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Nour M.A.,Risk Management Professionals | Maher S.T.,Risk Management Professionals | Schultz J.M.,Risk Management Professionals
17th Process Plant Safety Symposium, PPSS 2015 - Topical Conference at the 2015 AIChE Spring Meeting and 11th Global Congress on Process Safety | Year: 2015

Since August 2012, significant changes have been proposed by a number of agencies to Safety Management Systems (SMS) Programs, e.g., Process Safety Management (PSM), Risk Management Programs (RMP), and related SMS Regulatory Requirements. Many of these are framed within OSHA's and EPA's PSM/RMP Modernization/Expansion Programs, and key technical and regulatory changes are being proposed by Federal OSHA, U.S. EPA, Chemical Safety Board (CSB), California Office of Emergency Services (OES), and other agencies. As part of these SMS Regulatory Program Modernization Initiatives, on October 31, 2014, Cal/OSHA issued the latest update to its proposed regulation for "Process Safety Management for Refineries" in response to a report from the California Interagency Refinery Task Force. A number of these modernization initiatives have focused on perceived weaknesses in the application of the Process Hazard Analysis (PHA) and Mechanical Integrity (MI) elements of PSM/RMP. The main objective of this paper is to provide some tangible suggestions for effectively addressing proposed changes associated with Damage Mechanism Reviews (DMRs), with the intent of providing straightforward tips for owner/operator companies to address contemporary best practices and to minimize the effort associated with later upgrades to various PSM/RMP Program elements, once these proposed initiatives become regulatory requirements. The core of this paper will detail a Streamlined DMR approach to address near-term objectives and an Integrated PHA (iPHA) approach to address long-term objectives by harmonizing PHA and MI efforts. Key topics include: •The Challenge - Identifying Potential Mechanical Integrity Hazards and Adhering to New Regulatory Program Requirements •Addressing Damage Mechanism Review (DMR) Requirements •DMR Preparation • DMR Implementation Using the iPHA Approach • DMR Documentation Documenting the DMR within the iPHA.


Schultz J.M.,Risk Management Professionals | Maher S.T.,Risk Management Professionals
30th Center for Chemical Process Safety International Conference 2015 - Topical Conference at the 2015 AIChE Spring Meeting and 11th Global Congress on Process Safety | Year: 2015

Since August 2012, significant changes have been proposed by a number of agencies to Safety Management Systems (SMS) Programs, e.g., Process Safety Management (PSM), Risk Management Programs (RMP), and related SMS Regulatory Requirements. Many of these are framed within OSHA's and EPA's PSM/RMP Modernization/Expansion Programs, and key technical and regulatory changes are being proposed by Federal OSHA, U.S. EPA, Cal/OSHA, Chemical Safety Board (CSB), California Office of Emergency Services (OES), and other agencies. As part of these SMS Regulatory Program Modernization Initiatives, on October 31, 2014, Cal/OSHA issued the latest update to its proposed regulation for "Process Safety Management for Refineries" in response to a report from the California Interagency Refinery Task Force. The changes being proposed for these programs are extensive, currently being formulated, and are not synchronized between the various agencies. The focus of this paper will be to provide relevant background information, a summary of the proposed changes, and tips for addressing key technical and regulatory challenges, as well as providing the reader with a "roadmap" for effective implementation. This paper is designed to address the regulatory environment in March 2015, will be updated periodically to reflect this "moving target", and key topics include: Background - Pre-2012 PSM/RMP Universe Overview of Key Safety Management System Program Modernization Initiatives Key Elements of the Various SMS Regulatory Initiatives SMS Modernization Status and Potential SMS Program Impact What Should I Be Doing Now?. Copyright © (2015) by AIChE All rights reserved.


Maher S.T.,Risk Management Professionals | Long G.D.,Risk Management Professionals | Cromartie R.S.,Risk Management Professionals | Sutton I.S.,Sutton Technical Books | Steinhilber M.R.,California State Lands Commission
Process Safety Progress | Year: 2013

The April 2010 Deepwater Horizon tragedy and release from the Macondo Well resulted in a re-examination of the existing regulatory framework, significant modifications to the structure and function of key regulatory agencies, and the application of new safety management system (SMS) requirements to offshore facilities in United States waters. Late-2010 witnessed the evolution of both prescriptive and performance-based regulations designed to address the direct and underlying causes of this tragedy. The objective of this article is to briefly review these new regulatory requirements and illustrate how they are related to the application of other SMSs, for both offshore and onshore facilities. The common themes, objectives, and overlaps of specific onshore and offshore SMS elements was examined, and tips on how these overlaps can be used to more effectively (and sensibly) implement these programs is discussed. This article also outlined successful SMS programs that are being applied by various state agencies to onshore and offshore coastal facilities, and derived lessons-learned from these programs that may assist in the implementation of related federal programs. © 2013 American Institute of Chemical Engineers.


