SEVESO II and REACH RISK AND RISK ASSESSMENT PROCESS SAFETY MANAGMENT JOEL OLENER THE PROCESS SAFETY AND RELIABILITY GROUP HOUSTON TEXAS
PROCESS SAFETY AND RELIABILITY GROUP 800 WEST SAM HOUSTON PARKWAY SOUTH SUITE 107 HOUSTON TEXAS 77042 + 713-532-8800 International Specialists in Risk Management Process and Plant Safety Reliability Studies www.psrgroup.com
PSRG Established 1997 35 consultants on staff Average industrial experience over 29 years Headquartered in Houston Texas Subsidiaries in Colombia and Canada EU subsidiary being studied
PSRG Our goals for our clients Help you improve safety and security Help increase your productivity Identify areas to reduce likelihood and consequence of incidents Help you comply with norms, codes and standards
PSRG - OUR SERVICES Process Safety Seveso II Directive United States Process Safety Management Regulation Risk Assessment and Hazard Studies Hazard Identification Process Hazard Analysis, such as HAZOP, What-If, Failure Modes and Effects Analysis Likelihood and consequence evaluation Computer-based consequence modeling for fire and explosions
PSRG - OUR SERVICES Risk Management Evaluation of alternative solutions Cost-benefit analysis Reliability Studies Equipment Processes Risk-Based Inspection
PSRG - OUR SERVICES Incident and Accident Investigation Training Single project activities and long-term consultation services
SEVESO II DIRECTIVE What Is Required
SEVESO II Issued on 9 December 1996 for all members of the EU Two purposes: Prevention of major accidents involving dangerous substances Limitation of the consequences of major accidents to people and the environment
SEVESO II Directive requires operators to demonstrate that Major accident hazards have been identified Necessary measures have been taken to prevent such accidents and limit their consequences
SEVESO II Seveso II requires companies to Prepare a Safety Report Safety Report must be updated at least every five (5) years
SEVESO II Safety Report must contain information on Company safety management system Site and process description Identification of potential accident scenarios and hazards An estimate of the severity and likelihood Measures used to protect the plant and limit consequences Safety and reliability of the equipment and process Emergency plans
REACH: Registration, Evaluation, and Authorization of CHemicals
WHY REACH? EU thinks that there are inconsistencies in evaluation and registration of chemicals An apparent need for more data on chemicals Public concern and public perception
SCOPE OF REACH Covers all substances whether manufactured, imported, used as intermediates or placed on the market, either on their own, in preparations or in articles, unless they are radioactive, subject to customs supervision, or are non-isolated intermediates
REGISTRATION UNDER REACH Estimate of 30,000 substances Registration of chemicals required if manufactured or imported over 1 tonne per year Exemptions for food, polymers, and other materials Monomers in polymers may have to be registered
REGISTRATION UNDER REACH Registration to be done over 11 years, starting June 2008 By importer or manufacturer Highest import/manufacture quantities first Registration of the 3,000 very high risk chemicals start June 2007 Industry will need environmental and health data Companies can share data for registration
EVALUATION UNDER REACH Evaluation of the registered information for all substances exceeding a production volume of 100 tonnes (around 5,000 substances corresponding to 15 percent) or, in cases of concern, also for substances at lower tonnage Evaluation carried out by authorities and include the development of substance-tailored testing program focusing on the effects of long-term exposure
AUTHORIZATION UNDER REACH Authorization of substances which are carcinogenic, mutagenic or toxic to reproduction and persistent organic pollutants
REACH: DOWNSTREAM USERS Must consider safety and risk of materials they use To obtain information from their suppliers Users can tell suppliers what they do so the supplier can do the safety assessment For confidentiality, user may perform his own safety assessment
REACH: THE MOST DANGEROUS SUBSTANCES The Most Dangerous Substances Are chemicals that cause cancer, accumulate in the body and in the environment and affect the ability to reproduce
REACH: THE MOST DANGEROUS SUBSTANCES Producers of the most dangerous substances have an obligation to Develop a substitution plan to use safer alternatives Develop a research and development plan to find a safer alternative if no safer alternative exists
COSTS OF REACH Costs estimated at 3 to 5 billion euros over 11 years
PROCESS SAFETY MANAGEMENT
PROCESS SAFETY MANAGEMENT The necessary activity to manage and control the risks of your business SEVESO The United States Process Safety Management Regulation
