Energy Industry Insights

EG Webinar - Safety First: Navigating Process Safety Management in 2024

by EnergyGigs
Feb 1, 2024
TABLE OF CONTENT
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Join us for an insightful webinar featuring Jason Assir from Energy Gigs and Katherine Culbert, the founder and CEO of K&K Process. In this webinar, they will delve into the critical world of Process Safety Management (PSM). Katherine will share her extensive experience in process safety and discuss its importance, historical context, and applications across the energy sector, including the emerging hydrogen economy.

Jason Assir: Good afternoon, everyone my name is Jason Assir. I'm with Energy Gigs.

Jason Assir: And we're joined with Katherine Culbert, the founder, and CEO of K&K Process. We're gonna start in a minute or two. But before we do that, I just wanna quickly talk about Energy Gigs real quick, and then turn it over to Katherine. Who's our guest? She's an expert in process safety, and also running for Rail Commissioner here in Texas. So she's got a lot of really interesting insights around process safety and safety more broadly. It's January, so it's a good time to talk about safety as you think about your operations for the rest of 2024. For those that are new to Energy Gigs, we are a talent platform. We connect energy professionals and experts to energy companies that look to hire them, either through consulting engagements, full-time job opportunities, or attempt to perm placement. We have a platform like Upwork, but for the energy industry. But we also provide offline services to companies that are looking for that sort of support.

Jason Assir: Without further ado, I'd like to introduce you guys again to Katherine Culbert. Catherine, thank you so much for joining us on our very first webinar of 2024. You have tons of safety experience, and you have a specific focus on Process safety. If you don't mind telling us a little bit about yourself, and I know you have a little bit of a presentation you wanna kind of start us with.

Katherine Culbert: Absolutely. Yeah, thank you, Jason. And you know, thank you for having me. I'm excited to start this year with safety, and January is a great time to talk about safety, and so is every other month. It's always important to make sure that that's at the beginning of everything. So I just wanna quickly start with, you know, most meetings start with a safety moment. As you mentioned, I am a process safety expert, so slightly different. And we'll talk a little bit about that, but I wanted to start with a process safety moment before we get into the weeds here.

Katherine Culbert: So one thing to think about is your process safety information. So all of those things like drawings and design details and calculations, and all that sort of good stuff that goes into your facility. Think about where that's kept. Is it accessible by everyone that needs to see it? When they need to see it? And is it also safe from hazards, such as flooding or fires? Sometimes people will keep hard copies, which can be okay. But then, you know, you need to think about, is this my only controlled copy? Where are the rest of them? Or do we keep them all electronically? And then do we have a backup system for, you know, what happens if the network goes down, but the guys in the facility still need to access a P&ID or something like that. So just things to think about as you're going through your day. Think about all of your information that you've got and where it's stored, and how accessible and how safe it is.

Katherine Culbert: So going on, Jason, as you said, to give a little intro about me. I live in Houston, and I am a professional engineer. My license is in New York, which is where I grew up and where I started working. I also have a Project Management Professional certification from PMI, and that's not specific to engineering nor the energy industry. It's a general project management certification. I currently work for a major oil and gas company as their senior process safety engineer, and as you mentioned, I also own and operate K&K Process, and we are a pipeline and process safety consulting firm. And, as you mentioned, because that doesn't keep me busy enough, I'm also running for a position on the Texas Railroad Commission this year. There are 3 Commissioners, and one is up every 2 years, and for those that aren't familiar with the Texas Railroad Commission, it has absolutely nothing to do with railroads, even though its name is the Railroad Commission. And it's all about energy and oil and gas regulation. So something that I know a little bit about, and definitely am looking forward to campaigning this year.

Katherine Culbert: I also like to be involved in my community. A lot of people ask, oh, what do you do in your free time? Not that I have a lot, but in my spare time, I like to volunteer. I like to know what's going on in my community and help out. If you ran the Houston Marathon a couple of weeks ago, you might have seen me out there. I've been out on the course for the last 8 years as a volunteer, and I also am a volunteer with the League of Women Voters. I think voting is extremely important, and I've co-chaired their Voter Helpline at KPRC for the last few years. So you may have seen me flash across your TV on election day.

