In this time of pandemics and stay-at-home orders across the country, much thought has been given to the concept of doing more work remotely. As employees have been required to work from home, the popularity of various business collaboration platforms, such as Zoom, has exploded. As businesses have come to rely on these platforms to continue their essential activities, the idea of utilizing these platforms to conduct remote PSM/RMP activities such as process hazard analyses (PHAs) for our ammonia refrigeration and other highly hazardous chemical processes has grown to a fever pitch.
There are many arguments in favor of a remote PHA. First, it allows us to safely maintain social distancing as required with the current state of emergency due to COVID-19. Second, it allows for more team members to participate while avoiding travel time and costs.
While the first argument supporting remote PHAs cannot be disputed, the reduction in travel costs is often offset by the added time that is required to conduct a thorough PHA over business collaboration video conferencing. There are often technical glitches with the computers or video conferencing platforms that need to be dealt with throughout the PHA. Correcting these issues consumes valuable time, time that is still needed for the discussion of the hazards of the process.
Another time factor that comes into play when conducting a PHA through video conferencing is “Zoom Fatigue.” “Zoom Fatigue” is real. It is challenging to remain focused and engaged in a video conference for more than about six hours at a time. This requires more days to complete the PHA properly. An argument against this six-hour limit is to simply “take more breaks.” While taking more breaks is certainly an option, meeting over a remote platform makes it difficult, if not impossible, to corral team members and get them back on task. In addition to trying to corral team members from breaks, an online platform makes the team members extremely susceptible to the desire to multi-task. More often than not, attendees are involved in checking and responding to emails, answering phone calls, or even addressing in-person issues when on a video/conference call, instead of giving full attention to the task at hand. This makes team engagement difficult and dramatically reduces the effectiveness, and hence the quality, of the PHA.
Team member engagement is driven by the facilitator. Most facilitators rely on eye contact, body movement, and voice inflection to help keep the team members engaged in the discussion. This is difficult at best over a video link. It is downright impossible if any of the team members do not have a video connection and only participate in an audio connection.
Sharing of documents and information is more time consuming using a remote platform. First, any documents that are not in an electronic format must be scanned in order for the team to look at them. Often a scanner is not available or cannot handle the physical size of the document. This leads to attempts to share the document using cell phone cameras. This method is time-consuming at best and often unreadable at worst. Second, it is often impossible due to screen size and resolution to look at multiple documents simultaneously over a video link. When the team is gathered around a conference room table, they can very quickly scan multiple large drawings and collaborate on interpreting them.
It is necessary for the team members to understand the basics of the methodology being used to conduct the PHA. This is why at least one team member must be knowledgeable in the methodology, so that they may guide the team. This guidance is more difficult for the facilitator to provide, given the reduced engagement experienced over a video link. It is often difficult for the facilitator to identify a look of confusion, frustration, or boredom over a video link. It is much easier to do so when sitting across from each other at a conference table.
Finally, perhaps the biggest pitfall associated with a remote PHA is the loss of the ability to take “field trips.” Often, when discussing a hazard or failure scenario, there is ambiguity in the documentation, and memories are vague. When conducting a PHA on site, the team can get up from the table and walk out and look at the area in question. With a remote PHA, this capability is lost. If someone from the site is participating via the remote video link, they could go out and take photos of the area in question and come back and share them with the team. This is not ideal since often pictures don’t tell the whole story, and things may be missed if people only see the picture.
PHAs conducted remotely over a video conferencing link are a viable option for certain types of PHAs. For instance, when conducting a limited scope PHA for a change being conducted under Management of Change, a remote PHA may be a good option. This would depend upon the quality of the available documents supporting the proposed change. When a PHA is being revalidated, and the previous PHA had not been cited for deficiencies in its conduct, a remote PHA may be a good option, providing that a portion of the team members who are knowledgeable of the process being analyzed took part in the previous PHA.
There are many instances where a facility should think long and hard about the potential pitfalls of conducting a process hazard analysis over a remote video conferencing link. If the facility has no existing PHA, if the previous PHA methodology and level of thoroughness were cited by regulators, or if the proposed PHA team consists of few members who took part in the previous PHA, then an on-site PHA should be strongly considered.
About the Author: Bill Lape is a Project Director for SCS’s Risk Management Group in our SCS Tracer Environmental Division. His expertise is in the development and deployment of standardized Risk Management and Process Safety Management (PSM) Programs, including process safety program implementation and PSM support to manufacturing facilities that utilize ammonia as a refrigerant. Prior to joining SCS, he served as Director of EHS Programs and Compliance for Dean Foods where he directed a team of professionals who provided PSM/RMP support, as well as support for stormwater, wastewater, and air permitting at the company’s facilities.
