By Warren Johnson, Senior Project Manager, FGS Product Manager Regulatory compliance is a moving target. Codes and standards are under ongoing revision and the business landscape is constantly evolving. Fire and gas systems are protecting an organization’s most valuable investments and assets, yet they sit silently idle in the background often overlooked and untested. The maze of local, state, and federal codes and standards just add to the confusion and complications. The Challenges Many engineers working in the industrial manufacturing sector do not have first-hand working knowledge of the codes and standards that govern these critical life safety systems. Many of those that do are beginning to retire, leaving newer, less experienced staff in their place. There are 37 different pieces of equipment requiring OSHA’s Nationally Recognized Testing Laboratory approval. It’s understandable that these less experienced employees do not have the background to navigate all the specific code requirements governing the equipment for which they are responsible. These emerging engineers will need guidance. Even teams with extensive compliance experience know that these codes change and evolve, so they cannot rely solely on how things have been done in the past. The Stakes Creating a safer work environment protects both a company's personnel and its assets. Failing to do so can result in personnel injury, damage to the environment, and irreparable harm to a company's reputation. Poor code compliance may jeopardize insurance coverage or cause increased premiums. Code deficiencies found late in a capital project may lead to costly startup delays until compliance is achieved. The Most Common Codes Everyone Should Know ⮚ International Fire Code – Regulates the means of protecting lives and material property from fire or explosion hazards when modes of prevention fail. ⮚ International Building Code – Covers all codes regarding buildings except for residential family homes. ⮚ Life safety 101 – This established set of standards is intended to protect the occupants of a facility at each stage of the building’s life cycle—from construction to its intended use and eventual demolition— minimizing the effects of fires and other related hazards. ⮚ NFPA 72 – The National Fire Alarm and Signaling Code provides updated safety protocols to meet the ever-changing demands for improved fire detection, signaling, and emergency response communications. This code also regulates requirements for mass notification systems used for a wide range of emergencies from catastrophic weather, terror threats, biological dangers, chemical incidents, and even nuclear disasters. ⮚ OSHA 1910.164 – Standardizes regulations for fire alarm detection systems and OSHA 1910.165, which focuses on regulating employee alarm systems specifically. Capital projects need to incorporate the requirements of these standards into their design since they are the most prevalent in constructing a facility. Compliance is far less likely without a deep understanding of these standards and where each applies. Most compliance errors are made due to: The lack of awareness of relevant regulatory codes. A deficiency in understanding requirements well enough to apply them properly. Organizations that wish to avoid the cost and confusion over non-compliance need to do the research and audit their practices. The caveat with self-auditing code compliance is that it can be like looking for a needle in a haystack without knowing what a needle looks like. Companies that do not know what codes to look for or which apply to their facilities may benefit from engaging a firm that specializes in regulatory code compliance. Learn More about aeSolutions' Fire & Gas Services

By Ken O’Malley aeSolutions Founder and President Think back to 1998 when technology, as we know it by today’s standards, seemed to be in its infancy. Businesses relied upon fax machines. E-mail had recently become the communications standard. E-commerce was reaching mainstream. And Google had just launched. 1998 is also the year that two partners and I, with no business management education or experience, founded aeSolutions, an industrial engineering consulting startup driven by a vision to accomplish great things, but in a different way. Our original vision, as it remains today, was to assemble a highly talented, creative, and engaged team driven to solve the process safety and automation problems that industrial companies face every day. Give smart people the freedom to act and the safety to fail, and they will outperform the expectations placed on them. To that end, I’m particularly proud of our high-performing employees, whom customers seek out because of their ability to solve problems. It's safe to say that the world, just as aeSolutions, has come a long way in the past 25 years. The Early Days So, what was it like when we started? While our particular industry takes codes and safety standards for granted today, it’s rather shocking to imagine there were fewer of them and were less broadly known or understood. For example, out of a roomful of people, only a few might know what SIL (Safety Integrity Level) stood for, which today is commonly understood. Second was the absence of options for sharing large amounts of data across diverse systems. Some may recall the communication “bus wars” where a few companies competed fiercely with