Katherine Culbert: And a little about K&K Process. We were founded in 2016, and you may wonder, K&K, there must be another K. There is. I founded the company with a business partner, but he has since left the company, and I've continued on with the operation. We work with companies in all different industries, not only energy. But the big thing that we work with is companies that have highly hazardous chemicals, so it could be oil and gas, it could be petrochemicals, it could be food and beverage, it could be fireworks, that's another one that a lot of people don't really think about, so most industries have an aspect of hazardous chemicals that our work applies to. So we can go in many different industries.

Katherine Culbert: So let's see, so a little about the industry. I want to share very quickly, let me get my right thing here. Just quickly, I wanna give a background on process safety, the worst industrial disaster which many of you may have heard of. Hopefully, you have. It's generally accepted that Bhopal, India, which happened in 1984, and to give a little background on this, you'll see a picture there of the remnants of the plant. It was overnight in December, in 1984, and a large amount of water had entered a tank that was supposed to be, you know, not really in service. It was kind of waiting to get rid of the chemical that was in it. It had methyl isocyanate in it, which is also known as MIC. And when this water entered the tank, it caused a reaction which they obviously were not expecting. And with that reaction, the tank began to overpressure. So what happened? They did have an emergency vent on the tank which opened, which is what it's supposed to do, however, that released large volumes of toxic gas to the atmosphere, and the cooling and the flaring systems that were on that vessel were inoperable at the time. So the emergency vent was the only thing protecting that vessel.

Katherine Culbert: And so, as it kept releasing, there was a poisonous gas mixture that covered the entire city of Bhopal. And you may think, oh, you know, right, if we have a chemical release like in Houston, you know, it happens regularly. But Bhopal was more of a tent city at the time. So people couldn't turn off their HVAC systems, or they couldn't, you know, go inside and shelter. They were basically in tents. So they had this poisonous gas that exposed more than 500,000 people almost instantaneously. And over 2,000 people died immediately that night. Over 8,000 more died within 2 weeks, and there are still people, you know, who have issues that we think are linked to the Bhopal incident that, you know, maybe we'll never know. So this was really the beginning of PSM.

Katherine Culbert: And so, because of what happened in Bhopal, and, you know, kind of looking at other industrial incidents that have happened, the general public and Congress both pushed OSHA to develop what they call their Process Safety Management rule, which they developed in 1990. Remember, Bhopal was in 1984. OSHA didn't actually come out with a rule until 1990, and then they finally published it as a standard in 1992, and enforcement started in 1997. So there was a long time there where we didn't really have a standard or anything to hold industry against.

Katherine Culbert: So now it's known as the PSM standard. And if you want to find it, it's in the Code of Federal Register. It's 1910.119. So a lot of times you'll hear people talk about that. So it's part of the OSHA standard, and it really describes requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, explosive chemicals, you know, something that could release could result in something like Bhopal or a fire or explosion. You know, a lot of people, especially here in Texas, know about the West Texas fertilizer plant. You know, that's another one that was should have been covered under the PSM standard and wasn't. There have been a lot of incidents out there that have led to the development of this PSM standard.

Jason Assir: After, and just a quick question on that, so particularly with the fertilizer and sort of at top of mind? Are there instances with new developments, new technologies, new chemical processes, or manufacturing capabilities where they don't... they're not perceived to belong to PSM safety regulation, and so but then some incident happens, it's like, oh no, it should have been. Is that kind of how it's been occurring?

Katherine Culbert: Yeah. So, you know, the PSM standard came out like I said in 1992, finally as a final rule, and it hasn't been updated since. So there have been, you know, new uses of chemicals, new chemicals that have been developed. And, you know, as something happens, unfortunately, right, as there is an incident, like in West Texas, then OSHA says, oh, maybe we need to add a few more chemicals. So the PSM standard right now is currently under revision. However, it takes like 8 or 9 years to revise these standards. So it's not happening anytime quickly. But they are looking at expanding the chemicals that are covered, the types of facilities that are covered. So there will be a little more... You know, there will be some change, and there will be some new stuff that's covered there.

Jason Assir: Okay, no, thank you.

Katherine Culbert: So just to give you an idea of PSM, we like to use the Swiss cheese model, which, you know, you don't want all your holes on your Swiss cheese to line up. And so you have a hazard out there that you know of, right? And then you've got things like engineering controls, administrative controls, behavioral controls that will hopefully try to prevent an incident from happening. And if by chance all those holes line up and there is an incident, there's also mitigating barriers that are involved in PSM, to try to minimize the consequences.

