Tips To Maximize Safety Compliance

In today’s chemical and other process plants, complying with safety standards requires more than just installing a certified safety instrumented system (SIS). Full compliance requires ensuring safety on a continuous loop-by-loop basis. SIS users perform some type of hazard and risk analysis before installing their safety systems. However, many still fail to audit their safety protection adequately after SIS installation and commissioning. The safety standards require process plants to have competent certified personnel audit their systems following installation and then periodically on a regular basis.

Many regulatory bodies consider this process, which is detailed within the IEC 61508/ISA84 standards, to be an industry best practice. With fines and even criminal convictions at risk, industrial organizations should make serious efforts to ensure that their safety systems are current. This is one area where ignorance is no longer bliss.

The Directive

Since the publication of the IEC 61508 and IEC 61511 standards, interest in rigorous safety analysis and applying certified SIS have increased considerably among the user community. The safety standards provide guidance on good practice and offer recommendations, but do not absolve users of responsibility for safety. The standards recognize that safety cannot be based on retrospective proof but must be demonstrated in advance. Therefore, the standards not only deal with hazard and risk analysis and specifying safety system requirements, but with the whole safety lifecycle. This includes validation of the installed system, operation and maintenance, and final decommissioning. Thus, the standard deals with the management of safety throughout the entire life of a system.

The standards require evidence of competence for those who perform assessments, but do not require that they be formally authorized or accredited. However, SIS users increasingly demand that the assessments be completed by competent and certified individuals or organizations. This is why many safety services companies promote their certifications. Today, several national and international organizations are setting up procedures and guidelines for compliance, training and certifying the competence of individuals and companies that perform such audits.

Trouble Keeping Up

This greater focus on safety as a holistic function across the lifecycle of the enterprise creates a greater demand for safety expertise than previously. In the past, a facility may have been satisfied with contracting an engineering firm to design and implement a safety system and then never touch that system again until decommissioning. This is no longer considered a best practice, and – in fact – can be dangerous. The requirement to monitor the system's health and prove both its functionality and applicability on a continuous basis increases the SIS resources needed by the end users.

Today's already overloaded SIS engineers not only face an increased work load regarding testing the systems for effectiveness, they must also maintain extensive records. Unfortunately, end-user organizations have not increased headcount in response. This is further complicated by a general lack of fresh talent entering the industrial space and by the fact that experienced engineers, many of whom have created one-off record systems, are retiring (or hope to do so soon).

Getting On Top Of The Problem

If plants don't have the staff, they will need to contract with a third party. They also need tools to alleviate the burden. The market has responded to both requirements.

Most SIS hardware suppliers and some specialty engineering firms offer consultancy with certified personnel. To differentiate themselves, these companies are touting not only their certified personnel, but also that their engineering and project processes are independently certified for compliance with safety standards. Although many large manufacturers can justify maintaining safety engineers on staff, mid-tier and small manufacturers will need to rely on outside resources to a greater degree.

Proper staffing is only part of the solution. Proper tools to collect, maintain and visualize the data in an auditable manner are essential. ARC Advisory Group has observed a growing market in safety lifecycle management solutions. Some solutions have been available for decades, while others are more recent entries. To varying degrees, these solutions help automate the collection of safety-related data from the safety and control systems, aggregate and centralize design information, and identify deficiencies or anomalies requiring attention. Solutions of this nature reduce the burden on personnel through automation and visual analytics. This allows personnel to focus more on process improvement than on basic data collection and analysis. Better tools can also reduce the number of increasingly scarce and costly specialists that end-user organizations need to hire.

So What’s A Chemical Company To Do?

Safety expertise is leaving the job market at a rate faster than it is being replaced. Unlike in years past, it often no longer makes sense for today's resource-constrained chemical companies to maintain in-house expertise for specialized projects like safety system analysis and de-sign. To adjust to the depletion of expertise, ARC recommends that end user organizations consider developing collaborative business relationships with service companies with the specialized expertise and a proven track record with the strategic parts of the process safety lifecycle management.

Lifecycle management can be laborious and expensive if the tools used require manual intervention and data capture. Worse yet, record-keeping can become woefully inaccurate and misleading. Since on-site personnel tend to be spread thin, are expensive and may not have all the expertise captured within an off-the-shelf solution, end-user organizations should seek a solution that provides a single version of the truth, automatically gathers information and creates easily auditable records and reports.

ARC recommends the following actions:

• Acquire the services of competent and certified people to analyze your safety protection requirements before selecting and installing your safety systems.
• Have your safety systems audited for compliance after installation and on a periodic basis thereafter by competent and qualified personnel.
• To ensure compliance, suppliers, system integrators and other third parties involved in safety system installation and maintenance should get their personnel trained and certified by a competent organization.
• Request your automation and safety system supplier to provide safety lifecycle management capabilities. This will help ensure a better understanding of data, reduce the time needed to respond to looming safety issues and enable you to do the right things to correct leading bad safety indicators.
• Honestly assess your operational and process safety behaviors, with the understanding that this could take some time to do properly.
• Review and thoroughly vet the functionality and offerings of different suppliers. Understand that some automation and safety expertise suppliers just offer a SIL assignment and SIL requirements software tool, while others can deliver more comprehensive process safety management software with capabilities like real-time risk analysis and management, real-time functional safety management and real-time traceability (NOTE: ARC's recently updated SIS market analysis report includes an overview of the leading suppliers and their capabilities).
• "Look up" and "look down" from where you are in the automation hierarchy. Talk to your traditional automation suppliers for levels 1 and 2 and advanced process control (APC) and talk to enterprise-level automation suppliers. They should be willing to help solve your safety lifecycle management problems.