Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90301

THE FORMAL ADOPTION OF A PROCESS SAFETY MANAGEMENT METHODOLOGY WITHIN AN INTERNATIONAL OIL & GAS PIPELINE COMPANY
Susan Urra Enbridge Pipelines Edmonton, Alberta, Canada

ABSTRACT Process Safety Management (PSM) is an integrated approach to managing loss prevention. At Enbridge, as with many organizations, several PSM elements of practice have been implemented with different levels of rigor, maturity and/or alignment with best practices. This paper presents Enbridge Liquid Pipelines approach to assess a strategy to adopt a formal PSM system. A description of the current regulation framework for PSM and the drivers for adoption are presented to explain the considerations during the scoping and design of a PSM system for an international oil and gas pipeline system that operates across numerous state and provincial boundaries, and one international border. The paper also discusses the requirements for organizational governance to ensure accountability for and ownership of individual elements of a PSM program throughout a large, geographically diverse organization such as Enbridge. Finally, a strategy to develop and potentially implement and manage PSM in a large organization such as Enbridge is proposed. INTRODUCTION Process Safety Management (PSM) is a framework commonly used in the chemical industry to apply management systems and controls (standards, procedures, programs, audits, evaluations) to identify, understand, and control the process hazards. The focus of PSM is on the technologies used in the hazardous process, the integrity of the equipment in the facilities where the hazardous process takes place, and the personnel involved in the operation and maintenance of the assets. The purpose of establishing a PSM framework is to prevent a loss of containment, which could foreseeably lead to an undesired outcome.

NOMENCLATURE ERCP: Emergency Response Capability Planning IST: Initiative Steering Team MI: Mechanical Integrity MOC: Management of Change MOC-T: Management of Change technology MOC-F: Management of Change facilities MOC-P: Management of Change personnel MOC-S: Management of Change subtle NGL: Natural Gas Liquid OP/SWP: Operational Procedures/Safety Work Procedures PHA: Process Hazard Analysis PSI: Process Safety Information PSSR: Prestart-up Safety Review QA: Quality Assurance T&P: Training and Performance BACKGROUND The regulation around PSM varies depending on the jurisdiction. In most cases the establishment of regulated PSM requirements has been a reaction to severe incidents in the chemical industry, such as the Seveso incident in Italy that triggered the Seveso II Directive(1) . In Australia, the ESSO Longford incident triggered the Major Hazard Facilities Regulations.(2) In the UK, the UK Pipeline Safety Regulations (1996)(3), the Offshore Installation (Safety Case) Regulations(4) and the UK Control of Major Accident Hazards Regulations(5) refer to PSM practices, although not as a prescriptive requirement. In North America the evolution of PSM has been driven mainly by best practices rather than a regulatory framework, with the exception of the PSM 1910.119 directive in the US (6) that lists highly hazardous chemicals that need to be managed

