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Roundtable Meeting June
2-3, 1999
The 21st
Century: Process Safety and Factory Mutual
Briefing Paper No. 5
Mary Kay OConnor Process Safety Center Roundtable
Meeting
June 2-3, 1999, George Bush Presidential Conference Center
College Station, Texas
Paris Stavrianidis
Factory Mutual Research Corporation
Norwood, MA
Abstract
This paper presents a brief history of safety
in the process industries during the 20th century. It identifies
the emergence of performance-based standards and regulations and discusses
the potential impact of these on industry. In parallel, the paper gives
a brief history of Factory Mutual, and discusses the business challenges
of the insurance industry in the 1990s. Finally, the paper describes
what the author sees as the technical and business challenges of the 21st
century both for industry and Factory Mutual.
Process Industries
There has been phenomenal growth in the Process
Industries in the 20th century. This growth has been driven
by timely opportunities, entrepreneurial leadership, advancing skills
and technology, profitable operations and safety responsibility. With
the advent of the industrial revolution new hazards arose resulting in
disabling injuries and fatalities. The process industries found this unacceptable
and continue to transition to safer processes. The speed at which this
transition occurs is a function of technology, operating experience and
cost. The focus on safety in the 20th century can be characterized
by a few significant milestones [2]:
- Pre-1930s focus on safety
was to identify who caused the loss and punish the guilty.
Significant effort was spent on finding
who caused the loss, even punishing the guilty. Little effort was spent
to "fix" or improve facility/equipment (exception is fire
protection with HPR concept which will be discussed later in this paper).
- Pre-1970s focus was on finding
breakdown in and fixing man-machine interface.
The philosophy was to design for operability,
while also taking safety into account. However, safety measures were
inserted by the process designers and not safety specialists working
with designers and operators. When incidents occurred, there was still
some association of blame and guilt, but the focus had shifted from
identifying the guilty to the interface between man and machine. In
other words, finding the breakdown and fixing it. This was largely driven
by managements response to worker concerns, expressed usually
by unions.
- The 1970s saw the development
of qualitative and quantitative risk assessment techniques.
This new development can be best characterized
by:
- The spread of the use of qualitative risk
assessment techniques (e.g., HAZOPs) among leading companies.
- Quantitative risk assessment techniques
(e.g., PRAs) used by the nuclear and aerospace industries (some in the
public domain, some not).
- Sensitivity displayed by facility operators
to potential impact on neighbors.
- In the 1980s, systemic approach
gained credibility, and was accepted by leading industries and government
agencies.
As a result of several notable accidents,
such as Bhopal, Piper Alpha and Pasadena, Texas, the systemic approach
-- i.e., looking at the overall system -- became attractive to industry
leaders as a way to quantify issues regarding safety in a consistent
and systematic way. Systemic safety management became equivalent with
risk-based safety management. At the same time, some key legislation
(see Table 1) was initiated in Europe.
- The 1990s are characterized
by broadened acceptance of the systemic approach and by the development
of performance-based or risk-based standards and regulations (national
and international).
Risk-based regulations were promulgated
and national and international bodies developed risk-based standards
for worldwide application (see Table 1). Leading industries (usually
multinational) that wanted uniform standards worldwide for sales, safety
and manufacturing specifications drove the development of standards.
Other stakeholders (i.e., government at all levels, trade organizations,
professional societies, and the public) became involved in the development
of performance-based standards and the dissemination of information,
thus assisting in societys risk perception, understanding and
risk acceptance.
Table 1. Some Performance-based
Regulations and Standards
Year |
Industry
Regulations and Standards |
FM Standards |
1982 |
SEVESO
Directive (European Community) |
|
1984 |
CIMAH (Control
of Industrial Major Hazard Regulations) UK |
|
1990 |
API RP
750 American Petroleum Institute Management of Process
Hazards, USA |
|
1992 |
OSHA 29
CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals,
USA |
|
1993 |
|
Factory
Mutual DS 7-49, Emergency Venting of Vessels , International |
1995 |
EPA 40
CFR Part 68 Risk Management Programs for Chemical Accidental Release
Prevention, USA |
|
1996 |
ANSI/ISA
S84.01, Application of Safety Instrumented Systems for the Process
Industries, USA |
|
1996 |
|
Factory
Mutual Chemical Risk Index, International |
1998 |
ICC Building
Performance Code Committee Report, International Code Council,
USA |
|
1998 |
|
Factory
Mutual DS 7-45, Instrumentation and Control in Safety Application,
International |
1998 |
SEVESO
II Directive (European Community) |
|
1999 |
IEC 61508,
Functional Safety of Electric, Electronic and Programmable Electronic
Safety-Related Systems, International |
|
Factory Mutual
In its 164 years of existence FM has continually
provided industry with property and business interruption insurance and
prudent risk management services, called Highly Protected Risk (HPR).