their protocols for market dominance. Who would have guessed at the time that “indeterminate” ethernet would ultimately reign supreme? In fact, the industry’s widespread adoption of ethernet has made collecting and sharing data across varied systems almost inconsequential today —something that was difficult and very expensive to do even on a limited scale 25 years ago. The technology limits of the time were offset by deploying larger project teams and having longer project timelines, timelines that would seem lumbering by today’s standards. Back then, projects were executed serially, with earlier disciplines mostly finishing their work before downstream disciplines would start. Today project timelines require almost concurrent execution enabled by advanced models and shared database tools. Our Successes Perhaps it was youthful naivety at the time, but having the confidence to be an early mover has contributed to our success. We’ve always been eager to take on new technical challenges and open to accepting a few missteps along the way. For example, we started building our process safety consulting business more than 12 years ago and very much underestimated the challenges and how different this business would be from our detailed engineering disciplines. This move considerably stretched our business systems and challenged everything we thought we knew about operating a professional technical services firm. The good news is that we pushed through it, and today have an incredibly skilled process safety consulting team. Another notable achievement was our industrial cybersecurity consulting business, which we built from the ground up and eventually sold. Once again, we were an early mover and eager to take on new technical challenges. Interestingly, cybersecurity risks rank among the biggest challenges facing our industry, followed by tightened project timelines and a growing lack of engineering talent available in the workforce. What We’ve Learned As a company founded and run by engineers, we always prided ourselves on our ability to identify and implement a solid technology solution to almost any problem, putting little emphasis on the human dimension. Today, however, that dynamic has shifted. When approaching a new problem, we start with the human impact. We’ve learned that the best solutions usually fail if they don’t acknowledge human nature both in initial buy-in and in long-term adoption and success. We’ve also placed greater value on teamwork. While we once focused on hiring rockstars in their fields, the strategy of hiring independent, self-performers only works to a point and won’t scale. Team members who focus more on supporting the growth and development of those around them make for a more successful organization and a far better place to work for our team members. Improving With Age As it should, our industry has noticeably improved and matured over the past 25 years, which ultimately helps everyone. We’ve witnessed operational efficiency, increased automation and productivity, and reduced costs as a result of minimizing labor-intensive processes and optimizing resource utilization. Better interoperability and improved safety, along with improved process automation schemes for greater accuracy and reduced errors, also have helped elevate our profession. Engineering’s Evolving Role Being a naturally curious bunch, engineers are creative problem solvers, with problem-solving often seen as an art form that comes with great pride and at great cost. Today, however, engineers must shift their identified value from developing “born-here” solutions to achieving objectives with less effort, lower cost, higher quality, and fewer surprises – something achieved through modularization and standardization. Engineers must embrace building on the work of others and continual improvement, which requires a culture focused on teamwork. What’s Next for aeSolutions? We were a new startup in 1998 leading the charge in functional safety and critical systems deployment. Given how the industry has matured over the past 25 years, I’d like to believe we’re in a better spot today because of our leadership during those early days. Our company has been through 9-11, the 2008 financial crisis, an oil market crash in 2015, and the passing of my business partner, Brian Merriman, who was a close friend, and the original visionary of our organization. These challenges and many others have forged us into a resilient organization that should not be underestimated. As we advance in the years ahead, we are committed to the long-term growth and development of our employees. If we empower our employees with more information and the education to understand and apply that information, and if we do this consistently, we will be successful by every measure. Finally, my advice to others looking to make their mark in this industry: identify the unique value that you can bring to your clients. Build a brand around that. And plan to work incredibly hard to separate yourself from the competition. Ken O’Malley is Founder and CEO of aeSolutions, a South Carolina-based industrial engineering and consulting firm. He welcomes his role of inspiring the aeSolutions team to excel and improve. As an inclusive, ethics-first, and genuine leader Ken is driven by a desire to establish and maintain aeSolutions as a destination employer that cares deeply about its people.

