AIChE Pilot Plant Benchmarking Study Environmental Health & Safety Section

1. AIChE Pilot PlantBenchmarking StudyEnvironmental Health & Safety Section Daniel J. Pintar UOP (Presenter)

2. Benchmarking Team Members • Current Team • Bob Duggal, Afton Chemical • Rich Palluzi, ExxonMobil • Dan Pintar, UOP • Joe Powell, Shell • David Edwards, Zeton • Sean Murray, Zeton • Previous members • Shiah Cherney, ChevronTexaco • Paul McKenzie, BMS • Kate Threefoot, DuPont

3. Type # Speciality Chemical 16 Commodity Chemical 4 Pharmaceutical 7 Oil & Gas 4 Sub-Industry Within the CPI

4. Pilot Plant Safety:Survey Results

5. Does your company have a formal safety program? • 100% of responding companies answer YES!

6. What type safety program do you have?

7. What type of safety metrics does your company use?

8. Employee Safety Incentive Program

9. Lost Work Case Rate 14 12 10 8 Number of Respondents 6 4 2 0 0 <1 1 Lost Work Case Rate Safety Record – Injuries, OSHA, Lost Work Case Rates

10. Emergency Response Team

11. How do you review new processes for EH&S?

12. Safety Review Process to Control Changes to Pilot Plant

13. How do you document changes to pilot plant?

14. Do you allow unattended operations of pilot plants?

15. If you allow unattended operations, what type of safety review process is used for these types of units and are their any special safety interlocks or safety requirements? • 9 responses to this question • Comments….. • We allow, but currently the vast majority would be more correctly classified as “Minimally Attended Operations” • Procedure defines operations that can be run unattended - stirring reactions, distillations with no over-distilling hazards, etc • Detailed hazard and risk analysis including safety shutdown system design and operation • Full management of change (MOC) process and training; risk analysis required. • Automatic shutdown • Alarms to alert staff on site or in the area • A risk assessment process, but this is only the case for fully automated continuous unit • PHA • No special safety interlocks – only past history/records • Formal review with safety staff and engineering staff. Pilot plant specific safety interlocks are required for unattended operation • No unattended operations

16. What have been the biggest changes in the areas of pilot plant safety over the last decade for your organization? • ~30 responses were received • A common theme was the advent of more “formalized” safety programs. Examples: • Formal safety reviews/PHA (8 comments) • Change Management – MOC (4 comments) • Formal safety training (4 comments) • PSM/Scale/Scope of Work (3 comments) • More formalized safety program guidelines/corporate requirements (2 comments) • Increased use of automation/alarms/interlocks was a common theme (4 comments)

17. What have been the biggest changes in the areas of pilot plant safety over the last decade for your organization? • Some others comments: • Catch tank installation for containment of runaway reaction effluent • Formal thermochemistry review process for every batch made in the pilot plant • Solids handling/exposure • Increasing amount of HSE regulations we need to comply with that historically seemed to only apply to larger manufacturing sites • The scale of the experiments has increased. Thus the chance of a serious incident is greater due to an increase in magnitude • We have modified our safety procedures to more closely handle pilot plants as continuous operating laboratory units. • Instituted a Safety Relief Valve database

18. What are some of the drivers of the changes in safety programs? • Increasing amount of regulations/compliance requirements is an obvious driver of these changes • Safety performance is a measure of corporate performance and is factored into strategic plans • The goal of 0 injuries, 0 environmental incidents • Social aspects that help drive these changes • “Sustainable Development” • Being a good corporate citizen • Emphasis on “Safety is Job#1”

19. What other issues associated with "Pilot Plant Safety" are of significance to your organization, and would be of interest to you in future benchmarking studies? • Safety staffing - dedicated safety staff (of FTE) per operator/technician and per pilot unit • Types of review procedures: • Pre-start up safety analysis • Types of safety review systems • Chemical review along with an equipment operation review. • Automation/safety system related: • Safety shutdown implementation philosophy. • Unattended/minimal operation. Remote monitoring from main plant control rooms for safety issues as backup to unattended operation • Personnel Safety • Solids handling • Handling Extremely hazardous chemicals • Monitoring adherence to operating procedures (requires routinely auditing of operators as they perform their jobs). • Industrial Hygiene Monitoring of new processes. • People from other organizations working in the pilot plants. • Area electrical classification philosophy

20. What other issues associated with "Pilot Plant Safety" are of significance to your organization, and would be of interest to you in future benchmarking studies? Continued… • Pilot Plant versus Prudent Lab versus Manufacturing Facility standards • Managing a Pilot Plant within a Manufacturing Facility with different standards. What control should Manufacturing have over how a pilot plant operates? • Managing between Pilot Plant and Prudent Lab • The degree to which commercial process MOC concepts should apply to smaller scale R&D pilot plants • Statistics/Metrics • Incident Reports, including Near Miss reporting • Current Safety statistics • Root cause analysis for all Safety Incidents/Injuries/Accidents • Corrective actions completion % & response time • Current training and training tracking • Reliability