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LOGICAL SEQUENCE APPROACH TO SAFETY

Introduction:
In any progressive nation the manufacture, processing, handling, storage,
transportation of toxic, flammable, corrosive and explosive chemicals
is a way of life.

But Hi-tech, changes in environmental and social conditions,


community awareness and legislative requirements have brought in a complexity of
factors that make Safety a vital factor to reckon and factor.

Hi-tech:
Modern industries are big and complex. Giant machinery and intricate processes
handle high pressures, high temperatures, corrosive, flammable and toxic
substances. Composition details of many patented materials are well guarded
particularly those covered by Intellectual Property Rights.

Environment:
Environmental factors include ecological pollution and degradation that may
cause community and industrial worker sickness leading to permanent disability and
long-term adverse impact.

Social factors:
Social factors and domestic stress have a direct bearing on a person’s
concentration to err on the job, he/she performs, and can affect safety and quality
of the work turned out.

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Chemical industry:
The small capacity multi-stream plants have yielded way to giant size single
stream units to obtain economy of scale . Compact size plants, new processes ,
high-speed equipment , and microelectronics is the feature of the day. Even though
exotic metals like chrome-nickel, moly-steels, zirconium , titanium and tantalum etc
are being used to combat corrosion , failures due to corrosion, erosion , metal fatigue,
creep failure and such , resulting due to greater stress and strain of the modern plants
has not been fully overcome. These factors further reinforce the essentiality of safety.

Logical Sequence Approach (LSA):


The logical sequence approach is perhaps worth pursuing for safety . In this approach
the risk analysis commences from conception stage of the plant and progresses to
Design stage- material selection–fabrication- inspection- layout-
safe storage , handling , transportation and on to emergency preparedness
planning and disaster management .
Having slotted, LSA helps to focus on to what to look for.

Design:
There are several standards/codes/regulations available for reference such as BIS,
IBR, IPR, IER, ASME, ASTM, API, DIN, JIS, BS, NFPA, NEC, Canadian and many
European standards including AFNOR, UNI and EU directives etc. In general, each
country or economy has a single recognized National Standards Body (NSB). The
advantage of incorporating built –in safety devices at this stage are immense and
should not be viewed an option for cost reasons.

Material selection:
Selection should be compatible to process fluids and plant process parameters.
As mentioned earlier choice of exotic materials facilitate a wide spectrum selection.

Fabrication:
The use of these materials has also created a compelling need for special welding,
fabrication, heat –treatment and weld inspection techniques. Even a minor lapse in
any one of these stages offsets the benefits derived by selection of such costly
materials. Bi –metal/exotic metal welding is another aspect requiring knowledge,
skills and perfection.

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Inspection:
After fabrication, work inspection is to be carried out. Besides in-house inspection,
Statutorily required and recognised third party inspections as are
called for, ensure conformance to the codes. This stage is used for correcting
noted deficiencies if any, instead of rejection and costly rework or failures
subsequently.

Several known inspection methods are adopted like hydrotest, pressure test,
magnetic particle, dye-penetrant, radiography, ultrasonic flaw detection,
metallography and wet fluorescent test, just to cite a few . The importance of the
correctness of the calibration of the measuring instruments reflects on the accuracy of
the readings. Methods should suit specific application needs.

Layout:
Land availability, prohibitive land costs, economic considerations of project
costs(capital outlay), and need for piping compactness have also resulted in
close spacing of hazardous units and storage.
The insistence of plan approvals from statutory authorities and safety certificates
from recognised third parties are motivated by the objective of an independent
scrutiny. Statutory requirements and recommendations should be viewed as a source
of valuable input and advantage is to be gained by the inputs.
Layout should avoid hazard cascade effect. While standards specify minimum
distances, other built-in safety features should be given due importance