By Ken O'Malley As aeSolutions celebrates its 25th year in business, it’s natural to wonder what the next 25 years will bring. And while there’s no crystal ball to predict how new technologies, for example, will change the way we solve client problems, the one thing I know is that our success will be grounded in the same people-first mindset that got us to where we are today. Here's what I mean. The way in which aeSolutions emphasizes employee retention and development makes me very proud. We have many long-tenured employees who could work anywhere, yet they choose aeSolutions as their professional home. For a company of our size, it’s rare to employ a full-time talent development specialist whose role is to create and improve employee development opportunities. While that represents a sizeable yet important investment to make our employees a top priority, we can point to more than two decades of proof that if we treat our employees well, our clients reap the benefit. The “Next 25” Technologies I was recently asked what I see as potential game-changing technologies that we can expect to impact the future of work, to which I responded that Artificial Intelligence (AI) will live near the top of that list for solving our most complex challenges, especially where large amounts of empirical data are available. The pace at which AI has advanced over the past year is staggering. Even more surprising is how accessible it has become to everyone. It has opened up new problem-solving opportunities and possibilities that we once thought were unimaginable. As industrial engineers and consultants, our work centers on designing and implementing solutions to complex challenges – something that AI will only get better at. At the same time, this advanced level of “machine thinking” will raise the potential for workers to contribute at a higher level which has always been the impact of new technology. This creates opportunities for people to grow and develop, something I think we should all be excited and optimistic about. I do believe advanced technologies will put some roles at risk, at least as these roles are being executed today, as these new systems get better and better at diagnosing complex problems. My optimism, however, comes from believing that humans will continue to maintain essential roles that require creativity, empathy, critical thinking, and ethical decision-making. Collaboration between humans and technology results in improved productivity and new opportunities; there’s no reason to think this latest technology revolution will be any different. Governmental and Market Factors Much of what we do here at aeSolutions is either directly or indirectly impacted by governmental policy, particularly as it relates to the regulated industries that we serve, such as the energy sector. Governmental decisions will continue to impact investments in new energy sectors, the green economy, and large-scale infrastructure programs. These are poised to create huge opportunities for companies like ours, provided we remain agile enough to adapt to these up-and-coming economic opportunities. On an international level, deglobalization without increasing production costs and a smaller workforce will both drive up the need for automation. Regardless, I’m confident we’ll continue to redefine ourselves in ways that allow us to deliver the most value to our existing clients and new ones. Staying Laser Focused For aeSolutions, putting the client at the center of our business, maintaining an efficient and lean operation to drive costs down, and focusing intently on clients’ needs and business objectives will shape the next two decades. Operationally speaking, being able to transition clients from our front-end consulting services to our back-end engineering and automation teams with high quality and predictability will be key to executing larger, more complex projects, ultimately bringing real, lasting value to our clients on a larger scale. We will continue to support our team members to help them reach their full potential as employees and as people. For clients, working hard to serve as their guides while always having a keen interest in their overall success, not just the success of their projects, is how we do business. With the leadership team we have in place and the exciting vision we have for the future, we are poised to take our employees, our clients, and our business to the next level.

by Greg Hardin, CFSE | Sr Principal Specialist, Practice Lead, SIS Engineering In 2016, the International Electrotechnical Commission (IEC) published Edition 2 of the IEC 61511 standard, “Functional Safety – Safety Instrumented Systems for the Process Industry Sector,” which the International Society of Automation (ISA) 84 committee also adopted in 2018 as a U.S. national standard (ANSI/ISA-61511-1-2018). This standard covers the design and management requirements for a Safety Instrumented System (SIS) throughout its lifecycle. The 2nd edition of IEC 61511 now requires – by use of the word “shall” – that a Stage 4 Functional Safety Assessment (FSA) be conducted during normal operation of a facility to ensure the SIS is providing protection and risk reduction against the hazards as designed and intended. Initial Stages of the SIS Lifecycle An FSA is carried out in five (5) stages throughout the SIS lifecycle. Prior to designing a SIS, a hazard and risk assessment is conducted to determine required Independent Protection Layers (IPLs) for risk reduction. After Safety Instrumented Functions (SIFs) have been allocated to protection layers, the Safety Requirements Specification (SRS) documents the functional and integrity requirements for each SIF. Following the SRS, the Stage 1 FSA precedes the design and engineering of the SIS, Stage 2 FSA precedes the installation, commissioning, and validation, and Stage 3 FSA precedes the SIS operation and maintenance. Stages 1-3 of the FSA cover the SIS from original concept as defined by the hazard and risk assessments, through design, construction, and commissioning. In practice, this is commonly where SIS assessment ends, yet Stage 4 is essential and now required