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by a PSM program. Best practices for PSM have been identified in the US by ACC, AIChE, and CCPS initiatives;(7) and in Canada, by the MIACC,(8) CSChE, and CCPA initiatives, as well as the Canadian Environmental Protection Act, section 200 (2000, federal)(9) and Bill C-45(10)the Westray Bill, which amended the Criminal Code of Canada to extend the liability of companies to the area of health and safety. The lack of a prescriptive regulatory framework for PSM in Canada has resulted in ambiguity and inconsistency with regard to how a PSM program should be designed and implemented as well as when it should be leveraged. However, it is important to note that a prescriptive approach to PSM regulation, such as in the US and Europe, also has deficiencies, mainly because of the operators emphasis on meeting the standard, which does not always result in the desired results intended by the regulation. Another element that contributes to the lack of direction and consistency around PSM in North America is the similarity of objectives with the Occupational Health and Safety (OH&S)(11) regulations in terms of the goal to eliminate harm to people, assets, and the environment. This overlapping of objectives was one of the findings of the Baker report on the Texas City incident where evidence gathered showed that BP focus on improving OH&S statistics increased personal safety at the expense of process safety(12). The focus of OH&S is on incidents that typically occur at a higher frequency and have a lower consequence than do process risks; hence, OH&S codes and standards do not specifically address issues related to PSM. Because of the above regulatory framework issues, corporations that want to implement a PSM program face the challenge of scoping and justifying the need for funding and resources for the implementation of a PSM system. Current PSM implementations in Canada cover some, but not all, of the PSM elements; they are disjointed, and the efforts and approach are usually minimal. For example, the PSM system developed by the Center for Chemical Process Safety (CCPS, 1989) was the basis for the 12-element system recommended by the Canadian Society for Chemical Engineering (CSChE, 2002). Then, in 2007, CCPS developed guidelines based on a 20-element, risk-based approach to PSM. Hence, depending on which predesigned PSM system an organization decides to follow, as well as how it decides to implement it, improvements to process safety can be minimal. Furthermore, PS implementation is usually triggered by market requirements (competition, client, or financial-backing driven) or by tool-sale efforts by vendors (e.g., software for documenting MOC, PHA reviews, etc.), evolving into an informal practice driven by specific personnel instead of top management. During the last few years several external drivers have influenced the way that risks are perceived, including recent oil and gas pipeline industry incidents, an aging pipeline infrastructure, and increasing public expectations. They have raised the need for the industry in Canada to keep plants and facilities operating safely to succeed in an evolving regulatory regime with increased regulatory oversight and a trend towards

greater risk aversion by both regulators and the public. The oil and gas pipeline industry in Canada must be careful to avoid facing the prescriptive legislation applied in the USA and Europe. THE ENBRIDGE CASE FOR PSM Enbridge Liquid Pipelines is regulated by 29 CFR 1910.119, so it does not necessarily need to switch to a specific PSM program or those proposed by organizations such as the CSChE. The PSM practices at Enbridge Liquid Pipelines follow regulations or best practices such as API RP 750 and individual elements of the AIChE CCPS, EPA RMP, and OSHA PSM, which are all embedded in the companys operational practices. Enbridges expectation of operational excellence, defined as achieving placement in the North America industry in at least the top performance quartile in all critical program areas (ORM Plan, Enbridge, 2011, p. 1), drives the interest in a PSM program. The critical programs areas are safety, pipeline integrity, leak detection, control systems, emergency planning and response, and public safety. This vision requires more than simply meeting compliance requirements to examining reasonable and cost-effective areas for improvements. The organization harnessed the efforts and resources required to achieve the vision for operational excellence by defining a safety culture initiative, led by a senior representative who was tasked with scoping, planning, and implementing the organizational shift and managing the change. To assist with the initiative the services of DuPont Sustainable Solutions (Dupont) were retained. During the exploration phase, one of the first discoveries of the task force that led this initiative was that, to achieve this status, Enbridge needed to define a broader principle to manage risk by incorporating process safety as an additional perspective on the preexisting safety scope, which focused mainly on personal safety. Based on this approach, implementing PSM was considered a good strategy to tackle process safety because a PSM system aims for operational discipline through the design and execution of each of the PSM elements. The dedication and commitment of the organization to operational discipline will result in operational excellence if the activities and decisions are executed consistently. In terms of the scope of PSM applicability, Enbridge Liquid Pipelines operates an extensive network of pipelines to transport crude oil and NGL products. In addition to the mainline component of the system, Enbridge Liquid Pipelines requires facilities that manage the injection, delivery, storage and pressure of the pipeline system. Federal regulation in Canada and US require pipeline operators to implement a Safety and Loss Management System(13)(14) as well as an Integrity Management system,(15)(16) in order to minimize release risk. During the exploration phase, it was decided that the focus of the potential PSM implementation at Enbridge would be on the facilities, with the future potential to extend the applicability to the mainline component of the system, if it deemed valuable.

