CGA’s P-86 Publication Guides Process Safety Management in Industrial & Medical Gas Facilities
June 17, 2021
For those organizations looking to adopt a holistic and systematic approach to assuring the integrity of their operations, process safety management has a vital role to play. First published by the Compressed Gas Association in May 2020, CGA P-86, Guideline for Process Safety Management, provides guidance to improve process safety across the industrial and medical compressed gas sector.
Created in response to a recommendation from the CSB (U.S. Chemical Safety and Hazard Investigation Board), the publication of CGA P-86 received the CSB’s highest commendation – “Exceeds Recommended Action.”
As the CSB observed at a public meeting in April 2021, CGA P-86 provides “detailed guidance on 21 elements that fully implement a process safety management system necessary to manage known process safety hazards […and…] cover all processes within the industrial and medical gases industries.”
A Process Safety Management Framework for the Compressed Gas Industry
The process safety management framework provided in CGA P-86 may be applied to all processes within the industrial and medical gases industry. The intent of this publication is to make process safety management understandable beyond the requirements found in U.S. Occupational Safety and Health Administration (OSHA) PSM regulations.
CGA P-86 is designed to address process safety hazards and to be equally suitable for processes found across the industry, including:
- air separation units (ASU) and nitrogen generator facilities
- hydrogen and carbon monoxide (HYCO) production facilities including electrolysis facilities
- hydrogen purification units
- acetylene production facilities
- nitrous oxide production facilities
- carbon dioxide production facilities
- cylinder and container filling facilities
- specialty gas production, package filling, and storage facilities
- chemical handling and transport facilities
- customer installations
A “facility” may include the main production plant, as well as any ancillary equipment where process hazards exist.
The decision to apply various process safety management elements to a given process should be made by evaluating the risk tolerance and agreeing on the management approach. For example, transportation and pipeline risks may be managed by applying national and international codes and might not require the application of all elements of the process safety management framework provided in CGA P-86.
In some countries, there can be existing regulatory requirements for process safety management systems. This framework is not intended to replace these requirements but may be used to supplement them.
21 Essential Process Safety Management Elements
The process safety management elements in CGA P-86 cover all key aspects needed to assure the integrity of industrial and medical compressed gas operations.
This publication includes a total of 21 process safety management elements:
- Element 1 – Leadership commitment and responsibility
- Element 2 – Compliance with legislation and industry standards
- Element 3 – Employee selection, training, and competency
- Element 4 – Workforce involvement
- Element 5 – Communication with stakeholders
- Element 6 – Hazard identification and risk assessment
- Element 7 – Documentation, records, and knowledge management
- Element 8 – Process and operational status monitoring and handover
- Element 9 – Operating procedures
- Element 10 – Management of operational interfaces
- Element 11 – Standards and practices
- Element 12 – Management of change
- Element 13 – Operational readiness and process startup
- Element 14 – Emergency and crisis management
- Element 15 – Inspection and maintenance
- Element 16 – Management of safety critical devices
- Element 17 – Work control, permit to work, and task risk management
- Element 18 – Contractors and suppliers – selection and management
- Element 19 – Incident investigation
- Element 20 – Audit, management review, and intervention
- Element 21 – Measures and metrics
For each element, an overview is provided, followed by a series of guidelines defining what organizations need to address specific to that topic.
Process Safety Management for New Systems and for Benchmarking
The process safety management framework in CGA P-86 is intended to provide the basis for the development of a process safety management system for those organizations that do not already have such a system in place. This framework may also be used as a common basis for benchmarking existing process safety management systems.
Organizations that have an existing process safety management system or integrated management system that incorporates health, safety, and environmental and process safety management, may choose to carry out a gap assessment versus the requirements of each element in order to identify any aspects of the system that need to be enhanced.
Once the initial assessment has been completed, the significance of the gaps should be determined, and a prioritized plan developed to address identified issues. In some cases, there can be a significant program of work needed to upgrade the management system to contain all of the elements of the process safety management framework.
For more details about this safety standard, the full Table of Contents may be downloaded for free from the CGA P-86 publication details page on the CGA portal.
CGA P-86, Guideline for Process Safety Management, is issued as part of a program of harmonization of industry standards, jointly produced by members of the International Harmonization Council.