Human Reliability practitioners utilize a variety of tools in their work that could improve the facilitation of PHA ‐ LOPA related to identifying and evaluating scenarios with a significant human factors component. These tools are derived from human factors engineering and cognitive psychology and include, (1) task analysis, (2) procedures and checklists, (3) human error rates, (4) systematic bias, and (5) Barrier effectiveness using Bow‐tie. Human error is not random, although the absent minded slips we all experience seem to come out of nowhere. Instead, human error is often predictable based on situations created external or internal to the mind. Human error is part of the human condition (part of being a human) and as such cannot be eliminated completely. For example, a task performed at high frequency (e.g., daily or weekly) develops a highly‐skilled operator with an expectation of a low error probability for that task. However, as the operator’ skill increases, their reliance on procedures decreases, leaving them open to memory lapses caused by internal or external distractions. The fact that a skilled operator becomes less dependent on procedures is not a conscious decision. It is part of the human condition. Forcing a skilled operator to read the procedure while performing the task they are skilled at, is like asking you to think about what your feet are doing as you walk down a flight of stairs. In both cases a loss of adroitness will occur. A large portion of this paper will be to describe with practical examples the five tools mentioned above. Task analysis is a talk‐through and walk‐through exercise of a task (typically focusing on one or two critical steps of a procedure) that is used to identify error likely situations (ELS). Quantitative human error rates can be attached to the ELS depending on if the error is associated with skill, rule, or knowledge (SRK) based performance. Systematic biases produced by Type 1 (fast) thinking cause judgment and diagnosis errors related to response to abnormal situations. Having a working knowledge of these five tools will improve a PHA‐LOPA facilitator’s awareness and ability to better evaluate human error related scenarios and Barrier failure. In addition the facilitator will feel confident about recommending the need for a more detailed follow‐up study such as an HRA (Human Reliability Analysis) . Click here to view the complete whitepaper Topics include: Human Factors, Human Error, PHA, LOPA, Facilitator, Task Analysis, Bias, Cognitive Psychology

Several Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) exist to help someone make their selection and placement of gas detectors (e.g. ISA-TR84.00.07, NFPA 72, UL-2075). However, there are no real consistent approaches widely used by companies. Historically, gas detection has been selected based on rules of thumb and largely dependent on experience. Over the last several years there has been a growing interest in determining not only the confidence but also the effectiveness of those gas detection systems. In fact, incorrect detector placement far outweighs the probability of failure on demand (of the individual system components) in limiting the effectiveness of the gas detection system. An effective gas detection system has three elements: 1. A comprehensive Gas Detection Philosophy 2. Appropriate Detector Technology Selection 3. Correct Detector Placement The Gas Detection Philosophy clearly specifies the chemicals of concern and the intended purposes, i.e. detection of toxic or combustible levels, voting requirements, alarm rationalization , and control actions. Appropriate Detector Technology Selection includes consideration of the target gas and the required detection concentration levels. The primary approaches for Detector Placement are geographic and scenario-based coverage. Geographic coverage places detectors on a uniform grid, and sometimes areas risk ranked to reduce the number of detectors required. Scenario-based coverage has a range of leak models and places gas detectors based on the dispersion modeling results. All three elements for effective gas detection (philosophy, technology, and placement) are interdependent but understanding their relationships is of paramount importance to design an effective gas detection system. The intention of this paper is to present the main considerations that design engineers and process safety professionals should address for each gas detection system element in order to obtain the best return on your investment when placing your gas detectors. Topics include: Instrumentation, Reduction of Risk, Risk Assessment, Protection, Detection System, Alarms and Operator Interventions, Detector, Gas Detection/Dispersion Prediction Click here to view the complete whitepaper

While there is extensive testing and validation of hazards from flammable vapors, less information is available regarding flammable liquid mists. A method is suggested for reasonably estimating the nature and severity of flammable liquid mist hazards by applying published mist property correlations to model inputs and outputs in dispersion modeling software. Better estimating these hazards is important to properly evaluate what mitigations will be needed. One common high flash point liquid that can pose a flammable mist hazard is heating oil. Published literature has documented that the lower explosion point (LEP) temperature of a flammable mist can be much lower than the flash point of the vapor-phase material, and the lower flammability limit (LFL) concentration of a flammable mist can be as low as 10% of the material’s vapor-phase LFL. The actual LFL of a flammable mist has been experimentally observed to be a function of the droplet size. Since many oils consist of a blend of hydrocarbons with various carbon chain lengths, only a few compounds may be chosen to represent the material in commercially available consequence modeling software. This paper will propose: 1) further guidance on an approach that will reasonably approximate the mist properties in the model; and 2) a practical example of modeling the consequences of a mist release. Finally, a case study will be provided where a range of known real world preventative and mitigative measures were tabulated, the existing measures were evaluated against these measures, and then upgrades were proposed based on the model observations. Click here to view the complete whitepaper

