Pillar Risk-Based Process Safety Element
Commit to process safety Process safety culture
Compliance with Standards
Process safety competency
Workforce involvement
Stakeholder outreach
Understand hazards and risk Process knowledge management
Hazard identification and risk analysis
Manage risk Operating procedures
Safe work practices
Asset integrity and reliability
Contractor management
Training and performance assurance
Management of change
Operational readiness
Conduct of operations
Emergency management
Learn from experience Incident investigation
Measurement and metrics
Auditing
Management review and continuous improvement
SOURCE: Adapted from CCPS (2007).
TABLE 7.2 Bayer CropScience System for PSM of Hazardous Chemicals
Focus Element
Commitment 1. Leadership and culture
2. Employee participation
Understanding risk 3. Process safety information
4. Process hazard analysis
Managing risk 5. Operating procedures
6. Training
7. Contractors
8. Pre-Startup safety review
9. Mechanical integrity
10. Safe work practices
11. Management of change
Response and corrective action 12. Incident investigation
13. Emergency planning and response
14. Compliance audits
SOURCE: Provided by Patrick Ragan, Bayer CropScience, on August 8, 2011.
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134 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE
ISP ASSESSMENTS AT BAYER CROPSCIENCE
Although claimed to be an integral PSM component, inherent safety
considerations are incorporated into Bayer’s PSM efforts in an implicit man-
ner that is dependent on the knowledge base of the individual facilitating
the particular activity (e.g., process hazard analysis or PHA). Although an
implicit system of ISP incorporation does not mean an absence of a commitment
to inherent safety, it does mean that the commitment is not visible to the extent
that could be considered desirable.
The disadvantage of an implicit system of ISP is corporate memory. The
extensive work of Professor Trevor Kletz over several decades of process safety
research, practice and writing has clearly demonstrated that organizations do not
generally have a long-term memory—at least not a memory longer than about
10 years. Corporate memory resides with individuals, and individuals retire, resign,
or otherwise move on to other opportunities. While acknowledging the value of
individual memory and active sharing of information between employees, if ISP
consideration requirements are not explicitly recorded within the suite of PSM
documentation, then such requirements may be forgotten or potentially ignored.
It would be beneficial for Bayer to formally incorporate ISP assessment into the
company’s PSM system and training and to record such assessments as part of
its audit and review processes. Doing so would provide regular opportunities to
update the assessment protocols in light of any new developments in the area.
As mentioned in Chapter 4, descriptions on how ISP considerations can be
incorporated into all elements of a PSM system are available. These include spe-
cific suggestions for training initiatives using the various ISP resources. Recom -
mendations are also given regarding compliance audits related to identification
and implementation of ISP. Both of these elements (training and audits) would
seem particularly relevant to the case of Bayer CropScience and the Institute
facility. Documented training of personnel with respect to the concept of inher-
ent safety, for example, would contribute to creating and maintaining a consistent
level of knowledge within the organization and formalize corporate memory in
this area.
In the course of reviewing the materials provided by Bayer CropScience
regarding the alternatives assessment performed by Bayer and the previous
owners of the facility and the design of the post-2008 facility redesign, it was
clear that safety considerations did come into play in the analysis. However, the
focus of the alternatives assessments and the redesign was primarily directed
toward managing the hazard rather than eliminating or reducing it, which is con -
sistent with the focus on passive, active, and procedural controls within the PSM.
Appendix B provides a detailed history of process changes that occurred at the
Institute facility, and points where ISP-type decisions were made are highlighted.
A summary of specific examples of the process changes that occurred are listed
in Box 7.1. For example, every time a significant reduction of MIC inventory
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PROCESS SAFETY MANAGEMENT AT BAYER CROPSCIENCE
BOX 7.1
Summary of Process Design Changes with Implications for
Safety at the Institute Facility Consistent with ISP Principles
• Union Carbide Company (UCC) practiced principles of sustainability in
1978 when it switched from the chloroformate process to the isocyanate
process for carbaryl production achieving higher yields, less waste, less
corrosion, and less environmental impact.
• UCC practiced passive and active safety strategies in 1978 and 1985
in the design of the MIC process featuring refrigerated underground stor
age, emergency scrubbers, and emergency flares.
• UCC followed ISP principles in its search for alternative chemistries
to MIC prior to 1985.