for the operation and maintenance phase to ensure the SIS meets its safety performance targets. Stage 4 A Stage 4 FSA is absolutely critical for monitoring SIS performance, understanding operating behavior of the installed devices, and verifying reliability assumptions made during design. It takes a number of years of experience with the operation for an FSA to truly reveal trends of how the SIS responds to process deviations. A Stage 4 FSA can determine whether: Are the SIFs being called upon with the expected frequency? Are the SIFs functioning correctly when called upon? Do SIF trips result from the causes identified in the hazard and risk assessments? Are proof tests procedures being executed at the required frequency and documented appropriately? If bypassing elements of a SIF is allowed, is the correct procedure followed when this occurs? Is a SIF in improper bypass mode? Other aspects of operation and maintenance identified in Clause 16 of IEC 61511 Although IEC 61511 does not prescribe when or how often to perform Stage 4, Stage 4 FSAs should be conducted periodically over the lifecycle of the installed SIS as new hazards are identified, after plant modifications, and at periodic intervals during operation to confirm that the SIS continues to operate and protect against hazards as designed. Historical data collected over the lifecycle of the SIS can also help mitigate failures and provide a basis for statistical reliability. The Bottom Line The 2nd edition of IEC 61511 emphasizes understanding the behavior of a SIS in its operating environment. The most important conclusion, however, is whether the SIS is providing the necessary protection, regardless of how carefully it was designed in compliance with standards. Investing in periodic Stage 4 FSAs to fulfill SIS requirements per IEC 61511, as well as addressing SISss during normal operation as part of good practice, can result in safer operations and confidence that the SIS is achieving its designed risk reduction. Related: FSA Stages - What They Are and Why We Do Them How About a Stage Zero Functional Safety Assessment (FSA)?

We previously addressed the basic concerns around combustible dusts, many of the standards that address dust hazard guidance, and the properties and testing for combustible dusts. This article will build on those topics to address potentially unrecognized dust hazards at your site and common potential ignition sources for both internal and external dust clouds or layers. Pt1. ​Do You Know the Basics? Pt2. Dust Properties and Dust Hazard Signs by Judith Lesslie, CFSE, CSP Identifying Dust Hazards If a process includes particulate or dust handling steps, then the process owner should determine if that dust is combustible and if so take the appropriate protective measures. That is accomplished by testing samples for the properties as described in part 2 of this series of blogs; then performing a Dust Hazard Analysis (DHA) and executing the necessary recommendations for process risk reduction. Safeguards and DHAs will be further discussed in later blogs in this series. If you are new to a dust or particulate handling facility, then there are a variety of ways that could alert you to a potential combustible dust hazard other than site orientation and area training. For example, clues that the process dust is potentially combustible include safeguards such as a nitrogen inerting system, electrostatic discharge control measures, nitrogen suppression systems, or building or equipment blast panels in the field and on the facility P&IDs. Equipment clues include the presence of dust collectors, eductors, air locks, screeners, pneumatic conveying system, rotary locks, silos or several different types of dryers. From a documentation perspective, if the facility area classification drawings note that any areas are rated as Class II (NEC) or Group III (IEC), then the likelihood the facility is handling combustible dust or particulates is high. Housekeeping regimes that are focused on preventing process dust or particulates from accumulating internally or externally are another obvious indicator. Lastly, and most concerningly, if you are present in a facility with the routine presence of dust layers or dust clouds, that is a clear indication of a dust issue that has potentially not been adequately addressed. Ignition sources In a DHA for combustible dusts, there are three basic tasks once the presence of a combustible dust is established. The first task is to identify credible ignition sources for potential dust clouds and layers internal to equipment and external to equipment (compartment or room-based dust clouds or layers due to undesired system leakage). The second task is to establish the potential frequency of the ignition scenarios and the potential consequences; this is often called risk ranking, similar to a process hazard analysis. The third task is to identify recommended improvements if a dust explosion risk ranking justifies it per facility risk criteria. We will discuss the first task, identification of ignition sources in this blog. For dust clouds, a catalog of ignition sources and their potential ignition energy should be compared to the relevant dust parameters, including minimum ignition energy (MIE) for an explosible concentration of the dust. What are ignition sources? Basically, any electrical, mechanical, or electrostatic energy source with enough energy to ignite a combustible dust. There are a variety of ignition sources for any given process, and they are not necessarily the same from process to process. Ignition sources are commonly listed with their typical ignition strength in millijoules, for ease of comparison to the minimum ignition energy (MIE) of the subject dust. A few ignition sources that are commonly encountered include: An additional consideration for dust clouds or layers internal or external to equipment is whether or not hot surfaces may potentially be present, for example due to process reactions, use of steam or fired heat, or equipment surface temperatures (including during malfunction conditions). These potential surface temperatures should be compared to