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SAFETY AND SECURITY REVIEW FOR THE PROCESS INDUSTRIESApplication of HAZOP, PHA, What-IF and SVA Reviews
By Dennis P. Nolan
Gulf Professional PublishingCopyright © 2012 Elsevier Inc.
All right reserved.
This book is intended to provide guidance to qualitative hazard analyses conducted for industrial and commercial processes, specifically for Preliminary Hazard Analysis (PHA),What-If, and Hazard and Operability (HAZOP) review teams. It also highlights how the methodology and procedures used for these reviews can be adopted and applied for Security Vulnerability Analysis (SVA). This book describes the nature, responsibilities, methods, and documentation required for the performance of such reviews. This ensures these reviews are conducted in a timely, effective, objective, and consistent manner as may be prescribed by a company's Process Safety Management (PSM) policy and security requirements. This book relies heavily on the common practices in the petroleum, chemical, and petrochemical industries since most of the major hazardous processes are located in these industries, and these facilities are increasingly becoming a potential target for security incidents.
The safety and security of process facilities are important parts of a company's operations. Worldwide petrochemical safety regulations, international security threats, and a company's own PSM policies would require that a hazard identification, process safety, and security analysis review of its existing and proposed operations be accomplished.
The limits of hazardous substances cited by both the U.S. Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) regulations dictate the application of PSM elements at almost all of a petroleum or chemical company's facilities. These reviews are intended to reduce the probability and/or consequences of a major incident that would have a detrimental impact on the employees, the public's well-being, onsite or offsite properties, the environment, and most importantly to a company itself, its continued business operation and survival. It should also be noted there may be a general adverse public reaction and, therefore, a company's prestige may suffer. Hazard identification and process analysis reviews are not intended to identify the minor "slips, trips, or falls," rather these are the responsibility of the company's general safety requirements that are well established and can be analyzed with other tools, e.g., Job Safety Analysis (JSA).
In March 2003, the United States implemented Operation Liberty Shield to increase the readiness and security in the United States primarily due to international threats from nongovernment affiliated self-motivated political and religious groups. One objective of this operation is to implement comprehensive process security management programs into existing OSHA, EPA, and FDA laws to address deliberate acts of threats of terrorism, sabotage, and vandalism. In April 2007, the Department of Homeland Security (DHS) issued the Chemical Facility Anti-Terrorism Standard (CFATS). The objectives of the DHS are to identify, assess, and ensure effective security at high-risk chemical facilities. Included in this standard are the requirements for facilities handling chemicals above a threshold amount and to submit an SVA for DHS review and approval along with a site security plan. A potential fine of $25,000 per day, an inspection and audit by DHS, or an order to cease operations is stated for noncompliance. The type and amount of chemicals handled which require submission of screening review and SVA submittals have been listed on the DHS website. Additionally, internal company security procedures, although confidential, would also require that an adequate security review be undertaken to identify and assess such risks. Since the methodology of conducting process security reviews is similar to existing process hazard analysis reviews, they can be adapted to fit within the parameters of existing procedures established for these analyses. Both American Petroleum Institute (API) and American Institute of Chemical Engineers (AIChE) have also issued their own guidelines to assist companies undertaking process security reviews. A major process safety consultant recently stated that statistics show that the use of outside security experts for the consultations of protective services has increased by 200% in the last 5 years. This was due to escalating concerns over workplace and domestic violence, privacy and security practices, and terrorist threats. Process security reviews are not intended to identify minor thefts or mishaps; these are the responsibility of the company's general security requirements that are well established and can be examined with other financial auditing tools.
The purpose of the evaluations described in this book is to identify the major risks that have the potential to severely impact the industry. It identifies simple processes and procedures to apply these reviews in an easy and practical manner.
PHA, What-If, and HAZOP reviews are the most common industrial qualitative methods used to conduct process hazard analyses, while SVAs are typically applied for process security analyses. It is qualitatively estimated that up to 80% of a company's hazard identification and process safety analyses may consist of PHA, What-If, and HAZOP reviews, with the remaining 20% from checklist, Fault Tree Analysis (FTA), Event Tree Analysis (ETA), Failure Mode and Effects Analysis (FMEA), and so on.
An experienced review team can use the analyses described to generate possible deviations from design, construction, modification, and operating intent or from deliberate actions that define potential consequences. These consequences can then be prevented or mitigated by the application of the appropriate safeguards.
The reader is reminded that a PHA, What-If, HAZOP, or an SVA report is a living document for a facility. As changes are made to a facility or its procedures, the applicable review is to be updated to represent the current facility. Process hazard analysis reviews are also required to be updated and revalidated every 5 years as a minimum by U.S. regulations (OSHA and EPA). Also, since the terrorist's agenda has not subsided, threat assessment/vulnerability analysis needs to be continually reevaluated.