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EXPECTED BENEFITS OF A PSM PROGRAM AT ENBRIDGE A PSM program ensures consistency in the allocation of operational resources to those aspects of facility maintenance in which the business risks are the greatest. A PSM program aligns with the Enbridge Boards mandate to achieve operation excellence because it takes a structured approach to a management systems audit that goes beyond compliance. A PSM program promotes a common risk tolerance across the organization by providing and supporting methodologies to identify and manage risk (for example, PHA). These methodologies are globally recognized and defensible, and can be supported and checked by many external resources. These methodologies will aid in decision making by providing risk-based information and closure to any significant gaps in current practices through envisioning and implementing best practices. THE ENBRIDGE PLAN TO IMPLEMENT PSM After the exploratory phase, where the need for a PSM in Enbridge was identified and the desired outcome was envisioned, the next step was to understand what was required to establish the foundations for the required cultural shift to ensure that the resources and efforts invested in this initiative deliver the expected outcome. Enbridge recognized that is required to establish a governance structure and performance measurements in order to set up a PSM program for success. Governance Structure An Initiative Steering Team (IST) was created to provide the governance structure. The IST members were all senior management representatives from the key organizational areas that were expected to be affected by this initiative, such as operations, integrity, and human resources. This team reports directly to the Enbridge Management Team, whose members are ultimately accountable for the implementation and performance of the initiative. Performance Measurement The performance of an organization is a function of the management systems in place and the level of execution of those systems. Therefore, to determine the state of operational effectiveness at Enbridge, it is necessary to evaluate the state of process and personal safety standards as well as the state of implementation of the management system that controls the execution of these standards. The following are the areas considered in the evaluation: Organization and structure Policies and processes Performance analysis Work as it is done Current state and reasons for current performance level

FOUR-PHASE APPROACH TO PSM IMPLEMENTATION When the organization decided to develop a strategic implementation plan for PSM, the following questions needed to be answered: What is the best way to proceed? Which preexisting PSM program should be followed? Where is the best value for the resources to be expended? What are the implementation-plan details, such as the timeframe, resources, and governance? The IST established a Process Safety (PS) project team to answer these questions and set priorities, request resources, and propose a plan to integrate the PSM program into other safety management structures and processes that were already in place. Members of the PS team were chosen from existing functional areas such as Operation Services, Operational Risk Management, Compliance, and Emergency Response. These areas are accountable for PSM-related activities currently imbedded in the management system of the organization. The PS project team reports to the IST for strategic guidance and tactical oversight and is directly sponsored by the Senior VP of Operations. The IST selected the PSM elements to be included in the PS project team work, based on alignment with PHMSA requirements (Table 1). The first 11 elements are of a preventive nature. The Emergency Response Communication Plan (ERCP) and Incident Investigation are corrective elements, and the PSM audit is a governance element. In addition to the PSM elements, the IST included two additional elements related to operating discipline (Table 2).
TABLE 1: PSM ELEMENTS PHMSA Requirements 1. Hazards and design details up-to-date, accurate and accessible; operations and maintenance technicians trained on the details 2. Correct and documented procedure to execute activities and ensure compliance 3. Personnel trained and retrained on the procedures, verified, and audited 4. Evaluation/reevaluation of the risks from loss of containment and the adequacy of safeguards 5. Controlled changes to the equipment/ technology; updating of PSI 6. Assurance that equipment is fabricated/installed to design 7. Start-up check PSM Element Nomenclature1 PSI

OP/SWP T&P PHA

MOC technology QA PSSR

Refer to Nomenclature section for acronym definition.

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8. Once commissioned, maintenance and improvement of the equipment 9. Controlled field changes to hardware and procedures 10. Sufficient PSM knowledge and capability 11. Same standards for work for everyone, including contractors 12. Ensured emergency response capabilities in the field and offices 13. Investigation of all incidents based on their consequence potential, including process incidents and business interruptions 14. Conformance with company policy and intent

MI MOCsubtle MOC personnel Contractor safety ERCP Incident investigation PSM audit

Key Work Streams Process Safety Management training Execute a screening study of as-is across Enbridge for each of the PSM elements