by Lauren J. Caldwell, PE(SC), CFSP, CMSE When performing risk assessments on process equipment, are you reviewing machinery as well? Bag dump stations, conveyors, and various vendor-packaged machinery provided with E-Stops are sometimes evaluated in a Process Hazards Analysis (PHA), but they tend to be reviewed at a high level. Because they do not have process flow, they may not be viewed as having traditional process safety hazards. Machines still have hazards, and there is a need for a deeper dive with respect to machinery-related hazards. Did you know that machinery E-Stops fall under OSHA’s General Duty Clause? In an interpretation letter from April 28, 1999, OSHA noted, “If a serious injury could result from an improperly-designed or installed emergency stop device, a citation under the OSH Act’s General Duty Clause could be issued.” This brings the question – how should machinery without process flow be addressed? There are separate standards available for evaluating machinery hazards and designing their safeguards appropriately: ISO 12100, IEC 62061, and ISO 13849. Fortunately, functional safety of machinery follows a similar workflow to the process safety lifecycle. Similar to identifying risk gaps in a Process Hazards Analysis (PHA), we can identify risk gaps for machinery. We can define risk targets, determine how to best close the risk gaps, specify a design, and verify the risk has been adequately addressed. This paper will present a practical example application to demonstrate machinery safety risk reduction in accordance with machinery safety standards for machinery common to chemical process plants. Click here to view the complete whitepaper

The case for incorporating site specific process safety data into our calculations, and how to do it. Originally presented at the AIChE 2023 Spring Meeting and 19th Global Congress on Process Safety If we’re honest with ourselves, Process Safety has a lack of data problem. Nowhere does this show up more than in the types of calculations we perform for Layer of Protection Analysis (LOPA) and Safety Integrity Level (SIL) calculations, for example. Sure, we have generic failure data. But do we have the confidence that this generic data is right for our specific application? In addition, many LOPA scenarios contain “one-off” equipment parameters (either initiating event frequency or probability of failure) for which there is no generic data, leaving teams guessing at what value to use. Worse, LOPA targets are getting smaller (i.e., 1e-5 or 1e-6 per yr) which often leaves gaps, requiring decisions to be made regarding capital spending. Sticking with generic data in these cases can leave us feeling that we are being too conservative. On the Operations and Maintenance side of the LOPA equation, we face similar problems when attempting to verify the installed performance of an IPL (Independent Protection Layer). A multitude of assumed parameters (e.g., failure rates, test and inspection intervals, time in bypass, etc.) for which we would like a method to incorporate actual site data into the values used during design. And ideally this method could optimize these parameters for potential cost savings (for example, extending maintenance intervals). This paper will present a straightforward and easy to use method for feeding operational data back into process safety calculations, using commercial software that is already running on your computer. The paper will explore how much data is needed to confidently claim a parameter value, starting with an assumed or generic value, and periodically updating that value with small data, as evidence (from testing, maintenance, actual demands, etc.) is collected over time. The authors have been using these methods successfully on real process safety applications for several years now, that were all triggered by difficulties and shortcomings in LOPA. These application case studies will be discussed as well. Click here to view the complete whitepaper

Functional Safety & Bayesian Networks Functional safety engineers fol low the ISA/IEC 61511 standard & perform calculations based on random hardware failures. These result in low failure probabilities, which are then combined with similarly low failure probabilities for other safety layers, to show that the overall probability of an accident is extremely low (e.g., 1E-5/yr). Unfortunately, such numbers are based on frequentist assumptions and cannot be proven. Looking at actual accidents caused by control and safety system failures shows that accidents are not caused by random hardware failures. Accidents are typically the result of steady and slow normalization of deviation (a.k.a. drift). It’s up to management to control these factors. However, Bayes theorem can be used to update our prior belief (the initial calculated failure probability) based on observing other evidence (e.g., the effectiveness of the facility’s process safety management process). The results can be dramatic. For example, ass uming a safety instrumented function w ith a risk reduction factor of 5,000 (i.e., SIL 3 performance), and a process safety management program with a 99% effectiveness, results in the function actually having a risk reduction factor of just 98 (i.e., essentially the borderline between SIL1 and SIL 2). The key takeaway is that the focus of functional safety should be on effectively following all the steps in the ISA/IEC 61511 safety lifecycle and the requirements of the OSHA PSM regulation, not the math or certification of devices. Both documents were essentially written in blood through lessons learned the hard way by many organizations. To learn more about the use of Bayesian networks in functional safety , read the full paper here. Click here to view the complete whitepaper

