PT Notes
CSB Recommendations on SIMOPs to OSHA and CCPS
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The U.S. Chemical Safety and Hazard Investigation Board (CSB) recently made recommendations on the need to address the hazards of simultaneous operations (SIMOPs) in process facilities. SIMOPs involve the conduct of two or more operations that occur together at a time and place, and may interfere with each other, increase the risk of either activity, or introduce new risks to one or more of the operations.
The CSB recommendations arose from their investigation into the November 2020 hydrogen chloride release at the Wacker Polysilicon North American facility in Charleston, Tennessee. The release resulted in one fatality and three other workers sustained serious injuries. It was caused when a worker applied excessive torque to flange bolts on a heat exchanger outlet pipe containing hydrogen chloride, causing the pipe to crack and release hydrogen chloride. When the incident occurred, other workers were performing an unrelated task nearby. There was no coordination of the simultaneous operations.
The CSB recommended that the U.S. Occupational Safety and Health Administration (OSHA) promulgate a standard or modify existing standards to require employers to ensure the coordination of SIMOPs involving multiple work groups, including contractors, and include requirements in the standard for employers to ensure:
- Identification of potential SIMOPs
- Identification of potential hazardous interactions
- Evaluation and implementation of necessary safeguards to allow for safe SIMOPs
- Coordination, including shared communication methods, between the SIMOPs
- Inclusion of emergency response personnel or services in the planning and coordination of the SIMOPs
Also, CSB recommended that OSHA develop a safety product to provide guidance on these requirements for SIMOPs.
The CSB recommended that Center for Chemical Process Safety (CCPS) should develop and publish a safety product on Safe Work Practices, including detailed guidelines for evaluating SIMOPs. The CSB recommended that the CCPS guidelines, at a minimum, should address the content found in CCPS’s website resource for implementing Safe Work Practices, and discuss guidelines for a SIMOPs life cycle, including:
- Methods to identify SIMOPs
- Methods to conduct a SIMOPs hazard assessment
- Safeguards and controls pertaining to SIMOPs
- Preparation for SIMOPs
- SIMOPs execution
The CSB also recommended that Wacker develop and implement a formalized SIMOPs program that addresses planned and/or permitted co-located work tasks including:
- Identification of potential SIMOPs
- Identification of potential hazardous interactions
- Evaluation and implementation of necessary safeguards to allow for safe SIMOPs
- Coordination, including shared communication methods, between the SIMOPs
- Inclusion of emergency response personnel or services in the planning and coordination of the SIMOPs
Additionally, the CSB recommended that Wacker ensure relevant staff are trained on execution of the SIMOPs program.
Further details on SIMOPs can be found in these articles:
Process Safety Incidents Involving Simultaneous Operations, P. Baybutt, Hydrocarbon Processing, November, 2017.
Simultaneous Operations (SIMOPs) Review: An important hazard analysis tool, P. Baybutt, Process Safety Progress, Volume 36, Issue 1, pages 62–66, March 2017.
