Inspectioneering
Inspectioneering Journal

Reynolds Wrap Up: Could the Dirty Dozen FEMI Issues Be Lurking Out-of-Sight at Your Operating Facility?

By John Reynolds, Principal Consultant at Intertek. This article appears in the March/April 2025 issue of Inspectioneering Journal.
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Introduction

There are at least 101 important essential elements of fixed equipment mechanical integrity (FEMI), all of which could lead to hydrocarbon releases and considerable losses under some specific circumstances [1]. However, this article is about my dirty dozen top contenders for FEMI issues that have a higher chance of leading to the risk of unanticipated catastrophic losses in hydrocarbon process plants (i.e., the ones with higher consequence/lower probability FEMI events on most risk matrices like the one shown in Figure 1). In column E of the matrix, the top two red boxes have the highest risk (consequences and probability), typically are well recognized by PSM analysis, and have most of the appropriate risk mitigation processes (physical and process) in place to control their risk. However, the ones in the lower three risk boxes in column E (labeled possible, unlikely, and rare for probability) are often not recognized as well when they involve FEMI issues. It’s mainly in those three boxes where most of my dirty dozen reside.

Figure 1. Typical unbalanced risk matrix.
Figure 1. Typical unbalanced risk matrix.

The Dirty Dozen

I arrived at my candidates for the dirty dozen by reviewing my files of big FEMI losses in our industry over the last 50+ years. Since these issues are somewhat less likely, they are often lurking in the background, out of sight for many FEMI personnel. What do I mean by “lurking” in the background? My dictionary describes the meaning of “lurking” as remaining hidden so as to surprise you in a massive ambush, or an issue that is present as a latent threat – one that is a hidden or more of a concealed threat. That’s precisely the type of FEMI threat that qualifies for being included in my dirty dozen.

Most of the other FEMI issues that we have to deal with are those that are more likely to produce a leak (i.e., risk probability is higher, and typically, risk consequence is often not as high). Some such issues may even be tracked on a list of bad actors of FEMI problems because they have already produced leaks/releases, and steps are underway to prevent more leaks. Clearly, these lower-risk FEMI threats are still important but generally don’t carry the “lurking” high-consequence risks that may not be getting as much attention as those that are better known to produce leaks and releases. So, let me briefly describe my dirty dozen threats for catastrophic losses in our industry.

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