Activities

Train PS Team members Evolve understanding along the

as-is study

PS Team to develop a screening

sample of as-is, work practices, and documentation Conduct stakeholder analysis to increase awareness during implementation phases and to capture unique perspectives from interviewees Introduce team to governance process and distribute current committees Examine alignment and design future state Develop a standards and/or procedures and/or how-to guide

Develop governance structures

TABLE 2: ADDITIONAL ELEMENTS OF OPERATING DISCIPLINE PHMSA Requirement Behavioral observation and intervention at all levels Key performance indicators PSM Element PSI PSM metrics

Develop a plan to establish process improvement teams (PITS) for process safety Establish a high-level plan and schedule for local implementation

Define the sequence of element

development

Communicate and produce

training packages

The PS project team was given three months to work with Dupont to develop a methodology to make a recommendation to the IST on whether (a) to proceed with a PSM implementation, (b) to proceed with revisions to IST plans, or (c) not to proceed. The objectives for the PS project team include developing and proposing an implementation plan and governance structures for the PSM program, including the definition of a sequence of PSM program elements and a schedule for implementation. Dupont proposed a four-phase methodology for PSM implementation, which is summarized in Figure 1.

Develop a sustainability plan

(review, re-authorize, etc.)

FIGURE 1: FOUR-PHASE APPROACH TO PSM IMPLEMENTATION

In terms of the specific activities for each of these phases, the methodology takes into consideration the following work streams (Table 3).
TABLE 3: KEY WORK STREAMS TO IMPLEMENT A PROPOSED ENBRIDGE PSM PROGRAM

During the first phase the PS project team develops a screening sample of Enbridge procedures, work practices, and documentation for each PSM element as-is. Each team member conducts a stakeholder analysis in his/her area of responsibility by comparing the as-is with the best practices for each of the following elements considered. By building the as-is baseline, a gap analysis helps to identify how far the corporation is from the best practices for each PSM element and envision a to be framework. Once the implementation plan begins, management commitment is required to establish the safety culture. Management responsibilities will include: Commitment of resources Involvement employees and contractors to ensure engagement Establishment of clear accountability Personal participation and corrective action Audit for compliance and corrective action Definition, tracking, and rewarding of strategic PSM critical operating tasks and key performance indicators Management commitment is paramount to gain a common perspective on what change is required, prioritize change actions and then mobilize the organization. Managements actions and communications need to demonstrate strong and genuine commitment to safety to align employees safety commitment and behavior with the companys safety vision, beliefs, principles, policies, standards, procedures, and goals.

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FINDINGS The gap analysis between the as-is state of implementation of PSM elements at Enbridge and the to be best practice benchmark revealed the following areas for improvement. Operational Excellence Operational excellence requires operational discipline. The current level of operational discipline at Enbridge presented the following gaps: Functional standards and procedures that are not always consistently applied Dedicated execution by key individuals instead of consistency of practice across of organization The absence of a comprehensive PSM system that ties the various functional approaches together with a consensus view of Enbridges risk tolerance for facilities. For example, the corporation lacks a definition of safety-critical equipment. Overall Enbridge Governance Structure for PSM Requirements and Activities Stronger strategic direction and oversight are required to ensure that escalating issues and/or deficiencies and the allocation of sufficient resources are dealt with in a timely manner. Establishment of a management system audit policy and process is required. A linkage between the execution and strategic committees needs to be established to escalate key, broad- based, high-risk, or high-expense issues so that decisions can be made. Risk-Tolerance Alignment PSM requirements should be evaluated against a single risk assessment tool across all Enbridge business units. In the case of the PSM implementation at Enbridge, the single assessment tool is the Enbridge Risk Matrix. This tool provides the risk tolerance for the organization. A work process that will ensure that changes to the risk assessment tool are integrated and communicated in a timely manner through the different staff groups who make PSMrelated decisions is required. A process to update previously conducted risk assessments is necessary when the risk-tolerance criteria have evolved. Process Safety Information Improvement Opportunities The PSI element is foundational to the establishment of a PSM program because it determines the feasibility of implementation of other elements such as PHA and MOC-T (technology). Key PSI data specific to each site consist of facility hazards and process hazards, the process design basis, and the equipment design basis.

