Unscrambling safety regulations

What You Don’t Know
Understanding all the aspects of safety is a daunting task. Mike Reilly, an engineer at Flint Hills Resources, a refining and chemical company in Wichita, Kan., says he understands his safety rules…he thinks. “But you don't know what you don't know,” says Reilly.

In a recent survey of Control’s readers, we asked: “Do you understand all the safety requirements that apply to your plant, such as ISA S84, SIL, PSM, ESD, etc.?” More than half the respondents answered “no.”

Chris Conklin, senior engineering specialist at Dow Corning Corp. in Midland, Mich., says he too doesn’t understand all of his safety requirements. “We went through a major workforce reduction a few years ago, and we lost significant knowledge regarding instrumentation, process controls, and safety instrumented systems,” he explains. “So, to answer the question honestly, I would have to say we don’t understand all of the safety requirements that apply to our manufacturing site with respect to safety instrumented systems.”

So who does? “Basic safety responsibility and authority currently resides in the safety and loss control department,” adds Conklin. “However, as far as I know, no one in that group has the knowledge or understanding about the safety requirements with respect to S84, SIL, ESD, etc. In our group, we recently identified this as an issue, and we’re seeking someone who can become our subject-matter expert in safety-instrumented systems.”

Len Laskowski, Emerson’s technical consultant and engineering fellow, adds, “Today nearly all companies are experiencing the lack of staffing to deal with all the new regulations, standards, and other issues. Some companies with long-established guidelines dealing with SIS systems are updating their internal standards to stay current with international standards such as IEC61511. Others, who had no or minimal guidelines, find it easier to just adopt the new standard. Some companies are still trying to assess the new standards, and determine what they must do to be compliant, and there are a few that have yet to do anything.”

Louis Szabo, business development manager at Pepperl+Fuchs, says end users are confused about safety requirements. “For instance, in one case, a customer used a ‘rule of thumb’ they obtained from Exida that provided parameters for a generic IS barrier,” he says. “Their understanding of MTBF data was incorrect, as was their understanding of SIL1 through SIL4. To them, MTBF meant ‘Mean Time Before Failures,’ instead of the actual ‘Mean Time Between Failures’ definition. SIL1 meant one year, SIL 2 meant 10 years, SIL3 meant 100 years, and SIL4 meant 1,000 years. This misconception was cleared up, and they’re now safer for it. In another case, a customer’s safety system was never tested. They experienced a failure in the primary control system, and the back-up never triggered, resulting in a chemical spill and a $10,000 EPA fine.”

Charles Fialkowski, product manager at Siemens Energy & Automation has similar horror stories. “I've heard some major oil and gas companies say, ‘Most here don't know how to spell SIL,’ which is rather scary. While I don't question their corporate knowledge, it's usually the local plants that are hurting the most for information and knowledge. From my personal perspective, over the past 10 years, I’ve seen considerable increase in knowledge and awareness across the board, which is very encouraging.”

Read the Manuals!
Unfortunately, improving safety is complicating by safety’s own standards nomenclature. Laskowski explains, “Just for the record, ANSI/ISA 84.00.01-2004 Part 1 is really IEC 61511-1, with the exception of clause 1y, the grandfather clause. This is frequently referred to as S84 in SIS circles. This standard doesn’t govern development of equipment to be used in SISs, nor does OSHA’s STD 29CFR1910.119, commonly referred to as PSM. Instead, Emerson and other vendors use IEC61508 as the benchmark to develop hardware and software for equipment that will be SIL rated and then TÜV certified as acceptable to use in SIL-rated applications.” No wonder so few users understand safety issues.

Scott Hillman, safety management systems manager at Honeywell, is TÜV-certified, so he appreciates how tough it is to get up to date. “Users are taking safety rules very seriously, and are earnestly attempting to meet these requirements,” he says. “They’re struggling with interpreting the standards, how to apply them, and what resources they have to implement them. A few end-users have the capability to respond internally. Most customers, however, will make use of the safety expertise available at Honeywell or other supplier organizations to implement their safety requirements into a safe, available, user-oriented safety solution. They realize that safety isn’t just a regulation they have to meet, and that it’s good business to operate their plant safely.”

The cost of safety is often misunderstood, too. Connie Chick, manager of the PACSystems group at GE Fanuc, says users are confused. “They are getting confused a lot of times by our own industry, which sometimes uses safety as a selling point. The customer doesn’t understand what a ‘total installation’ requires. For instance, a SIL-3 triplicate system can involve triplicated everything—I/O, devices, etc.—which then becomes really expensive. Jumping to that level is a real cost hit, and you need to understand whether it’s truly required for the application.”