Process safety - staying ahead by cdk16647


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Process safety – staying ahead
SreeRaj Nair reports on IChemE’s safety compliance roadshow
SAFETY is a fundamental requirement in the             analysis (LOPA) and SIL (safety integrity
process industries, nowhere more than those            level) ratings, with that required to develop
dealing with hazardous materials.                      PSPIs. This ‘one stone, two birds’ approach
   Authorities enforce a range of regulations such     helps companies comply with regulations
as Europe’s Seveso II directive, implemented in        while avoiding ‘initiative overload’.
the UK through the Control of Major Accident
                                                       learning from experience
Hazard Regulations 1999 (COMAH), which aims to
prevent and control major accidents.                   Jo Fearnley, senior consultant for
                                                       environment, health, safety and risk
   Those industries classified as hazardous
                                                       with Aker Solutions, shared the learning
under the COMAH regulations need to justify
                                                       experience from conducting five-year
and ensure that the risk is as low as reasonably
                                                       COMAH resubmissions. She talked through
practicable (ALARP) – something that is typically
                                                       recent changes to the regulations, authority
done with the help of safety reports and other
                                                       expectations and the best approach to
studies. Documenting the risks in a ‘one-off’
                                                       address the challenges of resubmission,
exercise is not enough, as many elements of the
                                                       particularly the new safety report                  The roadshow highlighted the significance of compliance
protective measures change over time. So it is
                                                       assessment manual and its requirements; how
also mandatory to keep the safety report and
                                                       to best define the scope of the report update/      with occupied building risk assessment included
associated records updated with any change or
                                                       re-writing; the ongoing shift in predictive risk    in the predictive information. He says that the
modification of the plant, facility or technology;
                                                       assessment towards quantitative assessments;        definition of what constitutes an ‘occupied
the documentation has to be reviewed and
                                                       and changes to the cost benefit analysis and        building’ can be unclear, and this is something
updated at least every five years.
                                                       ALARP justification. ‘Just for worst case events’   the revised guidance will seek to clarify.
   Over time, regulations are revised as the
                                                       studies are no longer adequate, she says.
understanding and thinking of operators, the                                                               Flixborough lessons
public and regulators on risk changes. It can be a     practice makes perfect                              June 2009 also marked 35 years since the
challenge for safety professionals to keep up with     Denis Hampson, head of the Cleveland emergency      Flixborough disaster – an opportunity to
these changes. IChemE’s recent safety compliance       planning unit, highlighted the importance           remind industry of the lessons learnt. A poster
roadshow for the process industries highlighted        of developing effective on-site and off-site        presentation by Jonathan Tan and SreeRaj Nair
the significance of process safety compliance and      emergency plans, backed up by training and          of Aker Solutions asked questions such as:
discussed the changing trends in the industry          mock exercises. The audience was particularly       How different are current practices for plant
and the approach of the regulators.                    interested in the intricacies of sharing            modifications? Do companies use management
                                                       information with the local authority and the        of change procedures for each and every
COMAH changes
                                                       public.                                             modification? Are emergency plans in place and
The Health and Safety Executive’s Sarah Shore,
                                                                                                           up to scratch, do they consider domino effects,
who currently leads the re-modelling of COMAH,         DSEAR requirements                                  and do they cover all scenarios? Have companies
used the opportunity to outline proposed               The Dangerous Substances and Explosive              modelled the consequences of an accident
changes. They include establishing a Committee         Atmospheres Regulation (DSEAR) and its              using suitable software, is the potential harm
of Competent Authorities (CCA), which would act        requirements for non-electrical equipment was       to humans and the environment understood and
as a unified competent authority for enforcing         the focus of ABB’s Steve Sherwen and Malcolm        appropriate responses clear? Do management
COMAH in the UK; improved operational                  Horne of Artenius. Recent changes to DSEAR          systems adequately address process safety, and
intelligence to support operational decision           have seen improvements to understanding             does management use proper practices to identify
making; transparent risk ranking to identify the       the conditions such as maintenance schedule         and manage risks?
sites presenting highest risk and transparent          prior to purchasing; maintaining the
performance rating systems that would identify         declaration of conformity after any repairs         summary
failing organisations. The CCA is expected to          or modification; awareness training for the         Major accidents still occur; and a lot more
have dedicated site inspection teams, would            technical team and sourcing personnel; adding       care needs to be taken within process safety
intervene on fewer but more strategically-             mechanical engineering input in hazardous           management. Although there is plenty of
important topics, and provide industry with            area classification; the inclusion of procedural    guidance, with acts and regulations in place, it is
simple, clear expectations. In addition, the           control on portable mechanical equipment in         often difficult for a process safety professional to
requirements for the safety report would see           hazardous areas; and appropriate identification     be sufficiently up-to-date with the latest changes
a reduction in the paper-based assessment in           (specifications, build plans etc) of equipment in   in every field. Events such as this roadshow are a
favour of increased site verification.                 hazardous areas.                                    key forum for safety professionals, management
                                                                                                           and competent authorities to share experience,
process safety performance indicators                  location, location, location                        best practices and knowledge. tce
Rob Peeling, operations manager with the               Finally, Ken Norrie, project manager with BASF,
Johnson Matthey subsidiary Vertec, discussed           who is also a member of the CIA working group
a unique methodology for developing process            revising current guidance for the location                              SreeRaj Nair (sreeraj.nair@
safety performance indicators (PSPIs) from the         and design of occupied building on chemical                    is a
facility process hazard identification records. His    process manufacturing sites, detailed the current                       process safety specialist
approach unifies the hazard identification and         statutory requirements and upcoming changes to                          currently working as
risk analysis exercise for a range of process safety   the guidance. Safety in occupied buildings should                       principal engineer with
activities including COMAH, layer of protection        form an integral part of a COMAH safety report,                         Aker Solutions                                                                                                                  october 2009      tce 67

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