For most of our history, risk management focused on developing and applying
scientifically sound loss prevention and mitigation techniques to provide
practical and cost-effective solutions that reduce industrial risk to
manageable levels. Some highlights of FMs history are [3]:
- The first sprinkler system (perforated
pipe) was developed in 1852.
- The first practical automatic sprinkler
was developed in 1874.
- FM begins testing and approving sprinklers
in 1884, primarily for fire specific scenarios.
- FM laboratories are established in 1886.
- FM issues installation guidelines for
sprinkler systems in 1893.
- Factory Mutual Research Corporation (FMRC)
is formed in 1941.
- FM begins sprinkler engineering research
in 1953 and scientific research in 1967.
- FM builds a fire test center in 1967 to
conduct large-scale fire testing.
- Additional "small-scale" laboratories
are constructed in 1970 at headquarters location in Norwood MA.
- Special Chemical Risk (SCR) group is formed
in 1978.
- Circa 1990, all peril coverage was being
written, and the charge for support services was modified to include
all peril loss prevention technology.
- Circa 1993 FM begins to employ effective
risk management principles (i.e., likelihood and consequences) in standards.
- In 1999 the four companies comprising
the FM System merge into FM Global. One company offering industrial
and commercial insurance and risk management services.
Insurance Activities in the 1990s
Factory Mutual offers industrial and commercial
property related insurance programs to industry. These programs focus
on property related loses and business interruption. What characterizes
and separates FM insurance from most competitors is our focus on joint
prudent underwriting with effective risk management. In the past, pre
1990, when an insured had an acceptable risk management program, they
would expect and often received a reduction in their premiums.
Industry has changed significantly in the
last decade. There is more competition in the insurance business from
international companies and from brokers that offer industry a "whole
package" that includes industrial, commercial, casualty insurance
and workmens compensation. The industrial insurance market
of the 1990s can be characterized as extremely competitive with
significant over capacity. As a result, industry has many choices (e.g.,
insurance, insurance and risk management, self-insurance, other risk transferal
vehicles) and premiums have dropped
significantly with smaller profit margins.
Industry has a choice to make: Purchase
inexpensive insurance or purchase a slightly more expensive insurance
that also includes risk management services. FM believes that risk
management coupled with sound loss prevention technology is a prudent
and complementary service to industrial insurance. Avoiding industrial
accidents, particularly in a very competitive business environment, helps
profitability. Insurance (either from an insurance company or through
self-insurance) will cover the cost associated with property damage and
business interruption. What it does not cover is the "uninsurable
losses" such as damage to a companys reputation and image,
loss of market share, customer dissatisfaction [4].
Engineering and Research Activities in
the 1990s
FM provides five engineering and research
services to industry:
- Engineering Field Services
Over 1000 field engineers all over the
world performing loss prevention audits and making certain that insureds
comply with FM Installation Standards and national/international standards
and regulations. In 1978, FM established the Special Chemical Risk (SCR)
Engineers group. Currently about 75 chemical engineers perform PSM activities
worldwide.
- Scientific Research and Advanced Engineering
Scientific research and advanced engineering
work in fire protection (sprinklers, fine spray technologies, gaseous
agents, additive systems, detection and smoke control), materials (flammability,
reactivity, nonthermal damage), structures (response of structures to
dynamic loading such as from natural hazards) and risk engineering (industrial
risk assessment and reliability, availability and maintainability of
process control and safety systems).
FM currently has over 200 installation
standards for industrial equipment in the areas of construction, arrangement
and mixture of contents, process equipment, instrumentation, control
and safety systems and protection systems (sprinklers, water mist, etc.).
The first performance-based standard installation standard was issued
in June 1993 (see Table 1).
- Approvals of Equipment for Industrial
Use
FM currently approves over 40,000 pieces
of equipment. Products, equipment and materials are tested for approval
against specifications (standards). All equipment is approved for industrial
applications. Approvals include hydraulic equipment, electrical and
electronic components and systems for hazardous locations, construction
material and fabrication. FM established a reliability and certification
program for safety instrumented systems based on ANSI/ISA S84.10 and
IEC 61508 standards (see Table 1) in 1998.