About 25% of the documents required for the facility description were not easily accessible/available, 70% of which are potentially critical to an effective risk-management scheme. An additional area for improvement is the level of accuracy of some critical documents, such as process flow diagrams and the operation philosophy, among others. Process Hazard Analysis Improvement Opportunities A Process Hazard Analysis (PHA) program has already been established at Enbridge to identify, evaluate, and manage operational hazards. However, the current program targets only the development of new assets by requiring that operational and capital projects include a PHA in their deliverables. The current Enbridge PHA program excludes or is deficient in the following elements of a best-in-class PHA program: 1. Consequence analysis: The exception is release modeling for new tanks being built in some specific municipalities, which require this assessment. 2. Safety instrumented system (SIS) evaluation: Safety Instrumented Levels (SILs) are implicitly determined for high-consequence scenarios as part of LOPA analysis in the PHA program, but the development of a SIS lifecycle management framework has not been evaluated. 3. Human factor analysis: A basic human factor checklist is included in the What-If methodology that is currently part of Enbridges PHA program. A development of a human factor risk assessment model is in early development; the initiative is being led by the Operational Risk Management group. 4. Facility sitting review: A basic facility sitting checklist is included in the What-If methodology that is currently part of Enbridges PHA program. 5. Inherently safer processes analysis 6. Management of PHA recommendations and management response: This process is in place in Enbridges current PHA program, but formal closure by senior management and escalation of pending PHA action item can be improved. Management of Change: Technology and Facility Improvement Opportunities Even though MOC-T and MOC-F procedures are currently in place, MOC-T covers only equipment changes outside the scope of company standards. In addition to this improvement, the current MOC-T practice does not refer to the original design basis. MOC-F covers changes that are not replacement in kind, and authorized changes are approved and documented for each procedure. However, both cases require improved training, tracked closing of tasks, and metrics to track adherence. Mechanical Integrity Improvement Opportunities Enbridge has in place maintenance procedurespreventive and predictivefor all PSM-critical equipment. As well, training programs include a training matrix for maintenance

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technicians who work on PSM-critical equipment, training on the hazards of process, training on maintenance procedures, and specific safety training on Safe Work practices. The following practices are not in place or require improvement: Mechanical Integrity Standards and Procedures/ Guidance documents Focus of maintenance and quality assurance efforts on equipment defined as PSM critical Application of requirements to contractors who work on safety-critical equipment Quality procedures extended to spare-part procurement, receipt, storage, issuance, and installation practices Approval and tracking system for temporary and permanent extensions or delays to scheduled maintenance Reliability Engineering program with root cause failure analysis for all PSM-critical equipment Quality Assurance Improvement Opportunities The current Quality Assurance Process for Mechanical Integrity includes procedures to specify supplier-selection practices, verify the fabrication quality by qualified inspectors, and communicate the design basis to vendor, operation, and maintenance personnel. Field verification practices are in place to ensure that the equipment is always installed as per the design. However, consistency in the application of the practices is required, and the development of a Quality Assurance Standards and Guidance document is recommended. Prestart-up Safety Review (PSSR) Improvement Opportunities A formal prestart-up safety review (PSSR) process and procedures are in place to confirm that equipment is constructed and assembled as per the design requirements prior to introducing a hazardous substance into the system. The current practice includes new or modified PSM-critical equipment and a check on the relevant elements of PSM. The physical inspections are guided by a checklist, documented, and signed; and PSSR recommendations are categorized as to their criticality and tracked to completion before allowing the introduction of hazardous substances into the equipment. Small gaps were identified in the application of this practice; there was general compliance for major projects, but there is inconsistency in application to smaller projects. PSSR practices are not currently audited to verify compliance. Hence, the development and implementation of an audit protocol is recommended. Emergency Planning and Response (EP&R) improvements Corporate procedures are in place, and all terminal facilities have developed action plans to terminate any release.