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Some Key Statutory Regulations—Indian context
(Illustrative)-- Refer current versions.
Batteries ( Management & Handling ) Rules
Biomedical Waste Rules (Management and Handling)
Central Motor Vehicles Rules
Chemical Accidents (Emergency planning, preparedness & response ) Rules
Declaring coastal stretches under Coastal Regulation Zone (CRZ)
NOC from District Authorities as defined
Environment (Siting for industrial projects) Rules
ESI Act
Factories Act/State Factories Rules
Gas cylinder Rules
Indian Electricity Act / Rules
Indian Petroleum Rules
Static and Mobile Pressure Vessels rules
The Air (Prevention and Control of Pollution) Rules
The Environment (Protection ) Act
The Environment (Protection ) Rules
The Hazardous Waste (Management & Handling) Rules
The Manufacture, storage and import of hazardous chemicals Rules
The Noise pollution ( Regulation & Control ) Rules
The Ozone Depleting substances (regulation & Control) Rules
The Public Liability and Insurance Act
The Public Liability and Insurance Rules

Cross-reference with other codes mentioned under “DESIGN” in partnership with the
process and technology provider is beneficial.

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Safe storage:
It is by intent this part of the subject has been dealt with at this stage of the
handout. The aspects of LSA applicable to plant equipment and process for safe
handling of chemicals is relevant to the storage area and transport Safety as well.

Examples of storage design:


Single wall tank
Double wall tank(cup-in tank)
Double integrity tank
Fixed roof
Floating cum fixed roof
Spheres
Bullets
Rubber lined tanks
Underground tanks
Mounded storage
Deep sea Caverns
The storage design should be compatible to the substance stored and volumes. This is
the primary stage in LSA.

Besides the code referenced earlier. Engineer’s Tank Manual and the booklets
on Health and Safety series from HMSO are useful reference.
Some tanks are insulated and others heated or cooled. Some atmosphere pressure
tanks are mounted direct and in services like anhydrous Ammonia storages the
mounting is on piled pillars to avoid frost heaving by facilitating passage of air
currents.

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Built-in safety-Design safety
At the design stage itself , the built-in features should be integrated . Some of the
factors include.
-filling pipe location (top or bottom filled).
-flow velocity considerations.
-flush mounted on ground or piled pillar mounted.
-flanged , threaded bolted, instantaneous connected , or welded.
-design of vents, drains, overflows pipes, pressure relief, vacuum breaker, spark
arrestor.
-bundwall construction and capacity.
-overflow catchments, safe containment recovery, transfer or safe disposal.
-routing of drains.
-protection against stray currents, static and lightning.
-bonding and grounding connections.
-earthing strips/earth pits.
-pressurised/non-sparking/increased safety/intrinsically safe/flame proof/explosion
proof or other specified special protection electrical wiring, fittings and receptacles.
-excess flow check valves, remote operated valves
-fail-safe instrumentation with redundancy
-structural fireproofing and low smoke fire retardant cables
-fire-cable insulation
-gas –leak detectors, alarms, trips, interlocks.
One has to review to come up with the required design.

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Foundations
Soil test is prime requirement to ensure foundation stabilities. The characteristics to
be analysed are listed below depending on the terrain.
Sample testing
Soil fraction sieve analysis as per IS 460-1962
Liquid limit determination
Natural moisture content determination—as per IS 2720 Part II 1969
Bulk Density as per IS 2720
Triaxial tests as per IS 2720
Consolidation tests
Chemical Analysis
Obtain Foundation recommendation based on the test results validated by a certified
Chartered Civil Engineer.
Civil engineers may insist more

Drains:
Interdependent drains of caustic, acid and hydrocarbon liquids are harmful.
Accidental mix of caustic/acid or hydrocarbon entry into storm water drains is
disastrous. Spillage recovery system and oil/water seperators should be of approved
design.

Overflow:
Similarly volatile liquid storage tanks do not have open overflow while on sulphuric
acid tanks they are not an unusual sight.

Bundwalls:
Bundwall design should ensure minimum ten percent (10%) excess capacity hold upto
the full tank capacity and should be resistant to tank contents. Leaching and seepage
tests are essential.

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Metallurgy for storage tanks:
Metallurgy suitable for one substance need not be for another. While carbon steel is
suitable for concentrated sulphuric acid , some other acids can corrode it
even at low concentrations . Though ammonia at positive temperatures is
transported /stored without additional refrigeration in carbon steel tanks, Ammonia at
–33 degree centigrade requires special steel to avoid low temperature, caustic
embrittlement and creep failures. Dilute sulphuric acid evolves hydrogen with steel
and aqua ammonia can attack brass, copper and gunmetal components.
Contamination with Air (excess oxygen) can promote stress corrosion cracking in
ammonia storages and presence of water can cause solidification and crack failures of
valve bodies and Low temperature (freezing point) in pipelines/ accessories.

