The April 2010 Deepwater Horizon tragedy and release from the Macondo Well resulted in a re‐examination of the existing regulatory framework, significant modifications to the structure and function of key regulatory agencies, and the application of new Safety Management System requirements to offshore facilities in United States waters. Late‐2010 witnessed the evolution of both prescriptive and performance‐based regulations designed to address the direct and underlying causes of this tragedy. The objective of this article is to briefly review these new regulatory requirements and illustrate how they are related to the application of other Safety Management Systems, for both offshore and onshore facilities. The common themes, objectives, and overlaps of specific onshore and offshore Safety Management System elements was examined, and tips on how these overlaps can be used to more effectively (and sensibly) implement these programs is discussed. This article also outlined successful Safety Management System programs that are being applied by various state agencies to onshore and offshore coastal facilities, and derived lessons‐learned from these programs that may assist in the implementation of related federal programs. © 2016 American Institute of Chemical Engineers Process Saf Prog 35: 317–329, 2016
Specific requirements exist in all Safety Management Systems Requirements (e.g., Process Safety Management and Risk Management Program) for the creation, content, and periodic update of operating procedures (OP). However, the development and actual implementation of OP has challenges that often result in deficiencies, regulatory citations, and in some cases, unfortunate tragedies.Although OP concepts involve the straightforward documentation of specific steps for safe and effective operation, many process facilities struggle with:•securing the focus from operations personnel for the creation of quality procedures•securing feedback from operations personnel if procedural steps do not coincide with actual practices•ensuring the steps outlined in procedures avoid introducing additional process hazards•creating procedures that are in a user-friendly format •identifying the most effective level of information and depth to include in the procedure•addressing all modes of operations, including defining appropriate responsibilities Good-quality OP are critical for encapsulating operational best practices and also provide a basis for ensuring consistent quality assurance. The objective of this article is to convey an understanding of the challenges that must be considered with the development of OP and provide specific examples that will facilitate the creation and ongoing application of OP.
While safety instrumented systems (SISs) can be an essential element of process facility design to minimize the potential for process incidents, in some cases they can also be over-applied in the design phases of capital projects where the safety instrumented functions (SIFs) associated with the SIS are defined before the process hazards have been fully characterized. This approach may provide one mechanism for achieving a robust process control system design; however, the application of SIS also brings increased costs associated not only with the robust equipment needed to meet safety integrity level (SIL) requirements but also with the ongoing maintenance, testing, and procedures required throughout the SIS lifecycle. In order to balance the important safety benefits associated with the SIS with the increased capital costs it is critical to have a specific and comprehensive basis for decision-making. This article will illustrate the value engineering benefits of using the combined Hazard and Operability (HAZOP) Study and Layer of Protection Analysis (LOPA) methodology to comprehensively evaluate a design and provide a decision-making platform for determining whether protection for process hazards should be implemented using a SIF, a basic process control system (BPCS) feature, or alternate safeguard categories (e.g., relief valves, alarms, etc.) to ensure an adequate level of reliability without compromising safety. When the HAZOP/LOPA Study is performed following the value engineering session, the HAZOP/LOPA Study provides a critical cross-check to ensure safeguards are adequate and that changes made during the value engineering study do not introduce additional hazards. In contrast, when the HAZOP/LOPA Study is performed prior to the value engineering session, it provides a basis for decision making to remove SIFs or switch the function to the BPCS when the risk was determined to be low by the team (as defined by specific operating company criteria).
This paper discusses a process hazard management study of a fuel gas conditioning facility based on state-of-the-art fault tree analysis techniques. This facility lowers the water and hydrocarbon dewpoints of a high pressure fuel gas exposed to frigid temperatures during distribution. Using hazards checklists and guidelines as well as internal reviews, various process hazards were identified for this facility. Computerized fault tree analysis techniques were used to identify the failure sequences which could lead to process hazards, and analysts used these results to evaluate the impact of specific hazards upon process safety. Through recommendations presented in the study, the facility owner gained an increased awareness of potential problems and made modifications to reduce the possibility of a hazardous condition and subsequent catastrophic failure.Dans cet article, on prtsente une ttude de gestion du risque d'un syst&me de conditionnement de gaz combustibles baste sur les techniques les plus rtcentes d'analyse par arbre d'erreurs. Ce dispositif a pour objectif d'abaisser les points de roste de I'eau et des hydrocarbures dans un gaz combustible a haute pression qui doit Ctre expost a de basses temgratures lors de sa distribution. Plusieurs risques ont pu &tre identifits pour cet appareillage en utilisant les listes de vtrifications et les consignes donntes ainsi que des rapports internes. On a utilist des techniques d'analyse informatiques par arbre d'erreurs afin d'identifier les stquences de malfonctionnement susceptibles de conduire a un danger et des analystes ont utilist ces resultats pour tvaluer I'impact d'tvtnements fortuits sptcifiques sur la stcuritt du proctdt. Grice aux recommandations prtsenttes dans I'ttude, le proprittaire de I'installation est devenu plus conscient des probltmes pouvant survenir et a pu faire des modifications pour diminuer la probabilitt des catastrophes qui peuvent en dtcouler. his paper describes a study undertaken by Westinghouse T to evaluate process safety for a fuel gas conditioning facility through the application of hazard identification and assessment techniques (Leach et al., 1985). At the request of the client, Westinghouse used qualitative fault tree analysis to evaluate process safety and to recommend modifications to reduce the risk to process safety. Additionally, the customer was able to use the results of this analysis to: -Identify corrective action to avoid safety hazards and to minimize the possibility of financial loss and unscheduled downtime caused by system failures, accidents, and operability problems -Create a "living" system reliability model to continually evaluate the cost and benefits of proposed process modifications and operations changes -Identify those areas where increased operator awareness could most readily increase safety or reduce financial risk, or where relaxed operating procedures would minimally affect risk or reliability -Improve public relations by making a conscientious effort to reduce risks to public health and safety Computeriz...
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