Some firms likely will find that their design and management philosophy is out of alignment with various aspects of good engineering practices. When unacceptable risk is identified, you should establish an action with short-term and long-term measures to sufficiently reduce the risk. It is well proven that investments to improve safety and reliability of the process operation yield long-term economic returns.
An increasing number of companies are finding themselves operating within a regulatory framework that often doesn’t provide prescriptive requirements. Instead, the requirements are a moving target based on the somewhat fuzzy concept of good engineering practice. Keeping up and complying with the basic requirements concerning process safety and IPSs can seem taxing enough. How does a company move forward with continuous improvement when it seems that even the immediate goals are a moving target? To some, it may seem challenging enough just to maintain the status quo, let alone to embrace more changes.
Continuous improvement operates on the principle that finding failures and errors is the beginning of a learning process. Minimizing their reoccurrence requires an understanding of how they developed.
Consider continuous improvement as well as the application of good engineering practice as an ongoing process rather than an endpoint. Periodically analyze work processes, information, resources and skills to identify weaknesses that limit performance and to recommend necessary improvements. Information systems, whether computerized or manual, should provide personnel with up-to-date details in a format that’s easy to understand. Information should be revision controlled, yet accessible.
Many factors — such as the economy, market trends and technology, along with legal and political issues — affect IPF performance expectations and the designs used to attain them. A strong safety culture expects ownership and accountability for safe and reliable performance of the process equipment over its life. Management should support periodic evaluation of the existing equipment to determine that it’s designed, maintained, inspected, tested and operating in a safe manner.
Changes in operability, functionality, reliability or maintainability expectations may require implementing different design or management practices. Proof test, failure investigation, alarm, trip, audit reports, etc. provide valuable insight into personnel and management system performance. Operating excellence mandates identifying and resolving the root causes of unacceptable process reliability and equipment performance. Improving equipment mechanical integrity requires a culture that values maintenance.
Various management system activities can identify a need for improvement. Periodically examine overall information available to identify, trend and correct systematic problems. Perform a gap analysis to compare observed to expected IPS performance. The gap analysis should determine that:
- equipment is operating according to design intent;
- safety, operating, maintenance and emergency procedures are appropriate for competency and risk-reduction expectations;
- hazard and risk analysis or management of change (MOC) recommendations are addressed in a timely manner; and
- training of personnel is adequate for current work expectations.
You may identify significant issues during the analysis. Management system failures often are reflected in multiple performance metrics. Watch out for systemic problems such as poor adherence to policies, procedures, and practices or insufficient inspection and preventive maintenance. If IPS equipment isn’t maintained, it’s likely that other equipment also is suffering from inadequate maintenance. The cumulative maintenance deviations, whether intentional or unintentional, may cause a breakdown of multiple protection layers.
Checking IPS requirements and performance frequently demands team effort. Some organizations establish a formal structure in which particular personnel participate as site representatives on a core team. The core team evaluates changes in the good engineering practices and recommends modifications to internal practices.
Whenever work processes are modified, a shift in emphasis often leads to changes in the way team members perceive the process, its associated risks, various protection layers and IPSs. This shift may result in recommendations for additional risk reduction or IPSs. These recommendations and other continuous-improvement efforts complete the lifecycle, moving the process toward safer and more reliable operation.
Determining the path forward
The key aspect of continuous improvement is charting the course to achieve it. Over time, various options will be presented to upgrade hardware, software or human interface systems. Review each proposed change using a MOC process to identify how the change affects other functions or systems. Address areas for improvement with an action plan, which typically prioritizes recommendations based on consequence severity and risk gap.
Action plans should define objectives, milestones and timelines. Periodically reassess action plans to determine whether there’s a need to accelerate the schedule or broaden the objectives. For example, you may decide to speed up a planned IPS upgrade in response to a manufacturer withdrawing support for critical equipment. To be successful, action plans should be communicated to affected personnel so they understand and commit to them.
Implementing upgrades aimed at improving long-term operational effectiveness takes time to complete, depending on the complexity and degree of change involved. As the IPS is changed, operating plans and targets should consider any additional risk borne by the process during the transition. Once the design basis changes are underway, review the operating and mechanical integrity basis and implement all needed revisions.