Managing Documentation for Process Safety Systems and S-84 (ISA 61511) Brazos Section ISA October 10, 2013
Greg Geter, P.E. BSIE - LSU 1992
25 Minutes ● The Vision ○ Ensure system health and compliance through consistent, clean data ● The Rock and the Hard Place ○ Good intentions meet practical limits in day-to- day management ● The Approach ○ Unifying data “islands” into repeatable, auditable reporting ● The Goal – Full Lifecycle Care ○ Complete. Correct. Compliant. **SAFE**
ISA-61511 Requirements ● Identify Hazards ● Assign IPLs ● Engineer IPLs for: ○ specificity ○ independence ○ auditability ○ maintainability ● Implement per Design ● Maintain per Design
Fundamental Challenge ● Lack of information continuity across departmental groups ● Multiple software packages and legacy processes snag and slow communication, verification, and compliance efforts Engineering (SRS) Daily Operation “Are we SIS & compliant?” O Eng’g p s IPL List Inspection, Testing, & PM PSM (PHA & Maint LOPA)
A Day in the Life… ● Typical PHA/LOPA output – 300-600 pages formatted PDF or multiple Excel files in differing formats ● SRS (Safety Requirement Specification) – Word document, 60-80 pages, lots of reference documents, and difficult to maintain, index, or search ● Engineering documents – too numerous to catalog ● Proof tests – Word documents scheduled in third-party software ● And all of this…..
…times 10-15 Units ● Bulky ● Minimal lookup abilities ● Lots of wasted man-hours ● But most importantly… ○ Not tied together ○ Not easily auditable for consistency ○ NOT SUSTAINABLE ● So, software to the rescue, right???
Software? ● YES! But, using what you already Manage- ment have. ○ Simple and single portal: PSM “One stop – Soup to Nuts” ○ Cross-system audits: “The Audit is the Rule” Engr’g ○ Management reporting and executive dashboards: “ Real-time KPIs” . s p O Maint.
The Goal ● Where We Want to Go Manage- ment ○ Plant-wide visibility of PHA data, LOPAs of Record to ensure LOPA consistency PSM ○ IPL lists: SIF, SIS, SRA, and BPCS and Non-Instrumented IPLs (RVs, Mechanical Stops, Flares) Engr’g ○ Centralized IPL Design Information ○ IPL assessment tracking with reporting ○ Maintenance and Operations data . s p O collection ○ Easy to answer “Are We Compliant?” Maint. ○ All in Sync -- All Accounted For
Sounds like Unicorns and Rainbows How Do We Get There?
The Vision ● Single portal or group of reports ● Optimized for search s d e e F ● Live feeds from data islands e v i L ● Flexible and comprehensive Operations EPC/ Projects SIS/ Engineering PSM Maintenance LOPA of Records view Third-party interfaces Summary tables SIL levels, etc. IPL Registry Scheduled test dates IPL checklists SRS tables PHA Pro data Live auditing Status charts Test dates Consistent, repeatable, reportable, and auditable information thread
Technology Choices All have their place, but without proper planning, champion, and disciplines, they will all eventually fail.