A completed review report can be used to demonstrate to interested parties that a prudent analysis has been accomplished and all possible actions have been examined and/or implemented to eliminate major hazards or minimize the threat. It has been noted that the Chemical Safety and Hazard Investigation Board (CSB) routinely examines hazard analyses that have been performed on processes which they are reviewing, to ensure that they were performed adequately.
This book can also be referred to by review team members. It will serve as a reminder of their duties and responsibilities in the performance of the required reviews and report development.
These guidelines should be considered for all of a company's facilities, domestically and internationally. They are intended to be applied at both permanent and temporary facilities, whether located onshore or offshore.
The typical review is usually intended to be a formal audit review of an "essentially" complete project design or modification to ensure that the probabilities or consequences of major incidents have been eliminated or reduced to acceptable levels prior to being placed in service. Risk analyses should be continually conducted as part of the project design to avoid the identification of major concerns by the later reviews. In fact, documentation from a design risk analysis should supplement the formal HAZOP, PHA, What-If, or SVA reviews.
Process safety and security reviews are not intended to replace or duplicate a project design review. Unusually, complex or large projects may require several levels of a safety or security review during their design phase. These may be initiated at the conceptual, preliminary, detailed, and final design stages. Such levels are usually encountered in multimillion dollar offshore facilities, refinery, or chemical processing plant projects where major changes occurring later in the design would be severe in economic and schedule terms. These multilevel reviews start at a broad viewpoint and gradually narrow to specifics just as the project design proceeds. Where operating procedures are not available during the design, a supplemental PHA, What-If, HAZOP, or SVA review may be considered for these documents. In fact, an initial review may recommend that subsequent final designs be again evaluated by a PHA, What-If, HAZOP, or SVA as a follow-up. It is essential that these follow-up reviews be completed as incidents investigated by the CSB have identified failure to perform a follow-up risk analysis as a contributing factor in some incidents.
During the period of initial implementation of process safety and security management policies, existing facilities may also be the subject of PHA, What-If, HAZOP, or SVA reviews.
Typically, most reviews will be concentrated toward processes which have the potential for major incidents (i.e., hydrocarbon or chemical processing equipment and operations).
It should be remembered that where there are utility systems that could pose severe consequences to individuals or the company (e.g., toxic vapor releases, exposed high-voltage electrical components), a review of their system or components should also be considered.
The basic approach for these reviews is quite flexible. They can be used to analyze a variety of operations and processes such as oil and gas well drilling, product manufacturing, chemical production, factory processes, chemical processing, transportation, marketing, computer control logic, operating procedures, organizational changes, security control, and monitoring.
Chapter ThreeObjective and Description of PHA, What-If, and HAZOP Reviews
1. Definition 9 2. Objectives 9 3. Origins of Qualitative Safety Reviews 9 4. Limitations or Disadvantages 10 4.1 Limitations 10 4.1.1 Preliminary Hazard Analysis 10 4.1.2 What-If reviews 10 4.1.3 HAZOP reviews 11 4.2 Advantages 11 4.2.1 Preliminary Hazard Analysis 11 4.2.2 What-If reviews 11 4.2.3 HAZOP reviews 11
Most hazards that arise in a system are thought to be due primarily to defects in design, material, workmanship, or human error. There are many methods of safety analysis reviews that are available and can be applied to a facility or project design to examine and overcome human errors and the various failures of the process system. The methods may be either qualitative or quantitative in nature.
Quantitative methods are usually applied to obtain a more precise evaluation of an identified hazard. These are typically employed for design evaluations and resolution of recommendations when the identified risk is above normally acceptable industry levels and when major capital expenditures need additional justification. The reader is referred to other publications for guidance on quantitative methods.
Safety reviews are, ultimately, primarily looking for the possibilities of where human error may occur. Human error is commonly thought of as mainly occurring during the operational phase of the facility or system, but human error can also be the cause of defects in the design, material, or workmanship. Since most petroleum or chemical facilities are not mass-produced for specific applications, but individually designed, there is a large potential for human errors to occur during design, procurement, and construction. The extended operation lives of most facilities balance the equation so that "operational" human failures are equally important.
Human error is considered when one of the following events occur (which may be applied equally to design or operation of a facility):
1. An individual fails to perform a task or some portion of a task.
2. The task (or portion) is performed incorrectly.
3. Some steps are introduced into the sequence which should not have been included.
4. A step is conducted out of sequence.
Excerpted from SAFETY AND SECURITY REVIEW FOR THE PROCESS INDUSTRIES by Dennis P. Nolan Copyright © 2012 by Elsevier Inc.. Excerpted by permission of Gulf Professional Publishing. All rights reserved. No part of this excerpt may be reproduced or reprinted without permission in writing from the publisher.
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