PROCESS SAFETY MANAGEMENT The United States Process Safety Management Regulation Fourteen elements plus the determination of what is to be included Most important elements are Process Hazard Analysis, Management of Change, and Mechanical Integrity
ELEMENTS OF PROCESS SAFETY MANAGEMENT a) Application b) Definitions c) Employee Participation Process Safety Information d) Process Hazard Analysis e) Operating Procedures f) Training g) Contractors i) Hot Work Permit j) Pre-startup Safety Review k) Mechanical Integrity l) Management of Change m) Incident Investigation n) Emergency Planning and Response o) Compliance Audits p) Trade Secrets
RISK AND RISK ASSESSMENT
RISK Risk is the chance that something adverse will happen Generally expressed as a function of severity (also called the consequence) and the likelihood it occurs
RISK ASSESSMENT Identifying hazards Understanding the nature of the hazards Assessing the consequences Immediate and knock-on Assessing the likelihood of the occurrence
HAZARD IDENTIFICATION Chemicals in the process Processes in the plant used to manufacture, store, transfer products Understanding potential for process issues, such as exothermic reactions, runaway reactions, high and low pressure, high and low level in vessels
RISK REDUCTION Review existing control measures Identify additional preventive control measures Cost-benefit analysis Review for acceptability ALARP (As Low As Reasonably Practicable)
PROCESS HAZARD ANALYSIS
PROCESS HAZARD ANALYSIS A Process Hazard Analysis is the comprehensive study that identifies and analyzes the hazards in a process The most common technique is the HAZOP study
HAZOP HAZOP is a HAZard and OPerability study Hazards or operability problems can occur When the process deviates from the design or operating intent The HAZOP Process Analyzes the process for hazards or operability problems Identifies safeguards which prevent the problem, protect the system, or mitigate the consequences Analyzes the risks in the process
EXAMPLE SAFETY REPORT Reports are very detailed and comprehensive As an example of a chemical plant study About 400 static and rotating equipment items 432 page study There are an additional 121 pages for the text of the report
MANAGEMENT OF CHANGE
MANAGEMENT OF CHANGE The formal and systematic process of identifying when a change takes place and that it is reviewed and approved to ensure: That the planned change provides the intended benefit without compromising safety, reliability, profitability, or the environment That the change does not degrade the initial safety that was designed into the process
MANAGEMENT OF CHANGE The literature suggests that over 80% of all large scale accidents trace their origins back to some sort of change
CHANGES Ross Pillari, former President of BP North America, said: The highest risks to the plant occur during a shutdown or a startup. In March 2005 the Isomerization Unit at the BP Texas City Texas Refinery was being restarted after a maintenance turnaround. It had a fire and explosion that killed 15 people.
WHAT IS A CHANGE? Change is an alteration or adjustment to any component, variable or property within an existing system
WHERE DO CHANGES OCCUR? Chemical inventory Equipment unavailability New equipment Operating conditions outside established operating limits Pressure Temperature Flow rate
WHERE DO CHANGES OCCUR? Materials of construction Equipment specifications Piping changes Computer program revisions Alarms and interlocks
WHERE DO CHANGES OCCUR? Temporary changes Emergency changes Variance for deviations from established procedures
SOME CLASSIC MANAGEMENT OF CHANGE FAILURES Chernobyl Temporary operating mode Disabled safeguards Flixborough Temporary pipeline installed Apollo 13 Spacecraft Electrical voltage specification changed
PROBLEMS IF CHANGES ARE NOT MANAGED Changes made that deviate from the Management of Change program have the potential for violation of regulations and fines
PROBLEMS IF CHANGES ARE NOT MANAGED Each change implemented without regard to the Management of Change protocol represents an uncontrolled risk An uncontrolled risk can never be properly managed
MECHANICAL INTEGRITY
MECHANICAL INTEGRITY Procedures and Training Establish and implement a written procedure to maintain process equipment integrity Train employees in how and why inspections, testing, and maintenance of equipment are important
MECHANICAL INTEGRITY Inspections and tests for each piece of process equipment Must follow recognized and generally accepted good engineering practices
MECHANICAL INTEGRITY Quality Assurance Only qualified personnel may perform work on the equipment Develop practices for ensuring all maintenance materials, spare parts, and system components are suitable for the application Document all maintenance and repairs
QUESTIONS?