Katherine Culbert: So that's kind of the background on PSM. If you do look at the regulation, there are 14 different elements. I'm not gonna go through all these right now, but just so you can, when you go and look up the standard, you can see that there is a description of each of these elements, and you know how they kind of play into the whole big picture of PSM compliance.

Jason Assir: It looks like we do have a question from one of the attendees. This is a question that kind of relates to geothermal. The question is, how can we apply your experience with hazardous chemicals to handling of high temperature geothermal brines?

Jason Assir: So I guess if you're drilling into a geothermal well, the brines have different gases, and...

Katherine Culbert: They do. Yes, and they have a lot of toxic gases. And so it's interesting you ask that question because oil and gas drilling is one of the areas that OSHA is looking to expand into when the PSM standard originally came out. They excluded oil and gas drilling with the intent that the industry itself would kind of self-regulate and would be developing its own standard. And for those of us in the drilling area, we know that that hasn't really happened. So that is one area that OSHA is looking to expand into. So right now, as far as using the PSM tools, if you will, there's definitely the ability to look at, you know, if you look at these 14 elements, there are different ways that you can apply them to things like drilling, and like the brine that comes out of wells, and you need to look at, you know, what is your overall system? Do you have a system in place? Do you have, you know, emergency planning and response definitely, a big one. When you're dealing with those types of hazards. You know, I know in some of those brines there's benzene's, and you know all sorts of different other chemicals, too. So you need to make sure that you plan that in advance. Employee participation is, I'm gonna say, that's a really big one right there.

Katherine Culbert: I know a lot of our folks out in the oil patch have a lot of experience. And they know what's gonna happen. And they can really help you develop a process so that you can operate more safely. Mechanical integrity definitely a big one with wells. You know, with all the casing pressures and all that sort of thing, making sure that all the valves are operating correctly, that all the casings are integral there, and not, you know, blown out and releasing things subsurface that sort of stuff. So there are a lot of the same elements within the PSM that you can absolutely apply to things like drilling. And and those wastes that come out of the process.

Jason Assir: We have another question. Can you talk us through how to overcome challenges of translating process safety management into operational practice or execution?

Katherine Culbert: Yeah. So one thing, you know, process safety. If you look at these 14 elements, you can see that they kind of touch on a lot of different things, right? It's not just one aspect of a process. You know, we deal with training. We deal with pre-startup hazard review and safety reviews, operating procedures, all that stuff. So as far as pulling this into operations. It's really it needs to be a synergy of, hey, we need somebody from the top, probably saying we're gonna do this so that there's support. But then, like as a process safety engineer, I work with our Operations department on a daily basis of hey, what's going on here, you know, we had an incident or not even an incident. We had a, for instance, something shut down, right? We had a high pressure, something on one tank and it shut something down. Okay, let's look at that and see what happened.

Katherine Culbert: You know, there's a lot of comparison between process safety and occupational safety, and I know a lot of people in occupational safety have heard of Heinrich's Triangle, where, you know, a lot of the little things like the slips and the trips and the falls, and the, you know, dropping things but not hitting anybody, and all that. Those all add up eventually to something big happening, right? And someone getting really hurt, or possibly a fatality. And it's the same with PSM, so if you have a lot of like little spills, things like that, you know, those can be indicative of something bigger is gonna happen. And, you know, if you have a lot of those little things happening, what, maybe we're gonna have a big spill, and maybe it's gonna lead to, I mean, I don't wanna say it, but, you know, it could lead to something like a Macondo, right? That's our big top of our triangle that we don't want to happen. So if we can start looking at all of those little things that are happening and really, you know, from a process safety standpoint, work with operations to investigate those. And hey, let's fix it, right?

Katherine Culbert: You know, oh, there's been a lot of corrosion under insulation at this one plant. Well, let's look at that. Let's figure it out, and let's fix the root cause of that rather than just, oh, we need to, you know, change this little section of pipe and put new insulation on, right? Like, so it's gonna happen again. So process safety really needs to work hand in hand with the Operations department to help them see things, cause a lot of times, you know, I mean, I work with a lot of guys who've been doing this a whole long time, right? Like they've been out in the field, they've been out on a rig, for, you know, 40 some odd years. And what do I know coming out there to tell them this and that, and you know. But it really, you need to be able to work with them and talk with them and help them see that, hey, maybe this week you're having is gonna lead to something bigger. Let's fix the whole root cause of it now, so that we know that you're going home at the end of your hitch.