Maher S.T.,Risk Management Professionals | Norton K.D.,FLUOR | Reyes E.,FLUOR
12AIChE - 2012 AIChE Spring Meeting and 8th Global Congress on Process Safety, Conference Proceedings | Year: 2012

Over the past decades, especially in the oil and gas industries, standardization of key design elements have progressed hand-in-hand with the vast proliferation of applications, especially with projects associated with oil and gas exploration and production. The use of standardized design elements have allowed vendors (companies specializing in "packaged units") to make minor alterations to their basic design packages to rapidly customize their design to meet the system design requirements. A discussion on practical tips on key issues that should be evaluated as part of the HAZOP Study covers the background, evolution of the use of packaged units, and vendor package integration into HAZOP; evolution of the use of packaged units in the design process and the importance of thorough evaluation before taking ownership; importance and benefits of challenging the vendor and thoroughly evaluating the vendor packages via HAZOP; examples from one project of safety issues that had not been addressed in the vendor-provided design details; helping the vendor get prepared for the HAZOP study, including a master checklist of issues not always considered by the vendor, to avoid design formulation instead of HAZOP; timelines for preparation for a HAZOP Study that includes a vendor package; and characteristics to look for in the individuals from the vendor company that are participating in the HAZOP Study. This is an abstract of a paper presented at the 2012 AIChE Spring National Meeting and 8th Global Congress on Process Safety (Houston, TX 4/1-5/2012).


Maher S.T.,Risk Management Professionals | Norton K.D.,Risk Management Professionals | Reyes E.,FLUOR | Vasudevan V.,Santos | Masciantonio M.,Santos
Global Congress on Process Safety 2012 - Topical Conference at the 2012 AIChE Spring Meeting and 8th Global Congress on Process Safety | Year: 2012

During the design phase of a project, vendor packages (e.g., compressors, water desalination) are typically treated as a "black box" with a very specific function, and the typical perspective of the buyer/owner/operator is that safety issues have been thoroughly addressed, based on the package vendor having designed and built a large number of similar units. Although in many cases, this is true, in other cases, low-probability/high-consequence events just haven't yet occurred on the systems that have been installed or the system operator may have made retrofits that have addressed potential safety issues. Regardless, the thorough evaluation of vendor packages, prior to acceptance/installation, as part of a holistic safety review is critical. When structuring a HAZOP Study that will properly challenge the design, a key issue is the knowledge, background, and state of preparedness of the vendors that participate in your HAZOP Study. Many individuals may be very familiar with the normal functioning of the system, but not so much the dynamic response of the system to upsets or things that might challenge safety limits. In other cases, the individual sent to participate in the HAZOP Study may not have been exposed to and knowledgeable of the types of the design limits that are pursued during the HAZOP Study. Another key issue that is often not investigated is the potential interactions between the vendor package and the process system. The HAZOP Study must also thoroughly review the vendor-provided information to ensure that turnover packages include all of the key process safety information that may be required for company requirements and regulatory programs. The key objective of this paper is to provide practical tips on key issues that should be evaluated as part of the HAZOP Study, and to provide checklists and timelines that can help the vendor representatives that are attending your HAZOP Study prepare. The tables of key information that the vendor should be prepared to discuss and the charts containing timelines for preparing the vendor for the HAZOP Study that will be provided in the paper will provide definitive guidelines and tips for ensuring that the vendor is properly prepared to support the HAZOP Study. The following key topics are addressed: • Background, Evolution of the Use of Packaged Units, and Vendor Package Integration into HAZOP • Evolution of the use of packaged units in the design process and the importance of through evaluation, BEFORE YOU TAKE OWNERSHIP • Importance and benefits of challenging the Vendor and thoroughly evaluating (via HAZOP) the vendor packages • Examples from one project of safety issues that had not been addressed in the vendor-provided design details • How to help your vendor get prepared for the HAZOP Study, including a master checklist of issues not always considered by the vendor, to avoid "design formulation" instead of HAZOP • Timelines for preparation for a HAZOP Study that includes a vendor package • Characteristics to look for in the individuals from the vendor company that are participating in your HAZOP Study.


Maher S.T.,Risk Management Professionals | Reyes E.,FLUOR | Vasudevan V.,Santos
Global Congress on Process Safety 2012 - Topical Conference at the 2012 AIChE Spring Meeting and 8th Global Congress on Process Safety | Year: 2012

