(32bx) Hazardous Chemical Management Noncompliance Observations Based on Audit Experiences

Title: Hazardous Chemical Management Noncompliance Observations based on Audit Experiences

Authors: Mr. Seckin Gokce and Dr. Tekin Kunt, PSRG

Effective management of hazardous chemicals is critical to ensuring process safety, yet noncompliance with established protocols remains a persistent challenge across various industries. Hazardous chemical management is not only a regulatory requirement but a cornerstone of process safety. While much attention is given to incidents that have occurred, a significant area of focus should also be on recognizing and mitigating the risks associated with incidents that have not yet happened. This presentation delves into common noncompliance issues identified during extensive global audit experiences. By examining recurring deficiencies in hazardous chemical management, such as operational discipline lapses, inadequate risk assessments, and gaps in emergency preparedness, the discussion aims to highlight the underlying causes and suggest best practices for improvement.

The most common type of non-conformities observed during process safety audits are as follows:

• Operational Discipline
• Management of Change (MoC) System
• Process Hazard Analysis
• Training and Competence
• Emergency Response and Planning
• Safe Handling and Storage of Chemicals
• Lessons Learned

Beyond addressing the visible nonconformities, this presentation also emphasizes the importance of recognizing and mitigating the risks associated with "incidents that haven’t occurred." These latent risks often go unnoticed until a near miss or a more severe event reveals them. By investigating unsafe behavior & conditions and sharing lessons learned, organizations can strengthen their hazard identification processes and improve human reliability. Additionally, the presentation will critique the current landscape of safety metrics, especially the metrics for the number of unsafe behavior & conditions challenging the industry to look beyond the numbers and understand the deeper, often overlooked, indicators of safety performance. Furthermore, the presentation will highlight the nuances of process safety culture, emphasizing the importance of fostering an environment where potential hazards are recognized and risks are addressed before they are realized.

Attendees will gain valuable insights into how audit experiences can serve as a powerful tool for identifying and addressing both existing and potential risks in hazardous chemical management. Through this lens, the presentation aims to uncover the gaps between reported safety performance and the reality of daily operations. By sharing lessons learned from audit experiences, this presentation provides valuable insights into how organizations can strengthen their hazardous chemical management practices and move towards a more robust process safety culture.

Keywords: Chemicals Management, Risk Assessment, PSM Audit