Integrating Mechanical Integrity Risk Management Systems with PHAs

This post is based on an article I originally wrote in the May/June 2013 issue of Inspectioneering Journal. You can find the original article here.

One of the reasons we continue to have too many fixed equipment mechanical integrity (FEMI) events in the refining and process industries is the lack of understanding and appreciation by site management for the hazards posed by the 101 FEMI issues. Too often the formalized Process Hazards Analysis (PHA) is almost completely separate from FEMI hazards analysis; and the two programs are often handled by two different functions at the site, each doing their own analysis. This blog proposes to integrate some aspects of various FEMI risk management systems more closely into PHAs, such that site management would have a better overall understanding and appreciation of the prioritization of the total risks to which the site is exposed.

Hazards Identification and Risk Assessment

Typically PHAs are updated every 5 years or more frequently depending upon the potential that the hazards in any particular process unit may be changing. The PHA process is often the responsibility of Process Engineering or Process Safety work groups. Parallel to the PHA work process is the work process being conducted by asset integrity groups to assess risks of FEMI hazards. And unfortunately, at some sites, there is no formalized risk assessment for FEMI risks. If and when FEMI hazard identification and risk assessments are being conducted, it is usually within the Asset Integrity Group, the Reliability Group, the Inspection Group or whatever else these functions may be titled at your site. If you are fortunate, both groups are doing a good job at assessing associated hazards and risks from their own particular perspective. If you are not so fortunate, then your site may be assessing some process safety risks with PHAs, but not effectively assessing the risks associated with FEMI issues.

Think how much better risks might be managed if the results of PHAs and FEMI risk assessments were fully integrated. The potential result of that integration may be fewer big events associated with FEMI. And history shows that even though our industry is doing better over the last couple decades, we are still having too many repeat FEMI failures that in turn cause major process safety events or financial impacts.

In this case, a repeat FEMI failure is one that occurs fairly frequently somewhere in the industry; perhaps not at your site, but somewhere else.  If each site does not learn from the big FEMI events that occur at other sites, then they are likely to repeat those failures because of a missed learning opportunity.

Site management will not come by the information they need by just sitting on a pile of reports about all of the good things that the FEMI groups at your site are doing. The only way they are going to fully understand and appreciate the FEMI risks they are carrying is when the site FEMI group is involved in site risk assessment and constantly informs site management of the top 10 or 20 risks that need attention.

Managers come from many different technical backgrounds and experiences before they are put in charge of the budget at your site. Those different backgrounds and experiences can lead them to favor spending their resources on other issues. Some just don’t understand the process safety value achieved by applying the necessary resources to maintain existing fixed equipment assets and would rather spend their limited resources on building new assets. Hence the importance again of the FEMI group keeping their management well informed of the magnitude of the top 10 FEMI risks that they are carrying and how to reduce those risks.

RBI vs. PHAs

At an increasing number of sites, Risk-Based Inspection (RBI) is being used to assess FEMI risks and thereby plan inspections based on the associated risk level for each piece of equipment or piping system. But as the name implies the RBI process is focused on risk assessment for inspection planning and not necessarily reducing total risk associated with a particular hazard. It may very well be that reducing or mitigating the consequence of failure (COF) is more effective in some instances. The PHA process may be better suited for evaluating COF. RBI is merely one tool in the total risk assessment portfolio.

Integrating FEMI into PHAs

Another benefit of fully integrating FEMI hazard analysis into PHAs is that agreed upon action items would then go into the same database management system to track progress to completion. Often PHA risk assessment action items get tracked very closely to completion by the site process safety management system; but many FEMI risks and associated risk management action items are not included in such a system. Having FEMI risks and action items integrated with and prioritized in systems, including total plant risks and action items, might lead to different decisions and fewer FEMI incidents.

One way of achieving full integration of PHA and FEMI hazard analysis is to have a FEMI specialist sit in on a portion of the PHA revalidation. Such a specialist would bring to the table all the different types of FEMI damage mechanisms that are both possible and probable in each specific process unit.

Conclusion

There is great potential value in more thoroughly integrating FEMI risk assessments into the PHA work process in order to seek the benefits from a total understanding of all process safety and mechanical integrity risks together in one work process and one management system. When management has all FEMI risks and their associated mitigation action items combined into one management tracking system, it is more likely that all the higher risk FEMI issues will receive adequate attention.

How well are the FEMI risks at your site understood and managed? Do you keep a top ten FEMI risk list in front of your senior site management and update it regularly for them? Could you advance that understanding by management by integrating FEMI risk assessment into the PHA work process?