Callout lists are defined, and practice drills are critiqued. Current practices could be improved as follows: Including analysis and planning for credible natural disasters in the EP&R plans Including the participation of local response organizations and (in the US) community emergency response groups in local and regional response plans Developing a system to ensure that adequate personnel are available for all emergencies Following up on recommendations from practice drills by tracking and documenting to closure Incorporating site-specific consequence analyses for a wide range of potential releases into response plans RECOMMENDATION FOR NEXT STEPS From the identification of areas of improvement opportunities, the PS team was able to define guidelines for implementation planning and submit recommendations to IST. For each PSM element, the work required to implement the improvement was defined by the PS team, and a prioritization was executed based on the following criteria: Value to the organization if the improvement opportunity is pursued Resources required to pursue the improvement opportunity Applying these criteria, a score was assigned to each improvement effort, and foundational as well as quick-win efforts were identified to support decision making for implementation strategy. The implementation of a PSM program at Enbridge should consider the following strategies: 1. Apply a top-down implementation with the following sequence (Figure 2):

FIGURE 2: TOP-DOWN IMPLEMENTATION.

2. Work on improvements for no more than four PSM elements at a time by selecting a mix of foundational and quick-win efforts. 3. Develop a tactical plan rooted in the creation of Element Improvement Teams for improvement, in collaboration with a steering committee composed of senior management leaders for oversight and guidance. 4. Involve existing staff groups in improvement plans as much as possible. A schedule for implementation was outlined and is shown in Table 4.

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TABLE 4: IMPLEMENTATION OF ENBRIDGES PROPOSED PSM PROGRAM Rank 1 Improvement Opportunity Improve PSM governance a. Charter b. PSM standard c. Risk matrix PSI (standard, 100% application) PHA (standard and a few procedures, 100% application) MOC-T/MOC-F (procedure) PSSR (procedure) MI/QA (standard and procedure) PSM audit (protocol) Difficulty Medium a. Low b. Medium c. High Medium High Value High, foundational/ long-term Foundational/ long-term Foundational/ long-term Quick Win/ long-term Quick win/ long-term Quick win/ long-term High, foundational/ long-term Long-term Long-term

4. Long-term sustainability: Maintenance and continuous improvement of PSM practices are usually not considered during the planning and implementation of initiatives; hence, processes and practices are established and rolled out with no long-term planning for resources to ensure long-term sustainability. CONCLUSIONS Implementing the proposed PSM program at Enbridge Liquid Pipelines will establish a consistent way to focus operations resources on the aspects of facilities maintenance with the greatest business risks, which align with Enbridge Boards mandate to position the company as the industry leader in systems integrity and environmental and safety programs. The proposed PSM program promotes a common view of risk tolerance across the organization by incorporating and/or supporting methodologies to assess and mitigate risks that are defensible and globally recognized; hence, many external resources are available to support the efforts during the programs implementation and execution. The proposed PSM program will facilitate the decision making across different functional groups and will provide a structured approach to a management systems audit that goes beyond compliance. Finally, the business benefit of implementing this program is that it will close the gaps in current practices and thereby increase the organizations operational discipline and performance. Enbridge is at a stage where PSM has been identified as an important component in creating a stronger safety culture. However, the organization faces the challenge of availability of internal resources for the implementation phase. Currently, senior management is evaluating recommendations in order to establish a feasible action plan for moving forward. REFERENCES 1. Seveso II Directive (EU): http://ec.europa.eu/environment/seveso/index.htm http://ec.europa.eu/environment/seveso/legislation.htm http://europa.eu/legislation_summaries/environment/ civil_protection/l21215_en.htm 2. Major Hazard Facilities Regulations (Australia): http://www.dmp.wa.gov.au/6660.aspx http://www.dmp.wa.gov.au/7264.aspx Major hazard facilities: an overview of the Commonwealth legislation: https://www.comcare.gov.au/__data/assets/pdf_file/0004/ 41836/Major_hazard_facilities_OHS_70_Mar_07.pdf 3. The Pipelines Safety Regulations 1996 (UK): http://www.legislation.gov.uk/uksi/1996/825/contents/mad 4. The Offshore Installation (Safety Case) Regulations (UK): http://www.hseni.gov.uk/l30_a_guide_to_the_offshore _installations__safety_case___regulations_2005.pdf 5. The Control of Major Accident Hazards Regulations (UK): http://www.legislation.gov.uk/uksi/1999/743/

