Tracks & Schedule

In this session we will discuss the application of human factors analysis (HFA) to identify and mitigate performance-related risks in complex systems. Attendees will learn to use the HFA method as a tool to improve human performance by addressing both active errors and latent conditions, and will apply these principles through a realistic case study, focusing on improving safety and operational resilience.

After examining various incidents locally and across industry, a common theme began to emerge. There was a noticeable gap between theoretical knowledge of process safety fundamentals and their practical application. This gap was largely due to a lack of hands-on experience, caused by natural staff attrition as well as a lecture-based training approach.  As a result, the workforce understood process safety theory, but lacked the practical skills to identify hazards and implement mitigations in real-time. This led to a reliance on tools and work processes, reducing the need for critical thinking and holistic problem-solving where the workforce could effectively answer the ultimate question:  How do I know it is okay?  Additionally, there was a tendency to depend on a few experts rather than cultivate practical process safety knowledge across all team members. This resulted in a tenuous, unsustainable process safety management structure and highlighted a clear case for action. This presentation will explore a novel, interactive training approach that has been used to successfully develop a practical process safety skill set by focusing on the difference between lecturing and learning.

Facility Siting is a fundamental part of a process safety management system, and is at the heart of providing necessary protection to onsite employees and contractors.   Past incidents have demonstrated the importance of an appropriate approach to facility siting, with the need to consider all potential hazards.

Recent EPA RMP updates in 2024 require, among other things, consideration of hazards posed by proximate facilities, and accident release consequences posed by proximity to the public. These new requirements are causing companies to re-evaluate their existing facility siting studies.

With updated editions of API RP 752, 753 and 756 being released in January 2024, there are many additional requirements which should be considered. One update from the latest editions is the refuge concept, where a building or room could provide protection as either a safe haven or a shelter-in-place.

This presentation provides clarity on the different facility siting refuge options, as well as discussing the different types of hazards that a refuge may be required to protect against. Guidance is also provided related to evaluating hazards from proximate facilities to comply with the EPA RMP requirements.

This is a combined session with our Process Safety  and Environmental Hot Topics Tracks.

TCEQ adopted new 30 Texas Administrative Code Chapter 338, Aboveground Storage Vessel Safety Program, to implement the statutory changes to the Texas Water Code made by Senate Bill 900 during the 87th Legislative Session. The regulations identify the safety standards required by the statute and the entities regulated. The safety standards come from both federal regulations and national consensus standards. The program is intended to provide protection of groundwater and surface water resources in the event of an accident or natural disaster.

Regulated aboveground storage vessels (ASVs) under this program are made of non-earthen material, have a capacity of 21,000 gallons or more, store a regulated substance, and are located at a petrochemical plant, petroleum refinery, or bulk storage terminal. There are also specific exemptions set out in the rule.

Owners or operators of ASVs must register with the TCEQ and pay the annual registration fee by September 1, 2027. Owners or operators must certify compliance with the applicable safety standards by September 1, 2037, and then every 10 years thereafter. TCEQ will conduct on-site inspections at least once every five years to determine compliance.

TCEQ will discuss the requirements and deadlines for the new program and will provide updates on the status of the registration database, future outreach plans, and the guidance document currently under development.