• UCC followed ISP principles in its focus on less hazardous MIC-
adducts in 1986 (for remote production to avoid aldisol transportation).
• Rhône-Poulenc practiced passive and active safety strategies in 1988
with MIC incinerator and carbaryl reliability optimization, and ISP prin
ciples with MIC downsizing measures (Project MN).
• Rhône-Poulenc followed ISP principles in 1989 to 1991 in the evalua
tion and design of Enichem phenylmethylcarbamate process with cracking
at remote (Project MS) or at four individual carbamate plants in Institute,
eliminating MIC storage and transport and reducing total MIC inventory for
all carbamate production to a few hundred pounds. However, this process
was not implemented.
• Rhône-Poulenc practiced passive and active safety strategies in its
1993 Institute Modification Project.
• The Rhône-Poulenc 1994 Risk Management Plan contains passive,
active, and mostly procedural safety elements.
• Bayer followed ISP principles in modeling and analyzing the opera
tional impacts of reducing MIC inventory.
• Bayer MIC Unit Layers of Protection strategy contains mostly passive
and active and some inherent safety elements.
• Bayer (Project MINEXT) practiced ISP in 2010 by closing the West
Carbamoylation Center and by reducing carbamate production to two
products and reducing MIC inventory by 80 percent, and practiced pas
sive and active safety strategies by eliminating aboveground storage, and
using doublewalled construction, steamammonia curtains, and other
measures.
• Bayer followed ISP principles in 2010 by evaluating alternative chem
istries for the production and use of gaseous (instead of liquid) MIC,
including chemistries avoiding the use of phosgene (although none was
evaluated to be competitive or timely in the present business environment).
• Bayer also followed ISP principles in 2010 by substituting a non-
reactive material for brine in the MIC storage tank refrigeration systems.
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136 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE
occurred, one aspect of the philosophy of ISP (reduction) was implemented, even
if that term was not used.
Since ISP was not a formal consideration for the facility’s owners, the
committee finds that the managers of the facility in Institute missed opportuni -
ties to perform full safety assessments. Bayer CropScience did perform PSM
assessments, however, Bayer and the legacy companies did not perform
systematic and complete ISP assessments on the process for manufacturing
MIC or the processes used to manufacture pesticides at the Institute site.
Bayer and the previous owners performed various hazard and safety assess -
ments and made certain business decisions that resulted in MIC inventory
reduction, elimination of aboveground MIC storage, and adoption of various
passive, active, and procedural safety measures. However, these assessments
did not incorporate, in an explicit and structured manner, the principles
of minimization, substitution, moderation, and simplification. The legacy
owners identified possible alternative methods that could have resulted in
a reduction in MIC production and inventory, but determined that limita-
tions of technology, product purity, cost, and other issues prohibited their
implementation.
ISP ASSESSMENTS—EXTERNAL CONTEXT
Because Bayer implicitly uses ISP practices and principles within their PSM
system (e.g., reducing inventory of MIC and acknowledging the safety benefit
drawn from that), it is a useful exercise to consider what incentives could exist
for the explicit incorporation of ISP assessments into the PSM system. Indeed,
within the industry broadly, there are barriers to the formal consideration of ISP
including the perception that inherent safety is impractical, or costly, that there
is a lack of institutional infrastructure and frameworks for evaluating inherently
safer processes, and a lack of standards and guidance measures for existing opera-
tions (CCPS, 2008). The purpose of this section of the report is not to endorse one
method or another for encouraging the adoption of ISP. Rather it is to provide a
brief overview of possible drivers and barriers to formal, explicit consideration
of ISP by a company.
One possible mechanism for overcoming these barriers is through profes -
sional standards within the field of chemical engineering. Inherently safer pro-
cess assessments are a valuable component of process safety management.
However, as noted in Chapter 4, at this time the view of what constitutes an
inherently safer process varies among professionals, so the chemical industry
lacks a common understanding and set of practice protocols for identifying
safer processes.
Externally, industry standards could affect the formal incorporation of ISP
into PSM. It is clear that companies look to professional organizations, such as
CCPS, for guidance on these issues. Alternatively, were ISP to be incorporated
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PROCESS SAFETY MANAGEMENT AT BAYER CROPSCIENCE
into the standards of the American Chemistry Council Responsible Care Pro -
gram, for example, it would likely encourage adoption of ISP concepts into PSM
methodologies.