2 3

4 5 6 7

Low Low Medium Low

8 9

10

11

ERP (standard and local plans) Contractor safety management (standard and procedure) Incident investigation (procedure and management tool) Rules, procedures, and training a. Golden rules b. Operating procedures and maintenance procedures c. Training matrix for PSM-critical positions

Medium High

Medium

Quick win

High Medium High

Long-term

Medium

Expected challenges during the PSM implementation outlined above include the following: 1. Governance structure: Steering committees and multifunctional teams usually lack accountability and the motivation to achieve goals if the objectives are not tied to individual performance. There is no mechanism for escalation of issues to high-enough level in the organization where effective decision making can be achieved. 2. Resource availability: The practice of establishing steering committees and multifunctional teams usually does not appropriately allocate time for tasks execution into the members workload. 3. Inconsistent implementation: PSM implementation by various staff groups and across the regions is inconsistent because of the size and extensive geographical dispersion of Enbridges pipeline system.

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6.

7.

contents/made http://www.hse.gov.uk/comah/background/ comah99.htm PSM 1910.119 directive (USA, OSHA): http://www.osha.gov/SLTC/processsafetymanagement/ index.html http://www.osha.gov/pls/oshaweb/owadisp.show _document?p_table=STANDARDS&p_id=9760 Canadian Society for Chemical Engineering, Process Safety Management Subject Division: http://www.cheminst.ca/ a. http://www.cheminst.ca/index.php?ci_id=2562&la _id=1 b. PSM framework: http://www.cheminst.ca/index.php ?ci_id=3215&la_id=1 c. PSM Guide 3rd edition: http://www.cheminst.ca/ index.php?ci_id=3214&la_id=1 Chemistry Industry Association of Canada: http://www.ccpa.ca/ a. http://www.canadianchemistry.ca/ ResponsibleCareHome.aspx b. http://www.ccpa.ca/ChemistryBRHealth.aspx c. http://www.ccpa.ca/TransportationBRSafety.aspx d. http://www.ccpa.ca/EnvironmentBRSustainability.aspx American Chemistry Council: http://www.americanchemistry.com/ a. http://www.americanchemistry.com/Safety b. http://responsiblecare.americanchemistry.com/

8.

9.

10. 11. 12.

13. 14.

15. 16.

American Institute of Chemical Engineers: http://www.aiche.org/ Technical Societies: Center for Chemical Process Safety: The Global Community Committed to Process Safety: http://www.aiche.org/CCPS/index.aspx http://www.acusafe.com/Newsletter/Stories/1299NewsPSM_Canada.htm Environment Canada: http://www.ec.gc.ca/lcpe-cepa/ default.asp?lang=En&n=8C6B52D8-9 http://www.ec.gc.ca/lcpe-cepa/26A03BFA-C67E-4322AFCA-2C40015E741C/lcpe-cepa99_0307_bil.pdf Department of Justice Canada: http://www.justice.gc.ca/ eng/dept-min/pub/c45/p02.html Canadian Center for Occupational Health and Safety: http://www.ccohs.ca/oshanswers/legisl/billc45.html#_1_1 Baker Report, p xii Failure to Learn the BP Texas City Refinery disaster, Andrew Hopkins, p. 63 CSA Z662-07 Oil and Gas Pipeline Systems Onshore Pipeline Regulations, 1999: http://www.neb-one.gc.ca/clfnsi/rpblctn/ctsndrgltn/rrggnmgpnb/nshrppln/nprc2011_01 qstnnswr-eng.html CSA Z662-03 Oil and Gas Pipeline Systems PHMSA regulation Title 49 CFR Parts 195.452

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