There have been numerous guidebooks written for the application of Hazard and Operability (HAZOP) Studies[1] to operating facilities and capital projects where the design is relatively mature. For these systems, critical process safety information is typically available, but for fast-moving capital projects that is often not the case, and in addition there are often many contrasting issues: • Design flexibility allows for more extensive changes at early stages of the project. Even the ability to cost-effectively make larger numbers of smaller changes can have a measureable improvement in safety and decreased operational risk. • Less-detailed design information at early stages of the project can result in an incomplete safety assessment resulting in re-work and re-HAZOP. • Late design changes can have a more significant impact on project schedule later in the project cycle. • With the proper focus, designers can often benefit from feedback obtained from owner-operator personnel and from the thought process invoked by the HAZOP approach. These issues represent fundamental contrasting priorities. Although applying a designed-to-be-detailed analysis tool like HAZOP at early stages of the project is a fundamental challenge and presents many dilemmas to the HAZOP Study Facilitator, the application of a phased approach can help achieve the true objectives of the HAZOP Study, which is to make as many safety improvements as practical to minimize risk. The "double-edge sword" is by incorporating HAZOP Study approaches early in the design process, important safety improvements can be done more cost-effectively, allowing limited project funds to have a greater impact in lowering net risk, but it may require some "re-visiting" of the HAZOP Study. The alternative (doing a final HAZOP Study, after all of the design work is complete) obviates the need for any re-assessment of safety issues, but it also eliminates the practical ability to implement any design changes, unless the risk is very high. Thus, if carefully managed, the introduction of HAZOP concepts early in the design cycle, evolving the level-of-detail with design maturity, and the performance of focused updates to the HAZOP Study, can be used to most cost-effectively minimize the risk associated with the project design. This approach can also be used to minimize last-minute design changes that could have had the potential to greatly increase project costs and result in project delays. This paper will examine the use of the HAZOP approach during the design cycle and introduce mechanisms to make this Design HAZOP (D-HAZOP) meaningful as a decision-making and technical problem-solving tool that can be used to accent the Design Formulation and Design Review process. Our objective is to assist the reader with practical tips to communicate these concepts to the technical community and capital project management - to facilitate a shift in paradigm that uses HAZOP in a new way that provides for safer process facilities, while likely streamlining project schedules and budgets. D-HAZOP then is not perceived as a project impediment, but as support of critical capital project goals and objectives.


Maher S.T.,Risk Management Professionals | Cheek C.D.,Risk Management Professionals | Brawley-Roehl E.M.,Risk Management Professionals | Long G.D.,Risk Management Professionals
AIChE Annual Meeting, Conference Proceedings | Year: 2011

The April 2010 Deepwater Horizon tragedy and release from the Macondo Well resulted in a reexamination of the existing regulatory framework, significant modifications to the structure and function of key regulatory agencies, and the application of new Safety Management Systems requirements to offshore facilities in United States waters. Late-2010 witnessed the evolution of both prescriptive and performance-based regulations designed to address the direct and underlying causes of this tragedy. The objective of this paper was to briefly review these new regulatory requirements and illustrate how they are related to the application of other Safety Management Systems, for both offshore and onshore facilities. The common themes, objectives, and overlaps of specific onshore and offshore Safety Management System elements was examined, and tips on how these overlaps can be used to more effectively (and sensibly) implement these programs was discussed. This paper also outlined successful Safety Management System programs that are being applied by various state agencies to onshore and offshore coastal facilities, and derived lessons-learned from these programs that may assist in the implementation of related federal programs.


Maher S.T.,Risk Management Professionals | Norton K.D.,Risk Management Professionals | Surmeli S.,Risk Management Professionals
AIChE Annual Meeting, Conference Proceedings | Year: 2011

Fundamental changes in a chemical process are most cost-effective at early stages of a design, and specific inherently safer design evaluations are typically performed at these early stages to identify fundamental improvements that can remove hazards or significantly decrease the magnitude of the consequences associated with plant accidents. As the detailed design comes into focus, thoughts of inherently safer designs are rarely revisited because the designer's paradigm has shifted. Although fundamental changes are more difficult, there may still be opportunities during the detailed design phase to entertain new ideas of inherently safer design, especially due to the rapidly changing environment of process plant technologies. Thus, it is the duty of the process designers to look for new mechanisms for improving plant safety, and throughout the design process. As teams assemble for various activities, good opportunities for revisiting inherently safer design concepts do materialize. The focus of this paper is to present these opportunities to the reader, provide examples of inherently safer design concepts that can be applied at different phases of design, and provide guidance as to how these concepts can be applied specifically during the HAZID, HAZOP study, and LOPA processes that are routinely carried out during most major plant process designs.


Maher S.T.,Risk Management Professionals Inc. | Norton K.D.,Risk Management Professionals | Surmeli S.,Risk Management Professionals
Chemical Engineering Progress | Year: 2012

Some of the tools that can be used to identify opportunities towards inherently safer design (ISD) strategies and can be applied at different points during the design work are discussed. Identifying these opportunities and making changes prior to a detailed design avoids the added costs and schedule delays that would be incurred later for the design rework. The front-end engineering and design (FEED) phase relies on estimates of process variables, and the tools available to help the process designer identify ISD alternatives during the FEED phase include the hazard and operability (HAZOP) study and the layer of protection analysis (LOPA). Cost-benefit analysis allows decision makers to systematically consider design alternatives, taking into account both benefits and costs. Revalidating periodically allows a facility to evaluate the hazards and consider new mitigation measures based on technology advancements.

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