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“Common sense is lost when it isn’t handed down by senior engineers mentoring young engineers,” Summers says. “Documented internal practices must be periodically updated to reflect current practices, and good engineering practices need to be published,” she continues. “In addition, changes in operability, functionality, reliability or maintainability expectations may require implementation of more rigorous design or management practices. Also, proof test, failure investigation, alarm, trip and audit reports may indicate the need for improvement, and users must continuously monitor existing system performance so gaps in common sense are closed.”
Looking at the sheer number of refinery accidents, it might seem that most happen at U.S. facilities, but there is little or no thorough, historical accounting to confirm this anecdotal evidence. One of the most current studies, published in 2004 in AIChE’s Process Safety Progress concluded, “We identified that: (a) there are some problems with the government databases, (b) even with these problems, some important information can be extracted, and (c) descriptions of accidents are especially useful and educational. Some surprising and useful conclusions have also been developed; e.g., (a) major accident performance is continuing to degrade, (b) although PSM may be making a mark, something else is needed to improve industry’s accident performance, and (c) runaway reactions continue to be a significant cause of major accidents.”
European and other facilities worldwide have had significant accidents, but apparently on a less regular basis than in the U.S. If there are more accidents in the U.S., some observers say it may simply be because the U.S. has more refining operations and capacity, or that Europe regulates more closely because its denser population puts its refineries generally closer to populated areas.
There’s less debate about the fact that regulators in Europe have greater authority than their U. S. counterparts to inspect and enforce process safety rules before plants are built, when they’re operating and after incidents occur, and that civil and criminal penalties are more severe for violators. The bulk of OSHA’s and other U.S. authorities’ regulatory presence occurs after accidents happen.
Going beyond guidelines, IEC 61511 has been adopted as national law in Spain, Belgium, the Netherlands and Australia. In fact, following one disaster, Australia’s government passed an industrial manslaughter law mandating jail time for plant managers found guilty of contributing to staff fatalities. According to former ExxonMobil safety guru and director of Invensys’ Premier Consulting Services, Bob Adamski, “We get lots of people from Australia going through our training classes to become TÜV-Certified Functional Safety Experts because they’ve found they can’t work without the certification.”
Though industrial regulations supposedly lag in the former Third World, several Asian nations with growing refining operations reportedly are studying European and Australian regulatory model and plan to adopt similar rules.
“When we recently proposed several jobs in Hong Kong and some smaller Asian countries, they all stated that we had to conform to IEC 61511,” reports Adler. “The larger, more sophisticated process applications are trying to follow these standards, but many of the mom and pops are fighting it kicking and screaming because they don’t understand that process safety can pay for itself.”
Substandard Use of Standards
Widely varying facilities, technologies, applications, risks and other factors make it hard to draft process safety standards that can be applied to all settings in each process industry, let alone one that can be applied across all of them.
Still, there are common threads, which led International Electrotechnical Commission’s (IEC) developers to draft its 61508 and 61511 standards and updates. ISA and its SP84 committee adopted IEC 61511 as the ANSI/ISA S84.00.01 standard and revised it in 2004. OSHA recently recognized S84 as one of its Recognized and Generally Accepted Good Engineering Practices.
One important difference between IEC 61511 and ISA S84 is a grandfather clause that encourages non-compliant applications to be updated, but allows them to continue operating if they’re doing so safely until the application is renovated or otherwise altered.
The grandfather clause, it should be clearly noted, is not a license to keep on with the status quo ante. As Dr. Summers noted in her article for Control, “The Grandfather Clause Is Not a Jolly Fat Man in a Red Suit” (August 2005), all that the grandfather clause does is provide for not having to do a “rip and replace” in order to assure compliance with current standards. You’re still expected to do all the engineering, training, testing and continuous improvement necessary to meet the current standards.
Summers adds the American Institute of Chemical Engineers’ (AIChE) Center for Chemical Process Safety is is publishing a new book, Guidelines for Safe and Reliable Instrumented Protective Systems (IPSs), to expand on the SP84 committee’s effort to address the development and implementation of a comprehensive management system.
“Where S84 focuses on the life cycle of one layer of instrumented protection—the SIS—this new IPS book provides requirements and guidance for any instrumented system identified as providing risk reduction during a process hazards analysis,” she says.
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