If full- and partial-stroke testing has been accounted for from the very beginning, then the period between tests has also been included in establishing the SIL value for each safety loop (SIF). When the production times are extended without considering the impact on full- and partial-stroke testing, the process is very likely operating in a degraded, less capable state.
Partial-stroke testing is recognized within safety standards as a permissible way of extending the period between full-stroke testing; but the standards also caution that you can't use partial-stroke testing as a substitute for full-stroke testing. (See graphic, "Usefulness of Partial-Stroke Testing.")
What Gomer is telling Mr. B. is that because of the corporate mandated to extend plant operating schedules by default, that mandate also extended the testing periods of the time between full-stroke testing of safety loops and that is a problem.
Note: There are a number of process plants worldwide that are running much longer between planned shut-downs than they did just a decade ago. Unless those plant owner/operators have reviewed, recalculated and possibly redesigned (upgraded) each of their safety loops to accommodate the longer times between full-stroke testing, there is a very good possibility that they are not in compliance with industry safety standards, at least part of the time.
"Mr. B., I know I don't have to tell you how OSHA feels about IEC 61511 and IEC 61508.”
Like many of us, Mr. Barns probably didn't have a clue about OSHA's take on IEC 61511 and IEC 61508, and so he likely nodded his head knowingly.
Well sometimes that's okay, but when most people hear the term OSHA (U.S. Occupational Health and Safety Agency), or some similar regulatory agency, they immediately go into "pay attention" mode.
The two IEC documents have been internationally recognized as consensus standards written specifically for electrical/electronic/programmable electronic safety-related systems. That means that these standards represent "good engineering practice."
IEC 61508 came first, and it is quite detailed. It was developed to cover a variety of industries. IEC 61511 is a process-industry interpretation of IEC 61508, thus in many places, IEC 61511 references back to IEC 61508.
For the purists among us, IEC 61511 began life as ISA S84. S84 was harmonized with IEC 61511 in 2000. At the time of harmonization, S84 retained a "grandfather" clause. The concept of the "grandfather clause" in ISA-84.01-2004-1 originated with OSHA 1910.119.
The grandfather clause's intent is to recognize prior good engineering practices (e.g., ANSI/ISA-84.01-1996) and to allow their continued use with regard to existing SIS. The grandfather clause (ISA-84.01-2004-1 Clause 1.0 y) states: "For existing SIS designed and constructed in accordance with codes, standard, or practices prior to the issuance of this standard (e.g., ASI/ISA-84.01-1996), the owner/operator shall determine that the equipment is designed, maintained, inspected, tested and operated in a safe manner."
The grandfather clause establishes that the owner/operator of an SIS designed and constructed prior to the issuance of the standard should demonstrate that the "equipment is designed, maintained, inspected, tested and operating in a safe manner." There are two essential steps:
The ALARP (as low as reasonable practicable) concept requires that the risk be driven lower when the costs are practical. New practices sometimes include practical things, such as very affordable SIS solutions. The civil court and regulatory systems also seem to want them. So, there are cost and moral arguments for moving forward with partial upgrades as they become practical and feasible.
Technically, the S84 committee documented in TR84.00.04 that the determination had to be at least based on a risk assessment of the current design and management system to determine the risk reduction required and verify that the installed systems are capable of achieving it.
Practically, the equipment performance is estimated for the purposes of the design calculation. Then the performance is monitored in the field and when the performance does not match expectations, the assumptions have been invalidated and the risk gap must be addressed. This involves root cause analysis to understand whether the frequency of failure can be reduced. In some cases, this will result in the replacement of the existing equipment with better-performing models.
Ultimately, each SIS solution is likely to organically evolve as problems are found or when better technology becomes available that has advantages that outweigh its costs.
The key principles of both IEC standards are the:
The safety life cycle is just what you imagine; a continuous review and improvement cycle that has been designed to specifically address the safety system from its initial design to its eventual retirement.
We've already discussed SIL (safety integrity level) so we won't rehash it here.
To understand Gomer's comment "…how OSHA feels about IEC…" we need to look at two items.
The first is the U.S. National Technology Transfer and Advancement Act of 1995. This act requires that all federal agencies (i.e., EPA, FDA, OSHA, etc.) recognize existing consensus standards, such as IEC 61511 and IEC 61508. That means that all government agencies have been instructed to accept the premise of consensus standards and abide by the standards' requirements.
Second, in 2000, OSHA sent a letter to ISA. In that letter OSHA acknowledged that S84 (now IEC 61511) had been officially recognized and generally accepted as good engineering practices for SIS.
Additionally, though OSHA's 1910.119 (PSM – Process Safety Management) regulation does not include specific information on the requirements for safety systems, it does require that facilities perform a process hazard analysis (PHA) and take measures to mitigate identified risks. OSHA's mention of safety systems is simply, "The employer shall document that equipment complies with recognized and generally accepted good engineering practices." When we consider that simple statement alongside the 1995 Technology Transfer and Advancement Act, we can only conclude that IEC 61508 and IEC 61511 or something very similar, must be followed.
What Gomer was subtly reminding Mr. Barns was that if the plant had an incident that resulted in an OSHA investigation, the investigators would quickly realize that the plant was not conforming to IEC safety standards, and fines would most certainly be levied and someone might even end up going to jail.
AND HERE IT COMES