Written by: Adam M. Musthafa, Sr. Process Safety & Sr. Operation Management Specialist, LebSolution
This Note of Today (NOT) is a promised continuation of the previous one posted on 22 July 2019, titled as “MAJOR HAZARD IDENTIFICATION – PAYING ACUTE FOCUS IN HIGHER RISKS”. It answers the question asked at the end of that NOT: “What is done once the Major Hazards are identified and risk assessed? We will discuss it in the next Note of Today”. Click the below link to read the 22-July-2019 NOT again:
The operators of the Major Hazard Facilities (MHF) should not stop at just identifying and risk ranking of the potential Major Hazards. This campaign of the program should be followed by applying the information obtained from the Major Hazard Identification to identify what are the SCE (Safety Critical Elements) in its Operations. This exercise linked with another pillar of CCPS Risk Based Process Safety, which is “Manage Risk”, especially with the element of Asset Integrity and Reliability.
UK Offshore Operators Association (UKOOA) defines Safety Critical Elements (SCE) as any part of the installation, plant or computer programs whose failure will either cause or contribute to a major accident, or the purpose of which is to prevent or limit the effect of a major accident. In other words, SCE are equipment, instrumentation, controls, or systems whose malfunction or failure would cause or contribute substantially to the release of a hazardous material or energy or whose proper operation is required to mitigate the consequences of such release.
Term Safety Critical Elements, “SCE”, is originally introduced in the 6 July 1988 Piper Alpha Disaster
Investigation Report (Lord Cullen’s Report), leading to application of:
- UK 1996 Design & Construction Regulation (DCR)
- UK 2005 Safety Case Regulation (SCR)
Both regulations mandated identification and management of SCE.
With regards to regulatory regime in US, the identification and management of “SCE like” is mandated in US Law “30 CFR 250.1628(c)” which is derived from API RP 14C (Recommended Practice for Analysis, Design, Installation and Testing of Safety Systems for Offshore Production Facilities”, 8th Edition, February 2017). Whilst the title indicates application for Offshore Facilities, API RP 14C is also being applied to onshore facilities.
In Indonesia regulatory regime, the identification and management of “SCE like” is mandated in Permen ESDM No. 18 Tahun 2018 (Pemeriksaan Keselamatan Instalasi dan Peralatan pada Kegiatan Usaha Minyak dan Gas Bumi), and also in PP No.50 Tahun 2012 (SMK3). The same principles are also addressed in some others regulation from several ministrial office (ESDM for Minerba, Perindustrian, Kemnaker, etc).
By conducting these practices (Major Hazards Identification and SCE Identificatioon), the Operators of MHF have not only shown its commitment to its Company value and standard, but also implement best practices on managing risk in Major Hazard industry to be among the Company who manage its risk prudently by “Paying Acute Focus on Higher Risks”, by “Understanding your Vital Organs” so you can always make sure they are in fit condition.
How about your Company, do you know what are the Major Hazards and SCE in your operations? Let LebSolution know if you need help in this area.
Thanks and best regards,
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