Canadian Biomass • Spring 2021 • What you don't have, can't leak

What You Don’t Have, Can’t Leak,” is the title of a 1978 article by Trevor Kletz (1922 - 2013), a pioneer of Inherent Safety Design. He paved the way for a safer industry and for new trailblazers, including people like Kayleigh Rayner Brown, P.Eng., M.A.Sc., a research associate at Dalhousie University in Halifax, N.S. Kayleigh has worked in the nuclear, petroleum and aerospace manufacturing industries and, having completed a Master’s in process safety, is now leading hazard analyses in the pellet sector.

I have the honour of working with Kayleigh on the Critical Control Management (CCM) initiative currently being rolled out across Wood Pellet Association of Canada (WPAC) member facilities in British Columbia, in partnership with the BC Forest Safety Council (BCFSC). It will be a safety game changer for our industry.

I recently sat down with Kayleigh to learn more about process safety and how we can apply it.

ISD is based on four principles: minimization, substitution, moderation and simplification. Basically, it focuses on removing hazards so you don’t need to deal with them in the first place, rather than relying on extra equipment and procedures to be protected.

At a pellet plant level, it could be using equipment that contains dust so it can’t escape and accumulate elsewhere. So, it’s really about getting rid of the problem ahead of time.

Without ISD, we are opening industries to higher frequencies of Major Unwanted Events (MUE). One of the most tragic examples of this is the Bhopal gas tragedy. It happened at a pesticide plant in 1984 and more than half a million people were exposed to methyl isocyanate (MIC) gas and nearly 2,500 people died.

It was entirely preventable. They could have used a different manufacturing process or not have stored the chemical. On top of that, the installed safety devices weren’t working properly.

I grew up in a family who owns a fourthgeneration logging business in Nova Scotia, so safety is a core value for us. I became an engineer because I’m interested in learning about why things are the way they are and how to make things better. Engineering makes me feel empowered to make a difference. While my expertise lies in ISD and bow tie analysis, I know that safety is about people as much as it is about science!

You use your Process Safety Management (PSM) system to manage hazards and implement safeguards and controls.

Inherently safer design is part of PSM and can be used to eliminate the hazards, so you are starting with a safer facility but you can still incorporate ISD in an existing facility by making changes.

Another important component of PSM is CCM, which helps us identify and manage our critical controls. With the CCM in place we can assign accountabilities and a monitoring system to ensure those critical controls are managed.

It is an organization’s all-encompassing program to ensure that people, property, the environment, and business operations are protected from loss-producing incidents. It includes a broad range of elements, from hazard analysis to safety culture to key performance indicators, which all work together to achieve safer operations, and includes all levels of a plant from leadership to the frontline workers.

For decades, we relied on the traditional approach to occupational health and safety where it looks at the responsibilities of workers and having a safety program in place. Process safety goes beyond that and tries to anticipate how all the processes interconnect and what could go wrong.

The fact is, you can be as personally safe as you want and wear all your PPE (personal protective equipment), but if the underlying process is not safe, you can still have a disaster like Deepwater Horizon.

Absolutely! For example, moving dust collectors from inside a building or envelope to the outside. Another good example is, instead of minimizing hot work, what if we avoided it altogether and removed the ignition sources?

Are these types of actions being tracked and reported? Are there any leaders in ISD that stand out for you?

Yes, Contra Costa County in California. First, the Industrial Safety Ordinance (ISO) regulated facilities in the county in 1998. Facilities must communicate how they are incorporating ISD. This reporting is helping to expand our understanding of how ISD is being implemented and gives examples of how ISD can be applied in operating facilities, which has led to impressive safety improvements in the county.

Since 1998, there has been a downward trend in their loss producing incidents over the past 20 years.

The project I’m working on, along with Eric Brideau and Dr. Paul Amyotte, is “Inherently Safer Bow Ties for Dust Hazard Analysis,” under an Innovation at Work (IAW) grant funded by WorkSafeBC. As part of WPAC’s and BCFSC’s Critical Control Management initiative, I am leading bow tie workshops for wood pellet facilities to develop bow ties for the hammer mill, pelletizer, baghouse and silo storage. Now, Eric and I are examining these bow ties and identifying ways to incorporate ISD.

It’s basically a visual tool that shows how a hazard could lead to a dangerous event like an explosion or fire. The Major Unwanted Event is the knot in the middle. The rest of the elements of the bow tie aid our understanding of safety because it allows us to assess how dangerous situations may arise and determine what controls we need to have in place in order to manage this risk.

In an example of combustible dust in a hammer mill, which could lead to a dust explosion, we first need to understand how this could happen and how it could be prevented. We consider ignition sources, including prevention barriers such as rock traps and hot work programs.

Next, we think about what the consequences of a dust explosion would be and how they might be mitigated. We consider negative consequences, like harm to people and equipment, and examine mitigation barriers like emergency response plans and water deluge systems.

It’s really important to look at how prevention and mitigation barriers degrade and fail and how we can improve those efforts by practicing emergency drills and scheduling preventative maintenance for safety equipment.

So far, we’ve completed workshops at two facilities. Each workshop is five hours a day for a week. Because of the pandemic, I’ve had to lead them virtually, but the uptake has been great. The workshop teams include people with diverse knowledge bases and across all levels of leadership. BCFSC safety advisors Bill Laturnus and Tyler Bartels provide on-site and online support.

I think when organizations are approaching safety with an inherent safety mindset, including when people are building facilities, or looking at management change or doing incident investigations or other opportunities they have to explicitly and routinely incorporate inherent safety design. And, of course, working with the other elements of process safety management, towards the ultimate goal of reducing the frequency of severe incidents.

Gordon Murray is the executive director of the Wood Pellet Association of Canada.