Jason Assir: Yeah, I mean, I've heard, I remember when I worked in well containment, there was always an emphasis by the leadership of the company to try to cultivate a culture of safety cause? I mean, can you talk a little bit about like what? What is what, how does culture play into the elements, I mean is that part of the 14 elements? Or is that sort of the glue that binds it all like?

Katherine Culbert: Yeah. So culture is kind of the, I don't know if you wanna call it the umbrella that oversees it, you know, is over everything, or if it's the floor that's holding everything up. But again, it goes back to hey, we had a, you know, a pinhole leak on this pipe? What are we doing to fix the root cause, or is it? Oh, well, just fix it and move on with life, right? And those are 2 very different cultures. It's a hey, let's just, you know, Band-aid everything. And we just need to keep running, or it's a hey, we really need to look at this and make sure that we're operating safely. And again, it comes from the top right of, you know, are we gonna stop production for, you know, an hour so that we can investigate this? Or are we gonna just keep pushing through and pushing through and pushing through and cross our fingers, and hope that something bad doesn't happen.

Jason Assir: Yeah, makes sense.

Jason Assir: Very, very cool. I, I know, like our the community that we serve, and the members and the users on our platform. They, you know, it's a 2-sided marketplace in some ways, right? We have the companies that hire consultants, and then the consultants are the experts themselves. And you know, we have a lot of people coming into the energy industry, you know, and I'd love to understand like ha! What got you into the into process safety like, what was it that drew you into it? And...

Katherine Culbert: Yeah. So I was working as a for consulting firm in my first engineering job, and they were looking to diversify a little, and they got a contract with, you know, one of the local plants and needed somebody to go and do relief valve calculations, and I was low man on the totem pole. So they sent me. And you know that that was really my first introduction to process safety. But I really fell in love with it like it's really a proactive approach to industry and to life. Really, right like. I mean it. It's horrible. I can't go anywhere without, you know. Is that really a safe thing that we're doing? Or should those kids be climbing on that, or you know it. It's a lot of thinking ahead, and being proactive and trying to prevent incidents before they happen. So it's become kind of, you know, central to my life, I guess. You know, rather than reacting to things. I like to be proactive and think about things beforehand. So yeah, I think, definitely having an engineering background helps tremendously. Like, I said earlier, you know, I have to deal with a whole lot of people across the company. So it helps that I can talk the engineer's talk. I can. You know, I work with operations. I can talk their talk. I can, you know, sometimes I have to deal with legal. You know this. This is a regulatory requirement. So you need to be able to talk their talk, too, right? You know, and talking with operations versus talking with the legal department are very different conversations. I can only imagine like use of different words, I think is like, gotta put it nicely, I guess. Probably. Yeah.

Jason Assir: Well, II in terms of like if if if I'm in college now, or if I'm in a community college or I'm just graduating high school like, and I wanted to, I'm intrigued by safety and process safety like, what? What would you recommend? Or education paths for for me?

Katherine Culbert: Yeah. So really, any engineering is a great educational path. I mean, I'll stop that from the rooftops. That engineering has not led me wrong. As I wanna yell at my mother for making me go into engineering. I think it's definitely served me. Well, as far as process safety. There's also through AICHE, the American Institute of Chemical Engineers. They have a Center for Chemical Process Safety. So you can go to their website and look that up. And they have all sorts of classes, trainings, and you know, hands-on type stuff. That you can. They have boot camps. They've got, you know, how to develop a program. They've got all sorts of things. So that's a great place to start. And then just industry in general. Right? If you're interested in, you know, like I'm sure a lot of the folks here are energy folks, and if you're interested in that, then get involved in another networking, you know, an energy networking group, you know, things like like I said the AICHE, they've got a global congress on Process Safety happening in New Orleans in March. There are other things like the American Petroleum Institute or Texas Chemical Council. There's things all over and a lot of safety conferences right? If you look for any sort of safety type conference, they, a lot of them, will have a process safety component. You know, one of the tracks on the conference. That sort of thing. So you can always kinda go to one of those and see like, Hey, is this something that that I'm interested in.

Jason Assir: Okay, no, that's great. and...

Jason Assir: With the field sort of continuously evolving like, how have you sort of kept. You know, kept your your saw sharp, so to speak. You know, in terms of what? Where the industry is going.