As the share of green energy continues to increase worldwide, the demand for hydrogen is projected to grow rapidly. Production rates in 2022 of nearly 100 mT [1] are expected to triple to 300 mT by 2030 [2]. With such a rapid growth rate, many new players are entering the hydrogen production market. Hydrogen vapors are especially hazardous due to their large flammability range, high reactivity, and low minimum ignition energy. A great need therefore exists for process safety knowledge sharing that is focused on hydrogen safety at such facilities. Hydrogen behaves very differently from other materials. While hydrogen vapors are known to rapidly rise due to its very low molecular weight, liquefied hydrogen (LH2) is known to stay low to the ground including just after evaporating like other cryogenic liquids. Hydrogen has other unique characteristics as well due to a very low normal boiling point. The viscosity of LH2 becomes very low, allowing it to flow with minimal losses of kinetic energy. Altogether, a flammable vapor cloud from a LH2 release can travel a far distance even though it does not form a liquid pool. Advances in hydrogen safety are forthcoming and continue to evolve. In addition, several software vendors have specifically focused on more accurately modeling the properties and consequences of hydrogen releases. A selection of case studies will be shared in which hypothetical indoor and outdoor liquid and vapor hydrogen releases from new hydrogen facilities were evaluated. The case study selection will include an analysis of selection and placement of gas and flame detectors for hydrogen releases and a review of potential hazard preventions and mitigations. Click here to view the complete whitepaper

Have you ever had the problem of having a perfectly functional BPCS * interlock that you know is highly failure immune, yet when it comes time for the Hazard Analysis, you may only take one credit? Unfortunately, for facilities following the IEC 61511 safety lifecycle, any interlock not designed according to the standard is limited to one risk reduction credit. This can make meeting extremely low total mitigated event likelihood targets (such as 1x10-5 or 1x10-6) exceedingly difficult. ​ What can you do if you do not want to redesign your BPCS interlock to meet the IEC 61511 requirements? The only thing left is to seek out a deviation, though you better have good justification. This case study will examine the approach used for one client to justify two risk reduction credits on their robust BPCS interlock in two basic steps. The first step was to decide a reasonable probability of failure using a Failure Mode and Effects Analysis technique (FMEA) . All relevant failure modes including the ubiquitous human component were examined. Next, plant operating history was reviewed and applied in a Bayesian analysis to determine the upper credibility (confidence) limit. The overall FMEA and Bayesian analysis process, including the "why," "how," and results will be provided. ​ As a bonus, the methods used in this case study can be directly translated into a case for Prior Use Justification, data collection, and user-customized and maintained failure rate data. Click here to view the complete whitepaper

There are many devices (sensors, logic solvers and final elements) used in safety instrumented systems  that are independently certified for use in safety applications to different safety integrity levels (SIL). There is considerable debate however whether fire and gas system hardware should have SIL ratings at all. Vendors are naturally interested in promoting independently certified hardware in order to differentiate their products. Considering the differences between safety instrumented systems and fire and gas systems, focusing on the SIL rating or performance of the actual fire and gas hardware  alone is considered by some to be a misleading and questionable practice. This paper reviews a) the differences between safety instrumented systems and fire and gas systems, b) how typical voting of fire and gas sensors not only reduces nuisance trips (which is desirable) but also reduces the likelihood of the system actually responding to a true demand (which is not desirable), and c) why concepts and standards that apply to safety instrumented systems (e.g., SIL ratings) may not be appropriate for fire and gas systems . Click here for the complete whitepaper ​