Sometimes even air used for passivation of exotic metal liners of reactors
(to retard corrosion) has been known to have contributed to accidents .

Engineering inspection/ Condition monitoring and


Predictive maintenance.
Despite various measures, corrosion is a significant issue. From pitting to external
scaling it can assume many forms. In a typical carbon steel concentrated sulphuric
acid storage tank this can vary as:-
-Uniform corrosion
-Hydrogen grooving
-Horizontal grooving
-Weld corrosion and defects
-Galvanic corrosion- dissimilar metals
-Erosion corrosion
-End-grain attack
-Corrosion of tank internals
-Crevice corrosion etc
Attention spots
Inlet pipes, nozzles, roof, edge of shell plate, shell plate weld seams, between
tank bottoms and foundations, behind reinforcing pads for manholes or nozzles
or behind fillet-welded repair patches are area to watch

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Changes/Condition monitoring
Any modifications or deviation to codes should have the endorsement of plant
Senior Management review team and the Designer.

Condition monitoring by qualified personnel well versed with codes and calibrated
monitoring instruments facilitates identification of problem in advance and,
prevention of catastrophic failures by resort to predictive maintenance.

Following standards are valuable reference.


API/OISD/DIN/JIS/EU/National standards etc

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Operational phase
Basic elements of Pre–commissioning checks should include (Illustrative)
Blinds.
Calibration of instruments and process control devices.
Check for ice-formations under valve seats in low temperature services.
Check of loading arms and transfer hoses for ship to shore transfer, gantries.
Functional checks of electrical instrumentation and failsafe devices.
Functional integrity checks of fire protection system such as pumps, system
components and network.
Functional integrity checks of gas leak sensors and related interlocks, manual fire call
points, manual and emergency fire sirens, plant fire siren, one-touch emergency push
button.
Functional integrity checks of valves, alarms, trips, interlocks, set points.
Gaskets, bolts, nuts, washers, threads
Level gauges
Line blowing, purging, displacement and evacuation procedures
Operational permits introduction
Pipeline tracing checks to ensure continuity
Pressure gauges
Pressure leak tests
Punch list generation for safety items and addressing of any deficiencies
Purge status
SOPs and Special PPE
Valves
Vents, drains, elbows, flanges

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The following Drawings /Documentation /Calculation sheets should be preserved
(Illustrative)
Statutory Approved Layout drawings
Fabrication drawings
Soil Survey reports/Foundation recommendations
Pipelines sectionalised drawing/Isometrics
HAZOP Reports
Load calculation sheets for structurals
Structural stability reports
Pipeline routing drawing
Hazard Area classification drawing
Earthpit layout drawing
Lightning protection coverage drawings

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Post-commissioning phase
General Hazards can also arise from: Causative Factors (Illustrative)
Abnormalities in operation/ initiating event.
Equipment upset condition.
External fire damage.
Failure of pipe due to erosion or corrosion.
Failure of pumps seal.
Failure of fill/transfer lines.
Flange/gasket leaks.
Higher-pressure transfer.
Human error.
Improper procedures.
Improper selection of equipment for hazard classified areas.
Leaks to atmosphere, passing of valves, relief release.
Level/Flow/Temperature Control failures, Bye-pass condition.
Line fracture due line feed to tank being closed, overpressurization.
Line reverse flow protection valves malfunction.
Malfunction /failure of control valve.
Overflow/ spill, leak due to passing valves into collection sump.
Physical impact.
Pumping continues when tank already on high level
Pump seal leak Fire.
Rapid pumping of product causing Static charge build up
Relief valves/rupture discs faulty.
Uncontrolled hot work, maintenance activity/ inactivity.
Unsafe conditions.
Valves in the line closed.
Weather conditions.
Weld failure.
Rapid pump out with vent blocks can cause Storage to buckle.