FM offers risk management education to
all insureds at FMs Conference and Training Center. FM also offers
continuing training to all field engineers on state-of-the-art risk
management techniques and procedures. Most training is performed on
site (i.e., field offices).
Where is Industry headed in 2000 and beyond?
To predict the future, always a risky undertaking,
we should evaluate and understand the past. The past can be easily understood
by examining Figures 1 and 2 [2 and 5]. It is clear from Figure 1 that
the industrialized world, that is where risk management techniques and
performance-based standards and regulations are used, has made significant
improvements in process safety over the last 20 years. However, the few
accidents that have occurred have had significant consequences (e.g.,
Pasadena, Texas with 23 fatalities in 1989). Industry has to diligently
continue its focus on safety and to pursue the involvement of all major
stakeholders.
The problem is different in developing countries.
The need to quickly industrialize and expand their economies has perhaps
occurred at the expense of safety. Figure 2, even with limited data, does
show a lack of a downtrend on the occurrence of major accidents. The same
international companies that have had success in North America and Europe
have to transfer the lessons learned over the last 20 years to their operations
in the developing world.
The process industries truly made remarkable
advances in the 20th century; a defining difference in going forward into
the 21st century is the almost universal interdependence among businesses
on a global scale, the fast-paced technological advances, the very competitive
business environment, and the sensitivity of governments and communities.
What industry needs is to continue the development of performance-based
standards and regulations that follow the systemic approach and employ
life-cycle models that include the process itself, all safety/control
equipment, and people (operators and community). The approach must rely
on risk metrics to support prudent business decisions and be supported
by a safety culture nurtured and directed by top management. The success
of this approach does not depend on compliance to a minimum set of requirements.
If done properly, it requires a culture change that relies on a continuous
and long-term commitment to understanding, evaluating and improving the
process.

Figure 1. Major Accidents
in Europe and North America

Figure 2. Major Accidents
in Asia/Pacific and Middle East
Therefore, the focus on performance-based
standards and regulations will continue. Table 2 gives some expected standards
and regulations in the next few years.
Table 2. Emerging Performance-based
Regulations and Standards
Year |
Regulations
and Standards |
Expected
2000 |
Factory
Mutual, DS 3-29C, Sprinkler System Reliability, International |
Expected
2002 |
Draft IEC
61511, Functional Safety; Safety Instrumented Systems for the
Process Industries, International |
Expected
2002 |
Draft IEC
62061, Safety of machinery Functional Safety of Electric/Electronic/Programmable
Control Systems for Machinery, International |
|
Draft ASME
RA-S-1999, Standard for Probabilistic Risk Assessment for Nuclear
Power Plant Applications, ASME, USA |
|
NRC and
DOE following Risk Informed Regulations |
|
Draft DIERS
Report, Risk Considerations for Runway reactions, DIERS Group
of AIChE, USA |
|
OSHA PSM
and EPA RMP Beyond 2000? |
What we may eventually create are more performance-based
standards, regulations, directives, guidelines, and practices. Industry
may find a worldwide promulgation of different performance-based regulations
and standards. Very similar to the problem facing industry with prescriptive
standards. Without clear policies and procedures that are accepted by
key stakeholders, this may in fact increase manufacturing costs and create
confusion. As a result those not staying at the state-of-the-art are likely
to fall behind. They will find it difficult to catch up and lose competitiveness.
A possible solution is reliance on international
standards and regulations. In a highly competitive global market with
varying economic forces at work, it makes good business sense to have
uniform and consistent requirements and comply with international standards
such as the IEC 61508 or in the future the IEC 61511 for the process industries.
However, traditional compliance to the requirements
of international standards is not enough. Compliance should also be practical
and cost-effective. That is, it should be achieved by combining common
safety elements from different standards into one program to allow practitioners
to perform a task once and claim compliance to the same or very similar
requirements in a set of performance-based standards and regulations.