August 2025 – By Chris Neff, PMP — When planning your industrial project, a well-defined scope isn’t just a preliminary step — it’s the quintessence of getting your budget, schedule, and project lifecycle established. Done right, scoping helps teams prevent costly overruns, delays, and mismanaged resources. Yet, with competing priorities and complex cross-functional needs, critical aspects of the scoping process often do not receive the attention needed for setting a strong foundation, leaving projects vulnerable to avoidable risks. To address these challenges, implementing a clear project development plan — grounded in best practices — can ensure that scoping is comprehensive and realistic, supporting projects from concept to completion. Below are best practices to build an industrial project scoping strategy. Recognize That Scoping is a Dynamic Process Industrial project scoping isn’t a one-and-done static activity. It’s a dynamic, process that evolves as new information becomes available. It is normal for needs to shift over a project’s lifecycle as functional demands, regulatory requirements, and resource availability changes. Scoping requires teams to regularly revisit and refine an initial project plan, ensuring that organizations remain adaptable in addressing unforeseen challenges incorporating improvements as the project progresses. It’s about a sequence for validations, preventing the likelihood of jumping to conclusions. Implementing Progressive Scoping Reviews To establish a process for your project lifecycle, it’s beneficial to integrate scoping reviews into project milestones. This could mean revisiting the scope after each major phase, such as design, procurement, and initial implementation, or conducting scope checks in response to significant operational or environmental changes. Regular scoping reviews provide an opportunity to validate assumptions, assess performance against key metrics, and adjust for any emerging risks. A Practical Case Study In one case study example, a large industrial client was going through an equipment modernization project that aimed to upgrade multiple thermal oxidizers, incinerators, fired heaters, and boilers. The project’s complexity was compounded by the need to ensure each component adhered to rigorous safety and functional standards. Unfortunately, the initial project scoping had not adequately accounted for cross-functional collaboration, which led to disconnects between design and implementation. Furthermore, the scoping had failed to consider the long-term maintenance requirements necessary to keep the newly modernized systems sustainable. This misalignment in the early stages could have resulted in costly project revisions if the issue hadn’t been caught before detailed design work began. By bringing in additional expertise and refocusing on an aligned scoping strategy, the team was able to avoid these potential pitfalls, highlighting the importance of accurate and comprehensive scoping from the outset. This case exemplifies how asking the right questions early can illuminate critical needs that might otherwise go unnoticed, ensuring that projects are not only feasible but also optimized for a successful project lifecycle Ultimately, a dynamic approach transforms scoping from a preliminary task into an integral part of project success, ensuring each phase builds towards a cohesive, sustainable outcome. Ensure That Your Organizational Culture is Ready For project scoping to truly succeed, an organization’s culture must be primed to support it. This involves fostering a collaborative, integrated, and prioritized approach that connects the organization’s broader objectives and engages all necessary stakeholders. Three guiding concepts, collaboration, integration, and prioritization, are essential to building a resilient project scope that can adapt to changes and overcome the inevitable challenges that arise in complex industrial projects. ·         Collaboration  ensures that all relevant stakeholders have a voice in defining project requirements and identifying potential risks early. This open communication creates a shared understanding of project goals and constraints, reducing misunderstandings and aligning team efforts. ·         Integration  means that the project scope is aligned with broader organizational objectives, such as safety, efficiency, and regulatory compliance. By embedding these goals within the project’s core framework, teams create a unified roadmap that guides decision-making across all stages. ·         Prioritization  helps teams focus on the most critical tasks, especially when resources or timelines are tight. By ranking tasks based on their impact on safety, budget, and schedule, a prioritized approach ensures that the project remains on track and adaptable, even when unforeseen challenges arise. This alignment between culture and process not only enhances the success of individual projects but also reinforces a disciplined, goal-oriented mindset across the organization. Ask the Right Questions to Pressure Test Your Assumptions A well-defined project scope requires more than initial assumptions, it demands a thorough examination of expertise, processes, collaboration, feasibility, and objectives. By asking the right questions, organizations can pressure-test their assumptions and build a scope that anticipates challenges, leverages the right expertise, and aligns with measurable goals. Below are five critical questions to guide an effective scoping process. 1. Do You Have the Right Expertise on Board? Organizations often underestimate the expertise needed for industrial projects. Are the right people in the right rooms and integrated into the right discussions? Before beginning a project, it’s important for team leaders to carefully evaluate whether internal groups would benefit from the addition of consultants to supplement the effort. During the scoping stages of a project, the right expertise can help widen the aperture of an organization’s field of view — which leads to a higher integrity outcome downstream. 