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Process Safety Management at Bayer CropScience

All safety assessments and practices exist within the context of an organization, 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 operates 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 organizations, 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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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 131

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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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133 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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135 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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137 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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139 PROCESS SAFETY MANAGEMENT AT BAYER CROPSCIENCE REFERENCES Amyotte, P. R., A. U. Goraya, D. C. Hendershot, and F. I. Khan. 2006. Incorporation of inherent safety principles in process safety management. Pp. 175-207 in 21st Annual Center for Chemical Process Safety International Conference on Process Safety Challenges in a Global Economy. New York: American Institute of Chemical Engineers. Amyotte, P. R., A. U. Goraya, D. C. Hendershot, and F. I. Khan. 2007. Incorporation of inherent safety principles in process safety management. Process Saf. Prog. 26(4):333-346. Ashford, N., and C. Caldhart. 2010. Government regulation of environmental and occupational health and safety in the United States and the European Union. Chapter 30 in Occupational and Envi- ronmental Health: Recognizing and Preventing Disease and Injury, 6th Ed., B. S. Levy, D. H. Wegman, R. Sokas, and S. Baron, eds. Oxford, UK: Oxford University Press [online]. Available: http://hdl.handle.net/1721.1/55358 or from http://18.7.29.232/bitstream/handle/1721.1/55358/ Chapter-30%20_GovRegOfEnvl%26OccH_9Feb10.pdf?sequence=1. Ashford, N., and G. Zwetsloot. 1999. Encouraging inherently safer production in European firms: A report for the field. J. Hazard. Mater. 78:123-144 [online]. Available: http://dspace.mit.edu/ bitstream/handle/1721.1/1582/ISPRA.pdf?sequence=1. CCPS (Center for Chemical Process Safety). 1989. Guidelines for Technical Management of Chemical Process Safety. New York: American Institute of Chemical Engineers CCPS. CCPS. 2007. Guidelines for Risk Based Process Safety. Hoboken, NJ: John Wiley & Sons. CCPS. 2008. Guidelines for Hazard Evaluation Procedures, 3rd Ed. Hoboken, NJ: John Wiley & Sons. CCPS. 2009. Inherently Safer Chemical Processes: A Life Cycle Approach, 2nd Ed. Hoboken, NJ: John Wiley & Sons. Copsey, S., ed. 2010. Mainstreaming Occupational Safety and Health into University Education. Luxembourg: European Agency for Safety and Health at Work, Publications Office of the Euro - pean Union [online]. Available: http://osha.europa.eu/en/publications/reports/mainstream_osh_ university_education. Accessed: Oct. 3, 2011. CSChE (Canadian Society for Chemical Engineering). 2002. Process Safety Management, 3rd Ed. Ottawa, ON: Canadian Society for Chemical Engineering. EPA (U.S. Environmental Protection Agency). 2001. Hazardous Materials Emergency Planning Guide. NRT 1. National Response Team, U.S. Environmental Protection Agency. July 2001 [online]. Available: http://www.epa.gov/oem/docs/chem/cleanNRT10_12_distiller_complete. pdf. Accessed: Oct. 3, 2011. Hendershot, D. C. 2010. A summary of inherently safer technology. Process Saf. Prog. 28(4):389-392. Malloy, T. F. 2008. Of natmats, terrorism, and toxics: Regulatory adaptation in a changing world. UCLA J. Environ. Law & Policy. 26(1):97-127. OSHA (Occupational Safety and Administration). 1992. Process Safety Management 29 CFR 1910.119. Wilson, M. P., M. R. Schwarzman, T. F. Malloy, E. W. Fanning, and P. J. Sinsheimer. 2008. Green Chemistry: Cornerstone to a Sustainable California. University of California, Berkeley [on- line]. Available: http://coeh.berkeley.edu/greenchemistry/briefing/ or www.coeh.ucla.edu/green chemistry.htm. Zwetsloot, G., and N. Ashford. 2003. The feasibility of encouraging inherently safer production in industrial firms. Saf. Sci. 14(2/3):219-240 [online]. Available: http://dspace.mit.edu/bitstream/ handle/1721.1/1581/Feasibility.pdf?sequence=1.

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