Retrospective Process Safety - can you afford the risk?
We presented a case study at the recent Scale-up of Chemical Processes conference in Prague which highlighted the costs and complications associated with retrospectively assuring process safety for a hazardous oxidation reaction which had been operating for 50 years on the same site. Deficiencies in process safety assurance are typically revealed in one of two ways:
- You work it out for yourself (reactively as a result of an incident; or proactively by via internal competence development)
- Someone points it out to you (an external assessor – an auditor, external specialist consultant or a regulator)
The former is, of course, the most damaging and least favourable option… In the case study, the regulator spotted the deficiency and the company engaged external expertise, together with growing their own internal competence, to close the gap to regulatory compliance. There were numerous issues which the company had to address around worst case scenario identification, layers of protection and risk quantification / estimation, and relief system design (fundamental sizing and vent stream treatment / thrust force capability).
Over a period of two years the company has diligently addressed each of the identified gaps but the cost accrued is an eye-watering £500 k – and still climbing. Of course, over the 50 years the plant has operated there have been huge changes in the process, more stringent legislation, more educated and knowledgeable regulator and development in understanding of process safety and sophistication in the methods used to substantiate acceptable residual risk levels.
What should you do?
The thing you shouldn’t do is wait for an incident or for a regulatory intervention. Developing internal competence (or engaging external competence) to ensure process safety risk assessment is systematic and robust must be a clear aim. Having such systematic processes in place will ensure that new processes offer an acceptable residual risk level by design. Implementation of a robust management of change process (perhaps as part of an overall process safety management system) should then also ensure that changes to processes are reliably examined (against the procedures applicable at the time of assessment) – hence preventing older processes flying under the radar of modern standards.
How can DEKRA Process Safety help you?
We have helped many companies assess processes and implement assessment procedures as well as providing competence development programs in all areas of process safety through our Academy training solutions. For further information on how we could help you, please contact us on 023 8076 0722 or email us.