2. What Discovery Steps Are Essential for a Detailed Plan? Project scoping will typically begin with a planned set of discovery activities. However, a common mistake is a lack of coordination between efforts, in addition to improper documentation. Even though things are getting done, the order of operations may be suboptimal. The solution is to establish a clear set of steps that produces a detailed plan before the discovery process commences. Typically, a well-formed discovery process entails: ·         In-depth interviews and workshops  with stakeholders such as project sponsors, end-users, operators, and maintenance staff, in addition to workshops and meetings to facilitate open discussion. ·         Functional reviews to examine existing processes, systems, and workflows to identify inefficiencies, bottlenecks, and areas for improvement. ·         Technical evaluations  to help assess equipment, infrastructure, and technology. ·         Regulatory compliance checks , which involve reviewing applicable regulations, standards, and compliance requirements. ·         Objectives-setting and outcome mapping, which connects the organization’s goals to specific organizational objectives. ·         A comprehensive hazard analysis  to identify potential risks that could impact the project. The final stage of the discovery process is to develop a comprehensive project development plan and path to execution. 3. How Will Collaboration Continue Beyond Discovery? Collaboration begins in discovery and continues throughout the project lifecycle. Successful projects require continual input, buy-in, and feedback from stakeholders ranging from engineers to managers, team leaders, process experts, and executives. However, organizations are typically navigating heavy time and resource constraints, which can make stakeholder involvement a challenge. In these situations, the key is to incorporate the right expertise at carefully defined touchpoints. One way to develop an integration protocol is to understand how each stakeholder is impacted from the project. What will be the ongoing maintenance requirements? How will responsibilities shift? In terms of development, it is important to clarify expectations and collaboration parameters upfront. 4. Is the Development Plan Realistic and Achievable? The development plan should include: ·         A clear statement of goals and the desired outcomes to be achieved ·         A review of all complex regulatory and safety requirements ·         A clear, detailed, and precise scope definition that specifies all deliverables, tasks, and milestones ·         A resource allocation strategy that encompasses all personnel, equipment, and budget considerations needed for the successful execution of the project ·         A development schedule including documentation and approval steps that outline stakeholder participation ·         Roles and responsibilities to appropriately allocate the tasks to qualified resources Depending on the project, it may be necessary to create multiple options for comparison. Comparative analysis can help to evaluate the practicality and viability of the options from a technical, financial, and functional perspective to ensure the optimal path forward. 5. Are Your Goals Comprehensive and Measurable? Comprehensive and measurable goals are essential for the success of any industrial project, particularly if a scoping process necessitates a changing roadmap. To make goals measurable, each objective should have specific metrics or milestones that can be tracked and assessed over time. This allows project leaders to monitor progress, make informed adjustments, and hold teams accountable for delivering results. By setting goals that are both comprehensive and measurable, organizations can better manage resources, anticipate challenges, and achieve long-lasting project outcomes. Goals should address all critical aspects of the project, from safety and functional efficiency to regulatory compliance and cost-effectiveness. Connecting the Dots When Scoping Your Industrial Project By adopting these best practices and committing to a structured scoping process, industrial organizations can drive projects toward success with greater clarity, adaptability, and alignment with their strategic goals. Scoping effectively means more than meeting initial requirements; it requires ensuring that every stage of a project is aligned with evolving organizational needs and external demands. This integrated approach allows teams to navigate complex challenges, manage risks, and optimize resources throughout the project lifecycle. Ultimately, a well-defined and dynamic scoping strategy is the foundation for project lifecycle success. The process begins with ensuring your organizational culture is ready to ask the right questions early on. …And If You’re Having Trouble Connecting the Dots Scoping an industrial project is no small feat. But even with the best intentions, many organizations find that they lack the internal capacity or expertise to fully implement the strategies we’ve shared.   If your team recognizes the value in these best practices but lacks the bandwidth or technical proficiency to execute them effectively, engaging external expertise could help bridge the gap.   Working with a comprehensive project development solutions provider like aeSolutions  can help you connect the dots between your goals and execution. By partnering with an experienced project development provider, you can reduce risks, optimize resources, and achieve a cohesive, goal-oriented outcome without overstretching your team.   Scoping your project is paramount to its success, and having the right expertise to support you at every step can make all the difference. If you're ready to enhance your project’s potential, consider reaching out to a trusted partner to help you navigate the path forward with confidence.

