Process SHE Guide 13

HAZARD STUDY METHODOLOGY

PART 8 - PERIODIC HAZARD STUDIES

This Guide is issued by ICI Technology on behalf of the

Process Safety, Health and Environment Interest Group for internal circulation within ICI only.

This document will only be kept up to date when issued to the holder of a registered binder
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)
CONTENTS

PAGE

8.1

PURPOSE............................................................................................................................................................................. 2

8.2

TEAM.......................................................................................................................................................2

8.3

TIMING................................................................................................................................................................................... 3

8.4

PREPARATION................................................................................................................................................................... 3

8.5

DOCUMENTATION ........................................................................................................................................................... 4

8.6

METHOD ............................................................................................................................................................................... 4

8.6.1
8.6.2
8.6.3
8.6.4

General .................................................................................................................................................................................. 4
Hazard Study 1 .................................................................................................................................................................... 5
Hazard Study 2 .................................................................................................................................................................... 6
Hazard Study 3 .................................................................................................................................................................... 7

8.7

FOLLOW UP ........................................................................................................................................................................ 7

FIGURE
8.1
SHE ASSURANCE PRINCIPLES AND PRACTICE ................................................................................................ 8

Imperial Chemical Industries PLC 1998

Part 8 - Periodic Hazard Studies

Page 1
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)

8.1

PURPOSE
Periodic Hazard Studies (PHS) are process hazard analyses to ensure that the plant continues to be
operated and maintained to appropriate safety, health and environmental standards throughout its life;
and that these are not compromised by changes in operating procedures, feeds, or products and
modifications. It is particularly important to carry out studies when systematic Hazard Studies were not
applied during the design and construction of the original plant.
The requirement for a Periodic Hazard Study on an existing operation could come from a legal (e.g.
OSHA) or group standard (White Book GG 9.1) requirement, acquisition or a review after a series of
incidents. There are a number of techniques which can be used to periodically review the adequacy of
SHE arrangements on existing plants. "SHE Assurance Studies" (based on C&P SGO 2.22) or
"Process Hazard Reviews (PHR)", which include a process hazard analysis element, may be more
appropriate on some sites in order to facilitate an effective consideration and resolution of a range of
issues exposed by such studies and influenced by local and national standards and expectations.
In the USA there may be a legal requirement for Process Safety Management under OSHA 29 CFR part
1910.119. The Process Hazard Analysis element of PSM is met by ICI Group Guidelines GG 9.1 and
the use of Hazard Studies 1 and 2, (reference SHE Information for Managers note SHE-004 :
Volumes 1 & 2). Reference should be made to OSHA literature.
Periodic Hazard Studies, described here, may be used to satisfy part of the SHE Assurance Reviews
required by the White Book GG 9.1 (see Figure 8.1). The Periodic Hazard Study technique is based on
Hazard Study 1, 2 and 3, with the advantage of having an existing operation to study (rather than the
theoretical designs) when applied to the original project. PHS is also an opportunity to review the
inherent SHE aspects of the operation.
PHS is not an Audit.

8.2

TEAM
The team should kept small to allow rapid progress. The ideal size of for the "core" team is about five
people:The Hazard Study Leader
The Operating Manager
The Engineering Manager
A Supervisor or Operator
A Maintainer
Where possible, up to about half of the members of the previous study should be present. However at
least half of the team should be 'new'. Under the USA OSHA regulations there are extra requirements
for team membership which should be followed.
The Hazard Study Leader for the Periodic Hazard Studies will be appointed by the Responsible
Executive. The Hazard Study Leader should be an accredited practitioner of a level appropriate for the
complexity and hazard level of the facility and independent from the plant organisation.

Part 8 - Periodic Hazard Studies

Page 2
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)

8.3

TIMING
A Periodic Hazard Study will normally be held every five years unless triggered by an incident or
required by law. If an investigation following an accident, or dangerous occurrence or learning event
recommends that the plant is restudied, the process will probably involve the repeat of Hazard Studies 1
to 3 (inclusive).

8.4

PREPARATION
Normally, unless the Periodic Hazard Study follows closely after a PSM or GEP (or in the USA 29 CFR
(OSHA) 1910.119) audit of the facility, it will be necessary to review whether:
(a)

the ELDs are up to date;

(b)

there is an adequate modification procedure in place and that it is being followed;

(c)

adequate hazard studies have been carried out of the modifications which have taken place
since the last hazard study;

(d)

alarms, trips, pressure vessels, registered pipework and machines, and pressure relief devices
are subjected to periodic inspection/testing.

