2nd Quarter 2015 Newsletter

Here is what you will find in this edition:

Ask Doctor SIS: “RAGAGEP in Process Safety Management Enforcement”, by Angela Summers
“Process Automation Reliability vs. Safety”, by Bill Mostia
“SIS Management (part 2)”, by Eloise Roche
Unsafe Automation, incident cases
SIS-TECH Application Case, by Pete Fuller
Follow SIS-TECH on technical events and training calendar

Ask Doctor SIS

Angela E. Summers Ph.D., P.E.

How does OSHA decide that a particular clause of an industry practice or even a particular practice applies to a covered or non-covered facility?

OSHA issued a significant revision of their clarification letter on recognized and generally accepted good engineering practice (RAGAGEP) in June 2015. This is an expansion of their previous clarification letters to ISA’s Lois Ferson (retired) in 2000 and 2005, which defined how to approach RAGAGEP by using ANSI/ISA 84 as an example.

The significantly more comprehensive clarification states that RAGAGEP is “directly referenced in three provisions:

(d)(3)(ii): Employers must document that all equipment in PSM-covered processes complies with RAGAGEP;

(j)(4)(ii): Inspections and tests are performed on process equipment subject to the standard’s mechanical integrity requirements in accordance with RAGAGEP;

(j)(4)(iii): Inspection and test frequency follows manufacturer’s recommendations and good engineering practice, and more frequently if indicated by operating experience.”

The last point above emphasizes that after installation an instrument reliability program is needed to track equipment performance and to yield prior use support of the equipment’s fitness for purpose. The letter also references (d)(3)(iii) that addresses existing installations designed prior to the issuance of a new or modified RAGAGEP.

The letter provides OSHA’s interpretation of the words – shall, should, should not, prohibited, and must.

Normative practices are required for compliance, while informative practices should be reviewed to understand how the guidance impacts process safety. Anything recommended by a practice that reduces the risk should be applied unless the user can justify an alternative approach. The letter also clarifies the intent of references within PSM to internal practices versus RAGAGEP. Employers’ internal practices must either meet or exceed the protective requirements of published RAGAGEP.

Read OSHA Clarification Letter here.

Process Automation Reliability versus Safety

Is It Possible to Have Safe Systems That Aren’t Considered Reliable?

William L. Mostia P.E.

Noted and well-respected safety guru and author of Engineering a Safer World, Nancy Leveson, once stated in a presentation on “The Path to More Cost-Effective System Safety” that reliability does not equal safety: Reliability ≠ Safety. This is based on the observation that many accidents occur without any component or equipment hardware or software failure, leading to the conclusion that systems of highly reliable components or equipment alone are not necessarily safe. She also said that complexity compounds this issue.

So how does this statement relate to the process industries? Reliability and safety are many times treated differently, as if they’re dissimilar concepts or philosophies. It seems certain that we want a reliable and safe plant, but how do these concepts interact in a process plant?. Read full paper

SIS Management – Part 2: Maintenance and Repair

Eloise Roche, Senior SCAI Consultant, CFSE

You are about to design your plant’s first Safety Instrumented System (SIS). So, what is some of the initial information that you need before you can efficiently start? No doubt you have the hazard and risk analysis document which describes the necessary safety instrumented function and other safety controls, alarms and interlocks (SCAI) used to protect against the same hazard. P&IDs which show the location of the proposed sensors and final elements? Certainly!

You even have the logic diagrams ready which show all the process automation functions for this unit operation, so you can easily verify independence.

But would you be surprised if I said that the facility maintenance and repair strategy for SCAI is also essential to have at the beginning of the SIS design?

Too often, the instrumentation mechanical integrity program is considered as an “after thought” to a project. Indeed, some may think that there will be plenty of time to develop maintenance procedures and spare part plans after the project is installed and returned to operations. Nothing could be further from the truth when it comes to this element of SCAI Management. Read full paper here.

Please visit this edition’s Unsafe Automation Incident case study, to see an example of how failure in instrument maintenance and repair programs contributed to an explosive outcome.

Unsafe Automation

SCAI Maintenance and Repair Safe Automation incident!

Read more about the Buncefield incident here.

For our second industry incident case study focusing on safe automation management system practices and inherently safer automation practices, we have a summary of another explosion event. This incident occurred at a facility located near Hemel Hempstead, England, December 11, 2005, and resulted in 43 injuries and substantial economic loss. Key safe automation management practices highlighted in this case study include Maintenance and Repair and Management of Change, compounded with other safe automation implementation deficiencies.

More from SIS-TECH Application

Pete Fuller, Applications Advisor Senior SCAI Consultant

SIS-TECH Designs SIL3 Diamond-SIS For Pipeline Overpressure Prevention and Rupture Mitigation

Pete Fuller of SIS-TECH received a call from a corporate engineer needing a safety instrumented system to address two hazard scenarios associated with a plant in Louisiana. The corporate engineer had heard about a Diamond-SIS installation at a sister plant in Texas, where the system has provided several years of problem-free protection for some significant safety risk. The client needed a quick solution for the Louisiana plant as the equipment was about to go into a turnaround and the client needed a system that could be installed while they were down for the turnaround.

At the conclusion, the new owner of the Diamond-SIS was ecstatic to have this project initiated and completed as part of the scheduled turnaround. Read full solution here.

If you are in need of a Safety Instrumented System and would like to discuss the Diamond-SIS solution, please contact Pete Fuller at (713) 909-2100 or pfuller@sis-tech.com.

What is SIS-TECH up to?

Events:

Mary Kay O’Connor’s Process Safety Center International Symposium

October 27-29, 2015

College Station – Hilton Conference Center

Process Control & Safety Symposium

November 9-12, 2015

Houston – Houston Marriot Westchase

Training:

Oct. 5, 2015, Instrumentation Technology – 3 day course in selection, sizing, installation, maintenance and calibration of devices used in the automation of industrial processes. Class outline

Oct. 20, 2015, TÜV Rheinland FSEng Training/Certificate – 4 day course in hazards identification techniques, requirements for designing and managing SIS. Certification is available. Class outline

Nov. 10, 2015, Layers of Protection Analysis – 2 day course in fundamentals of Layers of Protection Analysis (LOPA). Class outline

Nov. 17, 2015, SIL Verification Using Quantitative Techniques – 2 day course in verification of safety instrumented functions. Class outline

Nov. 19, 2015, SIL Solver – 1 day course using SIL Solver Software; a SIL verification tool. Class outline

Additional information on all training dates