the auto-ignition temperature (AIT) of the dust to determine if an ignition hazard may exist from simple contact. Building on the concern for dust layer buildups both internal and external to equipment, a phenomenon called the maximum rate reaction is of concern for some combustible dusts. Some dusts are capable of self-heating in an exothermic reaction if allowed to persist in a layer above the maximum rate reaction onset temperature for long enough. You should be aware if your material is subject to this condition via the testing conducted as described in part 2 of this series of blogs. If you have no knowledge of whether or not your material is subject to the maximum rate reaction, this would be a good time to initiate testing! Testing results for the time to maximum rate/exothermic reaction at a given temperature is typically provided as a set of temperatures and times of interest. If the maximum rate reaction does actually begin due to layer buildup and a sufficiently warm surface temperature, then it can produce smoldering and fire; and combustion products can be carried along in a moving particle stream and become a secondary source of ignition. It can also produce toxic or flammable gases, depending on the process and conveying gas. The information obtained through maximum rate reaction testing is highly relevant to protocols for cleaning of dust layer buildups; keeping process temperatures and equipment temperatures at a safe level; and housekeeping & maintenance regimes to minimize dusting around process equipment. If you are handling a dust subject to the maximum rate reaction, then properly managing layer buildups via internal and external housekeeping and maintenance practices; keeping process temperatures below the maximum rate reaction onset temperature; and properly setting the equipment temperature classes to below the onset temperature for your electrical equipment are all of paramount importance. The bottom line is that even dusts with weak explosivity and high ignition energy requirements can be dangerous under the right circumstances. Development of a set of credible ignition sources, then identification of a set of adequate safeguards is key to managing combustible dusts safely. Later articles in this blog series will address potential safeguards and commonly used dust hazard assessment (DHA) methods. The Stakes Do you handle potentially combustible dusts or particulates at your site? It is difficult to adequately control a hazard that is not well-understood and no company wants to learn of dust explosion hazards the hard way. How do you know if you have combustible dust hazards present? Screening and testing of a representative sample of the dust for the parameters noted above is the clear answer. How do you know if you have credible ignition sources present? By conducting a DHA with sufficient technical expertise involved to identify credible ignition sources and compare them to the relevant dust parameters. So What? If you have not previously taken a deep dive into the properties of your particular dust(s) and ignition sources at your site, now would be a good time to do so. If you do not have the right technical expertise in your company to assess dust hazards, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables assessors to recommend reputable testing labs and to share the general and specific methods proven to minimize dust explosion hazards across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Next in the series: Dust Hazards Pt. 4 – Dust Handling Safeguards Full PSM Services

Industry uses many numbers in process safety associated with predicting the likelihood of rare, catastrophic events (e.g., failure rates, demand rates, incident rates, probability of failure, probability of ignition, etc.). Yet have you given serious thought to the accuracy and trustworthiness of those numbers? For example, layer of protection analysis (LOPA) often uses target numbers in the range of 10-4 per year or lower. How can you determine or prove whether you’re actually meeting these numbers? How can you use traditional frequentist-based statistics to make inferences about rare events that haven’t happened yet in your plant? After all, it’s neither practical nor ethical to determine rare event frequencies of catastrophic accidents by experiment. Instead, your achieving such rare event frequencies must be inferred. And there are many inferences that must be made when arriving at a calculated LOPA number. For example, the assumed probability of failure of each safety layer is an inference. And the data you may be using for the inferences may not even be from your plant. Yet you’re interested in your own situation, not everyone else’s. What to do? Enter Bayes. Bayes’ theorem (a.k.a. Bayes’ rule) provides the likelihood of occurrence of one-off events. Bayes’ probability is not defined by long-run, frequentist-based averages. In Bayes’ rule, qualitative knowledge of a process can be used to quantify the uncertainty of assumptions about the process. It can help you quantify the odds of the proverbial safety dice before you throw them. A Bayesian engine in simplified form. Bayes’ rule works with sparse data. It’s a simple formula for updating current beliefs based on new evidence (data that is both quantitative and qualitative) as it trickles in, as shown in the accompanying figure. It treats parameters as variables, not fixed-point values. It provides a way to update a parameter as new evidence (data) is gathered, as opposed to waiting potentially decades to pool enough data to make a valid frequentist inference. Bayes’ rule is also able to account for information that may not be showing up in your data. As new data and evidence trickles in, use of Bayes’ rule can provide the most consistent and rational method to update your current beliefs about safe operation. It’s the best we can do in a complex changing operating environment where we can’t afford to wait decades to gather enough data to use frequentist-based methods. To learn more about how Bayes’ rule can be applied in process safety, read the full paper “Reverend Bayes, meet Process Safety” .