Introduction | Control System Migrations | Part 7 | Cutover, Commissioning, and the Final Push August 2025 — by Tom McGreevy, PE, PMP, CFSE — Welcome to part 7 of our Control Systems Migration blog series . In this installment, we’ll be covering the cutover phase, which is where it all comes together. This is the point where months or even years of preparation culminate in the actual replacement of the old control system with the new. It’s a high-stakes, high-pressure moment, and one where success is determined by how well you’ve planned, documented, and executed. The term “ cutover ” covers everything from physical equipment replacement to software commissioning and testing. It’s not just about wiring panels; it’s about making sure every step, from demo drawings to site acceptance testing, is aligned and accounted for. Do I Need to Begin with a Full System Backup? The short answer: Absolutely . Before any equipment is touched, every element of the current system must be backed up. That includes program logic, Human Machine Interface  (HMI) configurations, and current “ as-found ” drawings. Photos of panel internals and field installations can also be valuable, not just as references in case you need to troubleshoot, but as a last-resort rollback option if something unexpected forces you to pause or reset the transition. In a rip-and-replace scenario, rolling back may not be feasible, but having a complete picture of the system you’re decommissioning can still help solve problems when they arise during construction or testing. What Should I Include in a Cutover Execution Plan? Your cutover execution plan should be specific and clearly documented. It must describe step by step how the cutover will proceed and clarify who’s responsible for each task. It should also detail what tools, drawings, resources, and timing are required for each stage. This plan should leave no room for ambiguity. What’s happening to each wire? Which devices stay, which go? Are there mystery components, the purpose and disposition of which is not 100% understood? Those need to be resolved before the first wire is lifted, or if not, at least addressed as part of your early cutover activities. Most importantly, there is significant value in making sure this plan is in the hands of the right people. Having a perfectly crafted set of work packages and drawings means nothing if the team in the field doesn’t have them. This kind of breakdown in communication is surprisingly common, but fortunately, it is also completely avoidable. What Pre-Shutdown Work Should Be Done Before a Control System Migration? Any construction or staging work that can be done before the shutdown should already be complete. This includes routing and tagging cables, installing panels where possible, staging materials, and setting up temporary facilities like backup power in accordance with OSHA safety guidelines . If it can be done early, do it early. This will reduce the pressure during actual outage windows and create space to address the unexpected. The Details Matter — Down to the Wire One of the most critical aspects of a successful cutover is understanding where every single  wire goes and what it does. If wires aren’t clearly labeled, properly documented, or tied to an understood function, you risk losing control over the tactical situation very quickly. Similarly, you must know the purpose and disposition of every field device. Is it being reused, replaced, or removed? Has it been tagged and labeled correctly? These details feed directly into the accuracy of your demo drawings and revised documentation, which in turn drives construction confidence and efficiency. Even the basics, like wire sizes, must be documented. Tasks like these may seem like a small detail, but mismatched or unlabeled wire sizes can lead to serious setbacks during installation. Construction Documents vs. Loop Sheets It’s also worth noting that loop sheets, while useful for function testing and configuration, are not  construction documents. Teams need full demo drawings, updated termination diagrams, and accurate cable schedules to perform field work efficiently. Relying on loop sheets for installation will almost certainly slow the progress and may invite error and confusion. Mechanical Completion: Knowing When You’re Ready Before applying power to the new system, everyone involved must agree on what defines mechanical completion. At this point, all installation work should be finished, verified, and supported by construction assurance documentation. It’s a formal milestone that marks the transition from building the system to bringing it to life. Assurance activities in support of demonstration of Mechanical Completion include visual inspections, comparison to approved drawings, wiring continuity checks, and proper ground measurements (of both safety and signal ground). Site Acceptance Testing, Commissioning, and Function Checks Once mechanically complete, the system undergoes site acceptance testing  (SAT) the first time it’s powered on in its new environment. This phase confirms that nothing was damaged during shipping or installation, and that