Of course, regulatory policy could drive companies’ adoption of ISP analyses.
In Chapter 4, Box 4.1 presented definitions of ISP, including two drawn from regu-
latory policy initiatives within the United States that require consideration of ISP.
In reviewing those policies, it is clear that the link between ISP strategies and the
framework set down by cleaner production and pollution prevention regulations is
seen as a starting place for considering the role of ISP in context (Zwetsloot and
Ashford, 2003). It is important to remember, however, that the effective implemen-
tation of ISP relies on the awareness of the professional, technical community, and
studies (Wilson et al., 2008; Copsey, 2010) have highlighted the need to improve
links between workforce preparation and industry knowledge of inherently safer
strategies for risk reduction.
In the United States, companies are required to have PSM systems in place
for handling of highly hazardous chemicals. However, the elements of OSHA’s
PSM (29 CFR § 1910.119) standard do not require any explicit consideration of
ISP. Rather the requirements accept the presence of a hazard, and the risks that
may come with its use, and are thus directed to the tiers of the PSM hierarchy
geared toward control and management of the hazard and its risk rather than
elimination of the hazard itself. The PSM elements required by OSHA were
presented in detail in Chapter 2 and are listed in Table 7.3.
The U.S. Environmental Protection Agency (EPA) policy has considered
the possibility of inherent safety at least since the early 2000s, but measures
regarding chemical accident prevention have tended to focus on prior planning
and “inspection and . . . corrective and preventive maintenance.” (Ashford and
Zwetsloot, 1999). Therefore, the concept of safety planning is far from new, but
TABLE 7.3 Fourteen Required Elements of OSHA’s PSM Standard
• Process safety information,
• Process hazard analysis,
• Operating procedures,
• Employee participation,
• Training,
• Contractors,
• Pre-startup safety review,
• Mechanical integrity,
• Hot work,
• Management of change,
• Incident investigation,
• Emergency planning and response,
• Compliance audits, and
• Trade secrets.
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138 USE AND STORAGE OF METHYL ISOCYANATE (MIC) AT BAYER CROPSCIENCE
the far-reaching ramifications of ISP appear to require a greater degree of plan -
ning and technological investment than do traditional safety strategies that tend
to be “failsafe” rather than “foolproof.” (Ashford and Zwetsloot, 1999).
The difficulties of implementing ISP also can be observed in the EPA Risk
Management Program (RMP) (EPA, 2001), which is still intentionally more
oriented to risk management than risk prevention (Malloy, 2008), and as a policy
matter does not mandate ISP. Nevertheless, companies dealing with hazardous
chemicals must develop accident prevention plans during hazard emergency
response planning, but this policy does not extensively involve stakeholders out-
side of firms (CCPS, 2009).
Other pertinent regulations and laws include the Pollution Prevention Act
(PPA), which is not primarily directed at accidents (Ashford and Caldhart, 2010),
and the Department of Homeland Security’s Chemical Facility Anti-Terrorism
Standards (CFATS) (Malloy, 2008). The post-September 11 approach is particu -
larly amenable to ISP (CCPS, 2009), because the unpredictable nature of terror-
ist attacks may create challenges for traditional assessments based on internal
production risks. However, regulatory bodies have tended to conclude that ISP
shift rather than prevent risks (Malloy, 2008). This is an important critique that
warrants further research, because of the possibility that inherently safer technol -
ogy may lead to the reallocating of risk to other areas of the production process
(Hendershot, 2010).
The previous paragraphs were a brief overview of the policy context for ISP.
More information, including international initiatives, can be found in Appendix D.
Finally, in regard to the perception of cost barriers to ISP, it is important to
recognize that for most established manufacturing processes, the materials in use,
whether hazardous or not, are cost competitive, and shifts to lower risk technol -
ogy or process design can involve costs and uncertainties for companies (CCPS
2009). This being the case, these cost issues, and/or the perception of them,
present a major practical barrier for industry to adopting safer processes ( Malloy,
2008). However, greater production stability associated with inherently safer
technology may lead to “greater reliability of production” and operations econo -
mies (Ashford and Zwetsloot, 1999; Malloy, 2008), which, if applicable, can
be seen as an overall benefit to the company. As discussed earlier in this report,
however, the costs associated with redesigning an existing facility mean that the
barriers posed by these costs will be much lower when incorporated into an initial
design or as part of a planned, significant modification of an existing site.
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