The Hazard Study Leader and the team need to have access to a considerable amount of information
about the operation. The Operating Manager should be able to supply the following information for the
study, or point to where it is kept:
(1)

plant process description;

(2)

control philosophy;

(3)

list of incidents, accidents and near misses/dangerous occurrences (and, preferably, the
associated reports) which have occurred on the plant and similar plants.
Associated
transportation incidents should be included;

(4)

material properties, (including HDS or MSDS). Preceding audits should have checked that these
are kept up to date;

(5)

health reviews and studies (e.g. Occupational Health Statements, Control of Substances
Hazardous to Health assessment, Toxic Substances Control Acts).
The responsible
occupational health professionals should be able to provide any significant trends in the health of
the operators and maintenance workers on the plant;

(6)

environmental reports or studies. A list of any excursions from the permitted aqueous and
atmospheric discharges should be available together with any prosecutions/citations. Any
conditions imposed should be noted, and assurances should be obtained from operating staff
that they are being observed;

(7)

siting reviews;

(8)

any reports/documentation required to meet legal requirements, (e.g. OSHA, Health & Safety
Policy, CIMAH report);

(9)

organisation chart;

(10)

emergency facilities and instructions;

(11)

flowsheets, line diagrams;

Part 8 - Periodic Hazard Studies

Page 3
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)
(12)

relief and blowdown schedule/reports;

(13)

trip and alarm system schedule;

(14)

original design manual and specification for the equipment;

(15)

operating and maintenance instructions;

(16)

history of the operation and list of modifications and changes;

(17)

Safety, Health & Environment Dossier, including any previous Hazard Studies, Fire Reviews,
Toxic Emission studies.

The above, together with any other related documentation (including relevant audit reports), should be
studied by the Hazard Study Leader to identify any deficiencies and an action plan produced for the
Periodic Hazard Study.
Visits to, and inspections of, the plant are recommended.

8.5

DOCUMENTATION
Documentation in the form of the records of hazard study meetings and supporting documents, together
with evidence of the completion of all actions, should be filed in the Plant Safety, Health and
Environmental Dossier. STD/F/01022 can be used to index the SHED information. It is important that
the marked up copy of the engineering line diagrams (ELDs) used in the studies are also retained. In
the USA it is also advisable to file a copy of the current version of the methodology used.
The study should generally be recorded on the appropriate standard forms, for example Hazard Study 1,
STD/F/01025, Hazard Study 2 STD/F/01013 and Hazard Study 3, STD/F/01015 and STD/F/01017.

8.6

METHOD

8.6.1

General
The Periodic Hazard Study consists of two main parts. The first part follows the Hazard Study 1
methodology. The second part follows the Hazard Study 2 methodology (but applied to actual plant and
up to date ELDs)
Repeating part, or all, of the Hazard Study 3 should be considered if any, or all, of the following apply:
(a)

audits have revealed deficiencies in the Hazard Study Process;

(b)

significant design deficiencies have become apparent;

(c)

the original hazard studies were poor or part, or all, of the documentation has been lost;

(d)

the plant has not run smoothly;

(e)

there have been major incidents;

(f)

there have been many modifications;

(g)

modifications have not been hazard studied;

(h)

the plant does not have a good modification procedure;

Part 8 - Periodic Hazard Studies

Page 4
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)
(j)

key documents such as the ELDs have not been kept up to date;

(k)

new requirements, statutory or corporate such as new regulations (particularly in the USA),
clarifications, or technical approaches have arisen since the original studies or since the last
periodic study.

Hazard Study 3 is necessarily more time consuming than other study techniques, but the results provide
a comprehensive insight into operating deviations, some of which can cause safety-related problems.
The main advantage of Hazard Study 3 is that it highlights operating problems, particularly related to
start-up and shutdown sequences, as well as identifying critical operator interaction with the process,
and providing the basis for writing comprehensive operating instructions. Also, when carried out
rigorously, it covers all deviation possibilities, and this can sometimes stimulate lateral thinking into new
directions which subsequently reveals unforeseen problems.
Hazard Study 3 has the disadvantage of also identifying minor hazards or operating problems that may
distract efforts from the major issues. Therefore, it is vital that the means of handling these minor
issues is agreed as part of the overall method of the study. For example, it may be decided that issues
that the team agree are 'minor hazards or operating problems' will not be noted as part of the formal
documentation of the study, but that the relevant member of the team such as the plant supervisor
makes a note to follow them up separately. Alternatively, it could be decided that potential operating
problems in particular will not be noted, as important ones will be known by experience and there will not
be the resource available to evaluate all of the potential problems.
For complex modifications to existing plants, a proper Hazard Study 3 of the changes should be carried
out.
8.6.2

Hazard Study 1
An existing operation should have a Hazard Study 1 Report and this should be reviewed to see that it is
up to date. Changes to the report should be issued as a supplement, or a revision, to the original report.
If there is no existing Hazard Study 1 report then consideration should be given to the writing of such a
report. This may not be necessary if the information exists in a suitable alternative form, for example in
acquisitions or Safety Health and Environment Dossier (SHED) filing system or data base.
Each of the sections of the Hazard Study 1 report should be checked to ensure that it is up to date. See
part 1 of this Guide for details on each section:
1.1

Project Definition. Establish the scope of the plant to be studied.