devices are behaving as expected at a basic level. From there, teams move into loop checks, verifying that inputs and outputs are correctly wired and responsive. These checks ensure that transmitters, control valves , and I/O points communicate properly with the system and that grounding is correct. This may also include bumping of motors for those motors controlled by the system, and verification of good communications to any and all third-party devices. It is critical that EVERY I/O device that had its wiring touched during the cutover be checked, to give high confidence in wiring integrity and to enable efficient functional testing. Finally, functional testing begins. Depending on the system, this could include “ water runs ,” simulation of Safety Instrumented Functions  (SIFs), and validation of interlocks . Every step should follow a documented test plan, not just for consistency, but to ensure accountability and traceability. The temptation to rush through these tests can be strong, especially during time-constrained shutdowns. But skipping steps here can have serious consequences, ranging from costly mistakes to safety hazards and legal liabilities. The Takeaway The cutover process is considered the most visible and intense phase of a control system migration. It’s where all the planning, documentation, and collaboration either pay off or fall short. When executed well, the cutover is a moment of accomplishment, the grand finale of your migration efforts. But without discipline, rigor, and proper preparation, it can quickly become chaotic, stressful, and, worst of all, dangerous to equipment and people This phase rewards diligence, not improvisation. Success lies in backing up thoroughly, planning clearly, assessing and addressing risk, labeling accurately, executing deliberately, and testing without compromise. If all of that is in place, your team can move forward with confidence, and your process can start up on a solid, resilient foundation .

Introduction | When “Just Fix It” Isn’t That Simple July 2025 — by Emily Henry, PE (SC) , CFSE, Functional Safety Group Manager — This blog is the second installment in our PHA Recommendation Playbook series , which is intended to help Process Safety, EHS, and facility managers overcome the common challenges they face when trying to close Process Hazard Analysis recommendations. If you missed Part 1, we explored how staffing and budget limitations create obstacles  that can stall even the most straightforward resolutions. In this article, we’re focusing on a challenge that doesn’t always get the attention it deserves: technical complexity . While some recommendations from a PHA might seem routine at first glance, others involve engineering considerations, system interdependencies, or implementation feasibility that turn them into long-haul capital project efforts. These complications can extend gap closure timelines, inflate costs, and even introduce new risks if not addressed with requisite knowledge and intentionality. Technical Challenges in PHA Recommendations | What Makes Them So Complex? Technical complexity refers to the engineering depth, system interdependencies, or feasibility issues that complicate the implementation of PHA recommendations . In industrial environments, this might include design changes that require coordination between multiple engineering disciplines, recommendations that call for feasibility studies, or changes to safety instrumented systems that necessitate revalidation. Sometimes, the complexity lies in hidden system dependencies, meaning that fixing one issue inadvertently introduces another. Compatibility concerns also surface, particularly when legacy systems aren’t designed to accommodate newer technology. Complicating matters further, many of these challenges aren’t fully apparent during the PHA session itself. A recommendation may seem simple on the surface — “install a relief valve”  or “update control logic” — but as the team attempts to move forward with recommendation implementation, the depth of technical complexity becomes clear. The Compliance Cost of Complexity | What Are the Risks of Unresolved PHA Recommendations? Delays caused by technical complexity come with consequences. Regulatory expectations require timely closure of PHA recommendations or, at the very least, well-documented justifications for delays. Facilities that fail to address these recommendations in a structured way may face unexpected audit findings, regulatory scrutiny, or even fines. Beyond compliance, unresolved technical items can increase safety risks. A partially implemented fix or an unaddressed hazard can lead to new vulnerabilities or process weaknesses. From an operational standpoint, unresolved recommendations may lead to unplanned downtime, deferred maintenance, or extended outage windows. Over time, these delays can cause friction between departments and erode trust in the process. How Should You Navigate Complex Technical PHA Recommendations Internally? Handling complex recommendations starts with engaging the right people early. Engineering, operations, maintenance, and safety teams must be aligned