Kahneman has written about fast and unconscious thinking (a.k.a. system 1), versus conscious and slow thinking (a.k.a. system 2). We use mental short cuts in fast and unconscious thinking to make it through the day. We do this simply because it’s exhausting to maintain a continuous conscious stream of thought for any significant length of time. (Think back how mentally taxing it was when you first learned to drive. Now the process is unconscious.) Unconscious thinking usually leads to good outcomes (or our race would not have survived for long), yet it makes us vulnerable to systematic biases (mental traps) that arise from their use. This can pose serious problems for operators when responding to abnormal situations. Proper operator response requires situation awareness, which consists of 1) what? (becoming aware of the problem), 2) so what? (interpreting and diagnosing), and 3) what now? (projecting into the future). Most decision making and task execution takes place in the subconscious mind. (People spend 95+% of the day in the subconscious state.) Unfortunately, our subconscious mind is more prone to systematic error and bias in decision making due to the use of mental shortcuts. This is the trade-off for fast and effortless thinking. Our subconscious mind is reviewing its stored pattern library looking for matches. If no match is found, it kicks out to our conscious mind. Our conscious mind is essentially in hot-standby, ready to engage only when a problem has been detected by the unconscious. But the transition between the two takes effort, and the conscious mind is slow and laborious. The three elements of situation awareness are best performed by the conscious mind. But due to the problems addressed above, it makes sense to evaluate how we might improve decision making using our subconscious minds. It takes time and practice to develop skill-based intuition. Yet for certain rare and hazardous events there may be no operational experience related to responding to such an event. Therefore, developing habits related to safe operation should be developed. Designing for effective situation awareness and operator response to abnormal situations can be addressed by considering the following four techniques: 1. System design 2. Developing skill-based intuition 3. Creating safe habits 4. Using “nudge theory” For more details, read the full paper “Design Operator tasks to minimize the impact of heuristics and biases”.

by Melissa Langsdon Senior Principal Specialist In the Clean Air Act Amendments of 1990, Congress required the Occupational, Safety and Health Administration (OSHA) to adopt the Process Safety Management (PSM) standard to protect workers and required the Environmental Protection Agency (EPA) to protect the community and environment by issuing the Risk Management Plan Rule (RMP). PSM and RMP were written to complement each other in accomplishing these Congressional goals. Both the PSM regulation in 29 CFR 1910.119 and the RMP Rule codified in 40 CFR Part 68 are critical aspects of industrial operations, aimed at protecting employees, facilities and communities from potential hazards associated with highly hazardous chemicals and regulated substances, respectively. To ensure adherence to regulatory standards, companies often seek the expertise of PSM/RMP consultants. In this blog post, we will delve into the role of process safety consultants and explore how they assist clients in understanding their compliance gaps, implementing effective safety programs, and continuously reducing risks. Understanding the Need for PSM Consultants PSM/RMP Program Development and Implementation can be overwhelming. In addition, many organizations require additional resources to support existing process safety programs due to a lack of dedicated resources or spending cutbacks. This is where PSM/RMP consultants come in. Their primary goal is to help clients bridge the gap between their existing safety programs and the requirements mandated by regulatory bodies such as OSHA and EPA with regard to process safety. Compliance and Beyond PSM/RMP consultants cater to a wide range of clients with varying objectives. Some clients approach consultants solely to ensure regulatory compliance by meeting the minimum requirements of regulations. Others seek to exceed regulatory requirements and proactively enhance their safety programs. Additionally, there are companies that are entirely new to the regulatory landscape, requiring guidance on implementing PSM/RMP programs for the first time. In some cases, regulatory requirements may even mandate the involvement of third-party auditors. It is worth noting that future changes in regulations may further emphasize the use of third-party auditors. The Dual Perspective of OSHA and EPA OSHA and EPA approach process safety from different angles. OSHA focuses on mitigating workplace-related risks and injuries from highly hazardous chemicals. On the other hand, EPA addresses regulated substances and emphasizes community safety and the prevention of offsite impacts. Process safety consultants possess expertise in both perspectives, ensuring comprehensive safety measures that protect both employees and the community. The Importance of Fresh Perspectives Having an external consultant with a fresh set of eyes is invaluable in identifying potential non-compliance issues and process gaps. Long-standing internal employees may inadvertently overlook certain aspects of the site’s safety