03 October 2008 00:00 [Source: ICB]
Staying compliant with rapidly evolving and changing environmental regulations is one of the challenges HSE executives and professionals must deal with routinely
ON THE whole, environmental regulations tend to be specific to the facility, depending on region, while air quality specifications differ from state to state, and country to country.
With more chemical companies supplying a global base, though, many are aligning their processes and health, safety and environment (HSE) requirements to the most stringent regulations to standardize output.
Among the legislation producers must contend with are: The UN Economic Commission for Europe (UNECE) Convention on Long-range Transboundary Air Pollution, the Stockholm Convention on Persistent Organic Pollutants, UNECE's Globally Harmonized System of Classification and Labelling of Chemicals, and the EU's Restriction of Hazardous Substances (RoHS) Directive.
Among the health and safety standards of the US Occupational Safety & Health Administration (OSHA), Process Safety Management of Highly Hazardous Chemicals (PSM) sets requirements for employers in facilities with specified quantities of flammable liquids and gases and other hazardous chemicals.
"The PSM standard is a performance-based standard that requires covered employers to have management systems that prevent catastrophic incidents caused by the release of highly hazardous chemicals," says an OSHA spokesperson.
OSHA has a Petroleum Refinery National Emphasis Program under which the agency will inspect all petrochemical refineries in federal jurisdiction.
Additionally, a Chemical National Emphasis Program is being developed to facilitate enforcement at chemical plants and facilities other than petrochemical refineries that are covered by the PSM standard.
These, along with the increase in customer demands for environmental stewardship, have broadened the scope of many companies' HSE staff.
But the EU's Registration, Evaluation, Authorisation and Restriction of Chemicals (Reach) legislation, introduced in June 2007, "is setting a standard for other types of legislation," says Larry Allen, vice president of environmental health, safety and quality for US-based industrial gases supplier Air Products.
Global major Shell Chemicals is dedicating a significant effort to the management of Reach in Europe, drawing on its own product stewardship resources but also the toxicology resources within the company.
"Regulatory pressures continue to grow in the global chemicals sector, and energy will continue to be focused on this area going forward," says Nigel Hobson, Shell Chemicals' vice president of operations and health safety security environment (HSSE).
EMPLOYEE PROTECTION
As Shell puts it, HSE responsibilities include ensuring no harm to the people associated with operations, including employees, contractors, customers and the communities in which the company operates prevention of spills to protect the environment compliance with the regulatory systems and effective, efficient management of the risks associated with operations.
According to Hobson, the two areas of highest risk are the construction of the Shell Eastern Petrochemicals Complex, on Bukom and Jurong islands in Singapore, where some 20,000 workers are on site and product transport, notably road transport operations where independent haulers are contracted to make more than 100,000 product deliveries each year. "The principal area of risk in these operations is at the point of product loading and unloading," says Hobson.
For France-based Rhodia, everything is set to the highest standard possible. "If the regulation is higher than the Rhodia standard, we try to implement the highest level of quality and safety in the other zones," says Jean-Paul Perez, Responsible Care director for Rhodia.
To increase the level of safety in Rhodia's plants, the company has developed a process safety program to integrate human behavior and technical skills.
"We need to protect against 'low probability, high consequence' accidents," says Perez. "Something like this might only happen once every 10,000 years, but it would create huge damage for the company."
Sunnyvale, California, US-based electronic chemicals manufacturer JSR Micro had its HSE staff take "a compliance-based approach to a proactive holistic environmental program," says Mark Ignatowicz, plant manager for JSR Micro.
The company has performed a campus-wide energy audit. "We are in the middle of implementing capital investments to maximize efficiency, reduce operational cost and lower our carbon footprint," says Ignatowicz.
JSR recently replaced its aging roof and spent 20% extra over conventional installation to install a "cool roof" on all its buildings to reduce the heat load.
The company has also been working with the World Semiconductor Council to reduce the dependency on perfluorooctane sulfonic acid in the manufacture of photoresist and antireflective coatings.
RESPONSIBLE CARE
Responsible Care is the global chemical industry's voluntary initiative where companies work together to continuously improve their HSE performance, while communicating with stakeholders about their products and processes.
In 2002, the American Chemistry Council adopted a new management system approach for implementing Responsible Care in the US, including mandatory independent third-party certification.
Canada-based NOVA Chemicals focuses on Responsible Care for its HSE needs. "Responsible Care enables the industry to demonstrate how its health, safety and environmental performance has improved over the years, and to develop paths to further improvement," says Bill Greene, vice president of manufacturing for NOVA.
"Through stringent process safety programs and procedures, we reduce the risk of uncontrolled manufacturing process events in our facilities," he says.
Some of NOVA's HSE efforts include maintenance programs to minimize the risk of equipment failure, chemical detectors to identify hazardous conditions and ventilation systems to minimize oxygen depletion.
Process fire prevention is an area of particular focus at NOVA, notes Greene. Any fire or evidence of a flame - "even those smaller than a candle flame," he says - in the process area, as well as adjacent spaces such as warehouse and utility areas, is classified as a process fire.
Product stewardship issues will increasingly shape the chemical industry and Responsible Care. "To be effective, we will need to expand the knowledge and understanding of our chemicals and work closely with governments, communities and NGOs [nongovernmental organizations] to ensure chemicals are safely managed and our industry is able to grow and continue to deliver benefits to society," notes Greene.
Asia, meanwhile, has been a high-growth area for the chemical industry. A specific challenge there, say producers, has been establishing functional competencies in such areas as health and safety, environmental engineering, process safety, and industrial hygiene. This "is a challenge for most of the major enterprises in Asia," says Allen.
In 2007, Shell Chemicals introduced the concept of "Goal Zero" to encourage "everyone to believe that it is possible to operate with zero significant incidents, and to feel a sense of personal responsibility for doing everything possible to prevent incidents from happening," says Hobson.
Shell Chemicals has taken a number of steps to embed Goal Zero thinking, including notifying all staff when incidents occur and regularly sharing progress updates sharing the knowledge learned from each incident in a way that highlights how individuals can change their approach to working safely, even if they work in an unrelated area and assigning direct accountability for these incidents to specific managers and putting responsibility on them to take the actions that will prevent these incidents from recurring.
Shell Chemicals has also been encouraging the spread of Goal Zero thinking to its contractors. Hobson says that Goal Zero is "beginning to encourage a belief that most incidents can be prevented - and so it is possible to operate without harming people and the environment."
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