Steps to Repeatable Auditing 1.Link Data Islands 1a. PHA, LOPA, & IPL Lists 1b. Engineering & SRS Data 1c. Operations & Maintenance Activities 2.Enforce Naming Conventions 3.Create Appropriate Reports
Step 1 – Link Data Islands ● Two Big Questions: ○ Where is compliance related data? LOPA & ○ What is common PHA across all? IPL List Operate & Maintain Engineering Data
Step 1a – PHA, LOPA, & IPL Lists PHA and LOPA data should be structured in such a way as to allow for easy extraction of IPL and device lists. LOPA, PHA, and IPL List What We Typically See Best Practice PDFs and Word docs Unstructured spreadsheets LOPA and PHA data separate Asset tags in long paragraphs or missing No standards verification
Step 1a – PHA, LOPA, & IPL Lists PHA and LOPA data should be structured in such a way as to allow for easy extraction of IPL and device lists. LOPA, PHA, and IPL List What We Typically See Best Practice PDFs and Word docs Structured spreadsheets Unstructured spreadsheets Commercial PHA tools LOPA and PHA data Dedicated Asset Tag columns separate Export to Word/PDF Asset tags in long paragraphs or missing Database style, standards- driven process No standards verification Checklists for verifying IPL compliance during study
What Does It Look Like? PHA and LOPA are structured to easily mine asset information and create IPL Lists. LOPA, PHA, and IPL List
Step 1b – Engineering & SRS Data Design reports that read from all applications that store engineering data for consistency – The Audit is the Master. Engineering Data What We Typically See Best Practice A system for every discipline Paper and spreadsheets Inconsistent tagging Where’s the SRS data?
Step 1b – Engineering & SRS Data Design reports that read from all applications that store engineering data for consistency – The Audit is the Master. Engineering Data What We Typically See Best Practice A system for every discipline Systems consistent in tagging Paper and spreadsheets SRS data clearly documented Inconsistent tagging Data exportable in structured format Where’s the SRS data?
Structured Data & Consistent Tags Goals: Easy to Export and Easy to Verify ● Why are we still accepting PDF and Word docs for SRSs? ● SRS can be executed in Excel or database with tables and fields ● Do a mail merge to Word if it needs to be fancy! ● What better way to know you’re done and compliant? ● Plenty of commercial tools for this
What Does It Look Like? Maintain links to LOPA through Asset tags and structurally describe underlying devices. Engineering Data
Step 1c – Operate, Maintain, and Proven in Use Statistics Support Feed Operations & Maintenance Systems with authoritative lists from your new streamlined process. Ops & Maint PIU Stats What We Typically See Best Practice Paper-based systems Inconsistent tagging Older legacy systems Incomplete SAP implementations
Step 1c – Operate, Maintain, and Proven in Use Statistics Support Feed Operations & Maintenance Systems with authoritative lists from your new streamlined process. Ops & Maint PIU Stats What We Typically See Best Practice Paper-based systems Systems consistent in tagging Inconsistent tagging SRS data clearly Older legacy systems documented Incomplete SAP Data exportable in implementations structured format
Linking It All Together Links through asset and instrument tags and device serial numbers allow for easy audit of entire information stream. Ops & Maint PIU Stats
When Links Go Bad Audit process will quickly show data that has no ! “home”.
Step 2 – Enforce Naming Conventions ● Garbage in, garbage out ● Critical for consistency and auditability LT-101 Lev. Trans on J-101 LT101
Step 3 – Measure Team Performance on Audit Report Results ● Clean audits ○ Reduce risks, Cost effective, Repeatable ● Examples of questions that are easy to answer when clean data audits exist: ○ Does the LOPA IPL list match engineering IPL list and “critical” flag in INtools? ○ Has ops scheduled maintenance work orders in SAP per test intervals specified in the SRS? ○ How many safety critical devices failed inspection last month? ○ How many BPCS loops are credited in IPLs plantwide?
Fancy or Plain, Audit Reports Tie Everything Together
Easy to Say – Next Steps? ● The Good News ○ No need to replace well-functioning processes or data management systems ○ Tools to accomplish these things are at-hand ○ Off-the-shelf tools exist ● The Challenge ○ All functional areas must understand the cultural change of data audit enforcement ○ Cleanup, mapping data, and writing audit reports can be daunting
Easy to Say – Next Steps? ● The Reward ○ Increased compliance oversight ○ Reduction in risk exposure ○ Clean data is addictive!
Conclusion ● Data islands slow down the ability to verify compliance, so: ○ Establish consistency between systems ○ Identify compliance data in each ○ Write audit reports to enforce syncing of data across systems ○ Develop reports and exports to easily answer compliance questions
Questions?
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