The Baker Panel Report - ABSA

IMPLEMENTATION OF EXTERNAL GOOD ENGINEERING PRACTICESExternal codes, standards, industry best practices, recommended practices, and other external guidance (collectively referred to as codes andpractices) play an important role in the management of process safety in refineries operating in the United States. 20 Some of these codes andpractices have the force of law; others do not. Several process safety-related regulations apply to BP’s U.S. refineries, and through theseregulations, various generally accepted codes and practices also apply. OSHA specifically acknowledges various industry codes and practices.For example, the OSHA process safety management standard cites process safety guidance that the API, 21 the CCPS (an industry technologyalliance of the American Institute of Chemical Engineers 22 ), and the American Chemistry Council developed. Even if existing codes andpractices do not have the force of law, they can provide valuable tools for managing and reducing risks associated with process hazards. Thesecodes and practices relate to numerous topics, such as the classification of locations for installing electrical equipment at petroleumfacilities 23 and instrumentation for fired heaters. 24 Following codes and practices relating to refineries helps ensure that refineries operatesafely because the codes and practices represent an accumulation of the knowledge and experience of many industry experts. Systemic failureto consider and adhere to codes and practices can result in operations being conducted at a higher degree of risk than would be the case if theoperations were conducted in conformity with the codes and practices.Under the scope of work used in their review of BP’s U.S. refineries, the technical consultants compared BP’s process safety managementprograms, procedures, and performance not only to applicable regulations, but also to codes and practices. Under the terms of the Panel’sscope of work, the technical consultants evaluated only a sampling of external codes and practices that apply to U.S. refineries as a basis fortheir conclusions. Specifically, the technical consultants reviewed BP’s U.S. refineries’ adherence to applicable codes and practices relating tofour areas: safety shut-down systems, area electrical classification, fired heaters, and facility siting.Based upon their assessment, the technical consultants found a process safety management system deficiency in each of the four sampledareas. In making these findings, the technical consultants identified the particular code and practice to which the finding relates. Basedprimarily on the findings of the technical consultants, the Panel finds that BP’s safety management system does not ensure the timelyimplementation of external good engineering practices that support and could improve process safety performance at BP’s U.S. refineries.> Safety shut-down systemsRefinery process units have important instrumentation systems intended to detect process upsets and then safely shut down equipment priorto reaching unsafe conditions. These systems are usually designed with multiple layers of protection using redundant and highly reliablecomponents. These systems typically remain dormant until an authentic process upset occurs, at which time they act to protect the process byputting it into a safe condition. Because these instrumentation systems are usually dormant, it is difficult to determine at any particular timewhether they are fully functional. As a result, it is important to perform functional testing of these safety systems throughout their operationallives to ensure dependable operation when they are needed.The technical consultants’ report indicates that it is important to consider the entire “life cycle” of a safety system—taking care to properlydesign it, construct it, operate it, and maintain it. In 1996, the Instrumentation, Systems, and Automation Society (ISA) issued an industryconsensus standard to outline the life-cycle care of instrumented safety systems (ISA 84.01-96). OSHA considers ISA 84.01 to be a recognizedand generally accepted good engineering practice under the performance-based requirements of the OSHA process safety managementstandard. ISA published an amended version of this standard in 2004 (ISA 84.01-04).In 2003, BP developed a series of engineering technical practices (ETPs) to provide guidance concerning the application of ISA 84.01. Based onthe technical consultants’ review, none of BP’s U.S. refineries had a comprehensive plan for conforming to ISA 84.01, and only Toledo and CherryProcess Safety Management Systems C 145