program, leading to compliance risks. By bringing in a different viewpoint, process safety consultants can help identify and rectify such issues, ensuring a more robust and effective safety program. Real-Life Implications Real-world incidents, such as the West Texas Fertilizer incident in 2013, have highlighted the need for continuous improvement in process safety. OSHA and EPA have pushed for regulatory changes as a result of these incidents. PSM/RMP consultants play a crucial role in helping facilities reduce their risk of chemical releases, thereby improving workplace and community safety, environmental contamination, and other onsite and offsite impacts. The Capabilities of PSM/RMP Consultants PSM/RMP consultants offer a range of services to assist organizations in enhancing their process safety programs. These include: Process Hazard Analysis (PHA) Facilitation: PSM/RMP consultants facilitate PHA sessions, which are used to identify potential hazards and develop risk reduction strategies. Overall Process Safety Program Development: PSM/RMP consultants assist in the development of comprehensive process safety programs, including management procedures, operating procedure development, and mechanical integrity procedure development. PSM/RMP Compliance Audits: PSM/RMP consultants conduct regulatory required 3-year audits to assess the compliance and effectiveness of PSM and RMP programs, identifying areas for improvement. Training: PSM/RMP consultants provide management-level training and internal training to equip employees with the necessary skills to facilitate PHA sessions and conduct internal audits. Risk Assessment: PSM/RMP consultants perform different types of Risk Assessments including Quantitative Risk Assessments (QRA), Safety Case Development, Layer of Protection Analysis (LOPA), and Alarm Rationalization. EPA Risk Management Plans: PSM/RMP consultants prepare initial and 5-year resubmission of EPA required Risk Management Plans, along with the Hazard Assessment for the development of Worst Case Release and Alternative Case Release Scenarios (WCRS and ACRS). As a supplier of complete process safety and risk management solution consultants, aeSolutions is proud to provide engineers from industry with design, maintenance, operating, and process safety backgrounds. Our specialists understand how plants operate because they have actually worked in covered processes and facilities. Their knowledge supports a practical approach to risk reduction solutions for PSM and RMP compliance.

by Tom McGreevy All automation projects ideally follow a process that reflects the classic systems engineering V model, whereby a need is identified, which drives requirements. Requirements are analyzed and broken down so that they can be allocated to a functional solution. In this manner, the classic “How do you eat an elephant?” problem can be tackled with a “one bite at a time” strategy. Once all requirements are allocated to an agreeable solution, the work to realize the solution can begin. Starting with the smallest subsystems identified in the analysis and allocation phases, the full solution comes together as subsystems are integrated to form a complete system that is not only built correctly, but provides a solution to the original need. Critical to the ultimate success of any automation project is appropriate testing as the system is being realized. In the industrial automation world, two very common terms are factory acceptance testing (FAT) and site acceptance testing (SAT). The FAT is typically performed at the facility of the system provider, either by an OEM or a control system integrator. A properly performed FAT will provide… >> Read the full blog on AutomationWorld.com #aesolutions #ThoroughSystemTesting

In the evolving world of chemical processing, companies face a formidable challenge as they strive to keep pace with ever-evolving industry demands, develop novel formulations and deliver innovative products to market. Meeting customer needs often requires adjustments to production processes, including new plants, facility expansions and equipment upgrades. The successful execution of such projects hinges upon comprehensive planning, particularly when it comes to evaluating process safety risks. Complex assessments, such as studies of overpressure relief devices, facility sitings and process safety procedure development, are crucial elements in this process. However, plant operators are primarily experts in running chemical plant operations, not project planning. To shed light on this critical aspect, Chemical Processing recently spoke with Chris Neff, senior vice president of project development for aeSolutions. In this discussion, Neff delves into the intricacies of the project-planning process and outlines methods for chemical manufacturers to integrate safety seamlessly into their projects. "I think one of the biggest challenges is the belief that process safety is a cost rather than an integral part of the operation." The full interview is available on chemicalprocessing.com as well as an audio podcast:

