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Roundtable Meeting — June 2-3, 1999

The 21st Century: Process Safety and Factory Mutual

Briefing Paper No. 5
Mary Kay O’Connor 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 1990’s. 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-1930’s 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-1970’s 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 management’s response to worker concerns, expressed usually by unions.

  • The 1970’s saw the development of qualitative and quantitative risk assessment techniques.

This new development can be best characterized by:

  1. The spread of the use of qualitative risk assessment techniques (e.g., HAZOPs) among leading companies.
  2. Quantitative risk assessment techniques (e.g., PRAs) used by the nuclear and aerospace industries (some in the public domain, some not).
  3. Sensitivity displayed by facility operators to potential impact on neighbors.
  • In the 1980’s, 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 1990’s 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 society’s 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 FM’s 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 1990’s

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 workmen’s compensation. The industrial insurance market of the 1990’s 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 company’s reputation and image, loss of market share, customer dissatisfaction [4].

Engineering and Research Activities in the 1990’s

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).

  • Installation Standards

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.

  • Education and Training

FM offers risk management education to all insureds at FM’s 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

  1. "ANSI/ISA S84.01; Application of Safety Instrumented Systems for the Process Industry", Instrument Society of America Standard, 1996.
  2. Croce, P., A., "System Safety Management: Better Business Through Risk-based Safety Management", 11th Industrial Security Symposium, Riyadh, Saudi Arabia, 1998.
  3. Croce, P. A., "An Industrial Insurer’s Approach to Risk Management", Conference on Architectural Surety, Albuquerque, NM, 1997.
  4. Stavrianidis, P., "Reduce Risk with Performance-based Safety Standards", Hydrocarbon Processing, October 1998.
  5. Lees, F., P., "Loss prevention in the Process Industries", Butterworth and Heinemann, Second Edition, 1996.
  6. 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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