What could be safer than food processing? This industry processes consumable products - wheat, corn, soy, sugar, dextrose and oils. With respect to process risk evaluation and mitigation, the food processing industry does not have the history in education, perspective or analysis that the chemical process industry has. The food processing industry does not fall under either the OSHA grain handling guidelines or the OSHA CFR 1910.119 PSM and PHA regulations. Consequently, there is a paucity of process documentation, mechanical integrity information, contractor controls, near-hit analysis and so on. These observations apply to an industry which has confined explosive properties exceeding those of coal dust, toxic materials exceeding the properties of ammonia and flammable materials equivalent to gasoline. But, they don't perceive that they are working in an environment laden with hazards with avenues for their escape.

This presents a challenging environment to the process risk analyst. Tolerable risk tables on the economic scale of the food processors must be developed. Layers of protection consistent with the sophistication of the industry must be identified and specified. Hazards, readily apparent in the CPI, must be explained to food industry personnel. But the most significant challenge is to educate the industry to look beyond intended performance to identify their hazards and project avenues for their escape.

This paper presents the experience of five years of working in the food processing industry to develop the sophistication necessary to identify hazards and evaluate risks in an industry which has largely escaped the focus of government oversight. The Imperial Sugar excursion coupled, to some extent with DHS pressures, however, has intensified both the internal and external pressure to implement PSM and PHA. This paper presents experiences upon which others can build to reduce the inertia and to speed implementation of PHA and PSM. Specific evaluation criteria and excursion examples will be discussed.