1.2

Process Description.

1.3

Control Philosophy.

1.4

Incident Review. The incidents and dangerous occurrences/near misses which have occurred
since the original studies on the plant (the subject plant) and on similar plants and associated
transportation incidents should be reviewed. For each of the incidents a clear statement should
be made as to how it will be avoided on the subject plant.

1.5

Inherent SHE. A list should be made of significant inventories of hazardous substances. The
opportunity for the application of Inherent SHE principles, see PSHEG 16, should be explored.

1.6

Materials Hazards. The Material List should be reviewed to ensure that it is up to date. The
Hazard Data Sheets/MSDSs should be checked to see that they are up to date. The effects of
any changes should be assessed. The differences between the up to date and original copies of
the MSDSs should be discussed.

1.7

Safety.

Part 8 - Periodic Hazard Studies

Page 5
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)
1.8

Health. The occupational health professionals should be asked to report on anything of

significance in the health of those involved in the operation or maintenance of the plant.
Particular attention should be paid to hearing, and a noise map of the plant, made after it has
been started up, should be reviewed.
The study should consider whether health hazards are adequately identified and prevented by,
for example, Control of Substances Hazardous to Health assessments or Toxic Substances
Control.

8.6.3

1.9

Environment. Excursions from permitted aqueous and atmospheric discharge limits and fines or
citations should be reviewed, together with any conditions imposed, and the precautions taken to
prevent any recurrences.

1.10

Transport and Siting. The effect of site changes and stricter legislation (OSHA) need to be
considered. Quantified Risk Assessments may be required.

1.11

External Authorities.

1.12

Design Guidelines and Codes. The study should consider whether new or revised Regulations,
design Guidelines or Codes have been issued that may impact on the plants design.

1.13

Organisation.

1.14

Emergency Facilities. The study should consider deficiencies identified by emergency practices.

1.15

Further Studies.

Hazard Study 2
Hazard Study 2 is conventionally based on process flow diagrams but Periodic Hazard Studies applies
to existing operations. At this stage the following will exist:
(a)

The actual plant.

(b)

The operating team.

(c)

The maintenance team.

(d)

The operating records.

The plant is divided up into small sections (container, pipeline, machine or activity), usually on the basis
of unit operations. Then, working from the ELD, the team applies the Hazard Study 2 methodology,
Figure 2.1, and guidewords, Figures 2.2, 2.3, to each section or stage of the operation in sequence.
Alternative established guideword lists, for example those used in ICI's Process Hazard Review process
concentrating on loss of containment, may also be used.
In carrying out the Hazard Study 2, emphasis will have to be paid to:
(1)

the application of the current materials hazard data;

(2)

human factors;

(3)

facilities layout;

(4)

environmental impact.

Where a Hazard Study 2 has already been carried it may be sufficient to revalidate that study.

Part 8 - Periodic Hazard Studies

Page 6
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)
8.6.4

Hazard Study 3
If it is decided to repeat the Hazard Study 3 on all, or part, of the plant for any of the reasons given
above, it is essential to have the ELDs checked before starting the study itself. Again, particular
attention should be paid to see if recommendations of ongoing follow up actions such as checks, testing
etc. were implemented and that procedural recommendations were incorporated into the operating
instructions.

8.7

FOLLOW UP
In the normal hazard study process for a new plant, hazard study actions will be reviewed at the next
study with a requirement that all actions for Hazard Studies 1 to 5 will be completed before the plant
starts up. In the case of periodic studies no such deadline exists and so an action plan together with
target dates for the completion of actions must be drawn up and dates set for the review of progress.
Proper action progressing may be a legal requirement (e.g. USA).

Part 8 - Periodic Hazard Studies

Page 7
S&TIS/14913

Process SHE Guide No. 13

Hazard Study Methodology
(March 1998 Edition)

FIGURE 8.1

SHE ASSURANCE PRINCIPLES AND PRACTICE

ICI Group Guidance GG 9.1
a
Hazards
Recognised
& worst
consequences
understood

SEVEN
PRINCIPLES

Periodic Hazard
Studies

b
Appropriate
Equipment &
Facilities Provided
+
'Fit for Purpose'
of reducing risk

Periodic Hazard
Studies,
Specialist Audits

METHODS OF
CONFIRMATION
g
Monitoring
Environmental
releases for
compliance

Management
Audit

SHE
ASSURANCE

Management
Specialist &
Operational
Audits

Systems
& Procedures
exist to operate
and
maintain
integrity

c
Management
Specialist &
Operational Audits

Management
Audit,
HS Auditing

Promotion
of SHE,
auditing
performance,
progressing
issues

Management
Audit

Emergency
Procedures:
Provision
Practice
e

Part 8 - Periodic Hazard Studies

Page 8
S&TIS/14913

Appropriate
staff: provision
of - information
instruction
supervision
training