Excerpt from automation.com: Review by external auditors with wide-ranging experience has proven at many sites to provide the best-case outcome of an audit, resulting in findings and best practice recommendations that drive true compliance with right-sized resource needs. In many cases, external auditors can also offer specific methods and techniques for efficient and speedy resolution of concerns identified at sites. Their range of experience enables external auditors to share the general methods proven to drive good PSM and RMP compliance across industry. Companies with lean or less-experienced workforces or that are unsure where they stand versus industry norms for PSM and RMP compliance may benefit from engaging a firm with experienced auditors. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to efficient compliance with the necessary standards. Read full article->>When it Comes to Process Safety Audits, External Auditors Maximize Safety. Here’s How. (automation.com) Full PSM Services

In the machinery industry, a safety function is a control function that reduces the risk of injury, exposure to hazards, or harm to the operator. To classify a safeguard identified in the risk assessment as a safety function, refer to the aeSolutions blog post "Machinery Safety – Is it a Safety Function?". Functional safety is a methodology used to design, specify, implement, validate, and maintain safety functions. Conformity to functional safety standards helps analyze safety function failure rates and provides assurance that the design and integration of safety functions are reliable and effective for the life of the safety function. The two most commonly used standards in the machinery safety realm of functional safety are ISO 13849-1 and -2, which are a sector-specific versions of the broader functional safety standard IEC 61511. ISO 13849-1 describes Performance Levels (PLs) that are analogous to Safety Integrity Levels (SIL) in process safety. Each safety function identified in the risk assessment and the Safety Related Parts of the Control System (SRP/CS) is assigned a required PL depending on the risk assessment and risk ranking structure. PLs use discrete levels to represent the range of the Probability of Dangerous Failure per Hour (PFHd) of the safety function. In practical terms, the PL signifies the reliability of the function and probability that a safety function will fail (i.e., not perform when needed). There are five (5) performance levels (a, b, c, d, e). PLa is assigned to safety functions required for low-risk hazards and has the least stringent design requirements, whereas PLe is assigned for high-risk hazards and requires a high performance level of the safety function. PLs are dependent on the hardware and structure of the circuit, and the circuit components are characterized by the circuit categories (B, 1, 2, 3, 4) and failure data such as the Mean Time to Dangerous Failure (MTTFd), Diagnostic Coverage (DC), and Common Cause Failure (CCF). The chart below from the ISO 13849-1 standard illustrates the relationships between these factors. Each circuit category requirement (x-axis on chart) is associated with specific performance level(s) (y-axis on chart). Category B is the most basic circuit category, with a single channel, low and medium MTTFd, and non-applicable DC. The resulting PL is either a PLa or PLb. Category 1 achieves higher reliability than Category B, and each circuit category progressively increases its requirements. Category 4 corresponds to a PLe and has the most safety function requirements, as it is a dual-channel circuit with high MTTFd and high DC. Once the actual PL of the designed safety function has been determined, it needs to be verified that it meets the required PL per the risk assessment. There are also software tools available that assist in PL calculation. If a gap exists between the safety function PL and required PL, the design needs to be reiterated to increase the PL, such as increasing diagnostic coverage or re-evaluating the circuit categories. Design factors, including process, operating stress, environmental conditions, and operating procedures, should also be considered. The next step is the most common mistake made in machinery functional safety – skipping the validation. Validation occurs after the safety function is designed, verified, installed, and programmed. A validation procedure analyzes and tests the safety function and can include a simulation of faults and verification that the safety function responds as expected under all scenarios. It is critical for those responsible for functional safety to validate that the function is acting as intended, as there is still potential for error at the end. The second part of the standard, ISO 13849-2, provides guidance on the validation procedure to ensure the category and performance level is achieved by the SRP/CS in accordance with the function’s design criteria established in ISO 13849-1. Following validation, maintaining these systems and applying regular preventative and corrective maintenance plans is also very important to keep the safety functions working in a safe and effective manner. Functional safety is necessary in the manufacturing and machinery industry to have assurance that the design and integration of safety functions are reliable and effective when called upon to reduce the risk of human injury or risk of exposure to hazards. PLs are a benchmark for performance that the safety function is required to meet; without benchmarks, it would be challenging to understand whether safety functions are achieving their purpose. The ISO 13849-1 and -2 standards must be applied to ensure that a safety function is both designed properly and validated to test that its intended performance is being achieved (do not make the mistake of skipping this step!) and maintained throughout its life.