Katherine Culbert: Yeah, it's really, I think a big one is that that Center for Chemical Process Safety. They they definitely communicate quite well attending conferences. And you can also set up notifications from the Code of Federal the Federal Register that anytime OSHA makes an update regarding PSM, you'll get an email, which is which is definitely a helpful thing. So you kinda know what the regulators are doing and what they're dealing with. So you can be aware of that cause. They have to publish everything and then give, you know, a 60-day comment period, and and and that sort of stuff. So there's a lot of time to kind of do your research as to what's happening. And then another good source is the Chemical Safety Board. They. They're headquartered in DC, and they do a lot of the incident investigations. And they do amazing reports, and videos and all sorts of great things to really show what happened and why they're recommending changes, whether it's to the PSM standard, whether it's to industry, whether it's just to a specific facility or manufacturer. So...

Jason Assir: We actually just got another question from an attendee. This is sort of related to the energy transition or new energies. Have you seen an increase in PSM conversations as it relates to the development of the hydrogen economy?

Katherine Culbert: Yeah. So hydrogen is a covered chemical. So it is covered under the PSM umbrella. I haven't been that involved in the hydrogen space. So I haven't, you know, really seen a lot of that. But I'm sure it's happening, you know, again, going to those hydrogen conferences, which is not something that I have been attending. But I'm sure that they have, you know, information on process safety and it. And like, I said, it is covered. So they're gonna have to be aware of this regulation. And what's going on with it.

Jason Assir: Last year we went to a number of conferences where hydrogen was sort of the darling of the ball, and many in many of these conferences. And but one thing we didn't hear a lot of conversations or see any innovation around is like the safety around hydrogen or the risks associated with moving hydrogen, you know, or, you know, related chemicals like ammonia or other. You know. I mean, what are your thoughts on that? And where where is that going like?

Katherine Culbert: So it that kind of goes on the pipeline side of things, I would say, and PHMSA, which is under the DOT regulates pipelines. Although here in Texas, if it's intrastate, it's regulated by the Railroad Commission, which is so. Yeah. So we really need pipelines can be a very safe way to transport materials. However, they also have evidence of leaking, and they, you know, have catastrophic spills and such. So they really need to be regulated well, and made sure that they're being taken care of. And, you know, II no company wants to do bad. No company wants to have, you know, a major spill. Unfortunately, however, they happen so. We just need to make sure that those regulations are staying up to date. And and it's tough when, you know, like PSM standard, it's taking 8 years to update the standard, right so. And it's the same thing with with the PHMSA pipeline safety standards right like that. That right now is still it's not mandatory. So you know there, there's a lot of stuff out there that can be done. And you know it. Just we need to make sure that we're doing that, and that we're following those regulations, and that we're again being proactive. That that's the big part of it is. Don't wait for an incident to happen to say, oh, maybe I should have you know, you need to think about that beforehand. So that we can prevent those from happening in the first place.

Jason Assir: Well, II think after we're we're at time. I I you know it always goes by so quickly. These webinars. II really do want to thank you for for sharing your insights about process safety talking about your background, and you know, helping us understand a little bit more about process safety. I mean thinking about the next year. Obviously, you have a lot of things going on this year. But, like, what are you looking like in terms of the industry. Like, what? What? Final thoughts on process safety in 2024 like? What do? What do you see? What are you expecting or hoping for?

Katherine Culbert: Yeah, I mean, II was kind of hoping the OSHA would come out with their new regulation. But I was just out of a webinar with with someone from OSHA last week. And I don't think it's happening. But yeah, I think just more awareness of it and more more companies that really are looking to do good. To really follow this this PSM standard. Not just, you know, the minimum. But hey, let's do even better than the minimum. So that we can, we can really show that we are a good industry, and that we're here to help protect people while still, you know, being a viable economic driver.

Jason Assir: Gotcha. Well, I you know, we may have some companies that are be interested in talking to you. So we're gonna we're gonna send the the show notes if you will. After after this we'll include your contact information if you want or not. Well, thank you again, Katherine. So much for sharing your time. Thank you. All of our attendees. We're going to this this call has been recorded, and so we're going to post it on our on our Youtube channel, and then we'll send an after action through notes about about the the topics that we discussed, and as well as contact information for Katherine. If you wanted to reach out to her directly. Thank you again, everyone, and we'll look forward to seeing you guys next month at our next webinar.

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