Factory Mutual Beyond 2000 An Integrated Approach to Risk
Management
As FM moves into the 21st century as FM Global,
we will continue advancing loss prevention technology and supporting the
development of performance-based standards and regulations. However, FM
will use an integrated approach to risk management. For example, the four
standards/regulations shown in Table 1, (IEC, ANSI/ISA, OSHA and EPA)
have some common Process Safety Management elements (see Table 3); however,
not all the elements are addressed by all the regulations/standards. For
sound process safety management (PSM), we believe one has to address all
the elements, preferably through an integrated PSM approach [6]. This
integrated approach avoids redundancy and overlap while complying with
safety elements of all four standards/regulations.
Table 3. Elements of Process
Safety Management
Elements
of
Process Safety Management (PSM)
|
ISA
/
IEC
|
OSHA
PSM
|
EPA
RMP
|
FM
Integrated PSM Approach |
Hot Work
Permits |
|
Ö
|
Ö
|
Ö
|
Incident
Investigation |
+ |
Ö
|
Ö
|
Ö
|
Mgmt.
of Change |
Ö
|
Ö
|
Ö
|
Ö
|
Mechanical
Integrity |
+ |
Ö
|
Ö
|
Ö
|
Operating
Procedures |
Ö
|
Ö
|
Ö
|
Ö
|
Pre-Startup
Safety Review |
+ |
Ö
|
Ö
|
Ö
|
Contractor
Handling |
+ |
Ö
|
Ö
|
Ö
|
Emergency
Mgmt. Plans, Inside Plant |
+ |
Ö
|
Ö
|
Ö
|
Emergency
Mgmt. Plans, Outside Plant |
+ |
|
Ö
|
Ö
|
Employee
Participation |
|
Ö
|
Ö
|
Ö
|
Training |
+ |
Ö
|
Ö
|
Ö
|
Installation/
Maintenance SISs |
Ö
|
+ |
+ |
Ö
|
Decommissioning |
Ö
|
|
|
Ö
|
Process
Safety Information |
Ö
|
Ö
|
Ö
|
Ö
|
Accident
History Data |
|
|
Ö
|
Ö
|
Compliance
Audits |
+ |
Ö
|
Ö
|
Ö
|
Ö , required by standard/regulation
+, partial/ implied compliance
blank, no requirements
|
An overall sound risk management approach
should also include certain accepted activities/steps as listed in Table
4 [6]. Again, the requirements of these activities/steps vary among the
standards/regulations but can be integrated into a single program.
Table 4. Integrated Risk Assessment
Approach
Risk
Management Steps |
ISA
/
IEC
|
OSHA
PSM
|
EPA
RMP
|
FM
Integrated Risk Assessment Approach |
Hazard
Assessment (includes Hazard Analysis) |
Ö
|
Ö
|
Ö
|
Ö
|
Accident
Prevention Management ( PSM) |
+ |
Ö
|
Ö
|
Ö
|
Consequence
Analysis |
Ö
|
|
Ö
|
Ö
|
Risk Analysis/Evaluation |
Ö
|
|
+ |
Ö
|
Risk Assessment |
Ö
|
|
|
Ö
|
Risk Management |
Ö
|
|
|
Ö
|
Ö , required by standard/regulation
+, partial/ implied compliance
blank, no requirements
|
Summary
The process industries have made great strides
in the 20th century, and recently demonstrated that prudent
risk management is the direction of the future. For the global economies
and markets of the 21st century, an integrated approach to
prudent risk management using international performance-based standards
and regulations can be a significant competitive advantage to the leaders
of the industry.
The "integrated risk assessment"
approach, shown in the last column of the Tables 3 and 4, allows one program
to be established and managed for practitioners to comply with these standards
using a range of techniques that afford practicality and cost-effectiveness.
References
- "ANSI/ISA S84.01; Application of
Safety Instrumented Systems for the Process Industry", Instrument
Society of America Standard, 1996.
- Croce, P., A., "System Safety Management:
Better Business Through Risk-based Safety Management", 11th
Industrial Security Symposium, Riyadh, Saudi Arabia, 1998.
- Croce, P. A., "An Industrial Insurers
Approach to Risk Management", Conference on Architectural Surety,
Albuquerque, NM, 1997.
- Stavrianidis, P., "Reduce Risk with
Performance-based Safety Standards", Hydrocarbon Processing, October
1998.
- Lees, F., P., "Loss prevention in
the Process Industries", Butterworth and Heinemann, Second Edition,
1996.
- Bhimavarapu, K., Moore, L., and Stavrianidis,
P., "Performance-based Safety Standards: An Integrated Risk Assessment
Program", ISA Technical Conference, Instrument Society of America,
1997.
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