on what’s practical, what’s required, and what constraints exist. Cross-functional collaboration is essential for identifying implementation barriers before a plan is set in motion. Conducting feasibility reviews internally can reveal potential problems with space, access, process compatibility, or cost. These reviews don’t have to be overly formal, but they should be consistent and thorough enough to inform the feasibility of implementation of the recommendation at a high level. Documenting known interdependencies also helps ensure one recommendation doesn’t inadvertently conflict with another. Instead of treating each recommendation as a siloed task, consider how they fit into the broader operational strategy. Iterative planning, where adjustments are made as new information surfaces, can help prevent bottlenecks and avoid over-committing resources. When Does Technical Complexity Require External Expertise? There are times when a PHA recommendation goes beyond internal capacity, whether due to staffing limitations or the depth of technical expertise required. Yet not all third-party support is created equal. Some firms deliver a report and walk away, leaving your team with a list of action items and little else in the form of background education. Working with an experienced third-party can change the dynamic. The right partner doesn’t just identify risks; they help you engineer prioritized solutions that are feasible, effective, and aligned with your facility’s operations. A third-party familiar with system interdependencies can offer practical mitigation strategies that don’t introduce new problems elsewhere. Execution also matters. A partner that provides project management oversight can track progress, maintain accountability, and deliver documentation that supports audit defensibility. By helping prioritize what matters most and sequencing efforts strategically, an experienced partner can support smarter capital planning and more efficient implementation. Collaboration with a third-party should never feel like you’re relinquishing control. Instead, it should feel like gaining clarity with a clear line of sight from risk to resolution, with results your team can stand behind. What Are Proactive Strategies to Minimize Technical Implementation Risks? Managing technical complexity isn’t only about reacting once a challenge appears. Many of the difficulties associated with implementation can be mitigated through proactive planning. Three core proactive strategies include: Integrating front-end engineering and risk assessment into your safety processes. This helps identify potentially complex recommendations earlier in the lifecycle. Flagging technically intensive items during the PHA itself or revalidation workshops, so that additional analysis can be scoped and scheduled. Allocating budget and time for follow-up studies, such as feasibility analyses, LOPA updates, or HAZOP reviews, when recommendations involve significant system changes. Maintaining clear documentation is also essential. It not only aids internal decision-making but strengthens your position during audits or external reviews. Finally, it helps to reframe these efforts not just as compliance tasks but as opportunities to improve long-term reliability and operational resilience of your facility. From Risk to Resilience | Technical PHA Resolution Isn’t Just a Fix—It’s a Foundation Facilities that manage technical complexity well don’t just avoid problems, they build stronger, safer operations. When engineering, safety, and operations teams work together to resolve complex PHA recommendations, the resulting improvements often go beyond the immediate fix. Systems become more reliable. Cross-team collaboration improves. Equipment failures and unplanned outages decrease. Moreover, facilities gain stronger footing in the face of audits or regulatory reviews. Well-documented resolutions with traceability to risk assessments show diligence and intent, both of which matter when follow-up questions are asked. When resolutions are handled with care, the outcome shouldn’t feel like a temporary workaround. It should feel like progress. The Takeaway | Moving from Technical Complexity to Technical Confidence Technical complexity is one of the more nuanced challenges in PHA recommendation resolution. It’s also one of the easiest to underestimate. The surface-level simplicity of a recommendation often belies the engineering coordination, feasibility analysis, and systems thinking required to see it through. By planning ahead, involving the right teams, and knowing when to seek experienced, third-party expertise , your facility can navigate even the most intricate recommendations without losing momentum. And when you do choose to bring in third-party support, working with a team that understands engineering, project delivery, and compliance can be the difference between checking a box and building something truly defensible. At its best, technical resolution doesn’t just close a gap, it builds a stronger foundation. From risk to resilience, the path is clearer when the process is collaborative, strategic, and informed.