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Ignition sources may be:
Cutting and welding flames
Electrostatic discharge sparks
Friction heating or sparks
Hot surfaces
Impact sparks
Lightning strikes
Sparks from electrical equipment
Use of cigarettes/matches etc
Warm Surfaces, Flames

Static electricity
Generally Static Electricity is an issue in the following Unit Operations:
Sampling
Pumping
Ullaging
Flange joints

Environmental/Natural
Landslide/Upheaval
Earthquake
Storm/Flood
Subsidence
Lightning

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Consequences and Nature of Fires:
Bulk Storage fires
Pool fire due to rupture and outflow
Flash fire
Jet Fire
Torch Fire
Vent fires
Vapour cloud explosion due to leakage and accumulation
Vapour cloud ignition/explosion, if unburnt
Flash backs
BLEVE (Boiling Liquid Expanding Vapour Explosion)

In case of storage to process equipment routing, the following can be valid.


Containment failure
Instantaneous release
Continuous release
Leaks/overflow
Pipeline leaks
Pump Mechanical seal leak
Fill/transfer lines failure

The release of Hazardous substance can result in any of the following scenarios.
Instantaneous release:
This will occur in case storage tank fails. The source strength is equal to contents of
the capacity of the storage tank.

Continuous release:
In this category, continuous release from process vents and fugitive emissions like
storage tank breather vents are not generally factored.
The gas/vapour otherwise discharged will spread in the surrounding area under the
influence of atmospheric turbulence.

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Broad category of hazard/risk/harm control measures
Layout--Inter distances.
Engineered—Built-in Safeguards.
Operational/instrumentation controls.
Procedural controls.
Fire and emergency combat, control and containment.
Special PPE like Fire proximity suit, Gas tight chemical suit etc.

Explanatory note:
Equipment Controls--- Built-in fail-safe controls
Instrumentation controls—DCS/PLC/SCADA
Temperature/Pressure sensitive reactions merit close attention.
Procedural Controls –SOP, work instructions, checklists, Batch logs etc
Fire protection—Fixed, Portable, Fire classification specific wet networks

Job Safety Analysis:


A comprehensive pre-commission Operational and Safety checklist should be
prepared based on HARA and HAZOP study done.
Developing a plant operation and safety specific checklist using the logical sequence
approach will be beneficial.
The implementation of Job Safety Analysis will facilitate hazard identification and
safe work methods.

Summary of the steps for JSA is reproduced below:


Assess the present job method correctness
Enlarge details
Correct/Eliminate hazard conditions
Introduce Safety Do’s and Don’ts checklist
Issue Work instructions card
Conduct refresher training for change
PDCA--Observe/Correct
Change physical condition /Job procedure, Issue New /revalidated procedure

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Transportation:
The LSA can be put to good use inside the plants. But when the time comes to move
the material from storage to consumer destinations outside the plants after processing,
a variety of different safety issues emerge.

The common mode of transport is road tankers though movement of hazardous


cargo is also done by rail cars and ships . Regulations for the movement of
Dangerous Goods by ships/rail are covered under IMO, IRS, IBC and DGM
regulations

Confining to the topic of movement by road tankers, the ICMA booklet on


“Code For Safe Transportation Of Hazardous Substances By Road” is a good
reference.
Plant checklist should not be limited to, but include:
-Verification of tankers fitness/roadworthiness/licences to haul designated cargo.
-Hazchem labels on panel and Tremcards are available.
-Tanker fitness ensured to avoid incompatible chemical mix.
-Spark arrestors and anti-static chains fitted.
-Approved PPE, fire fighting and first aid equipment carried.
-Wheel chocks available and driver qualified and trained to communicate incidents.
-Basic training imparted to the driver.
-Level gauges, relief valves, vacuum breakers, non-return valves and, excess flow
check valves are in good working condition.
-Tanker master isolation valve fitted and in working order.
-Ladders and platforms are in good condition.
-Unloading hoses are tested and leak tight condition.
-Standard operating procedures detailing sequence of valve operation and safe
recovery of residual vent during hose disconnect and tanker loading is published and
used.
-Safe height venting.
-Loading areas access restricted, and plant safety regulations enforced.
-Tanker entry and exit routes clearly defined and understood by all.
-Portable leak detectors kept handy at site.
-Loading operations or even unloading operations not carried unattended.

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-Public Liability Insurance cover taken by the plant as per requirement.
Contingency Management Plans:
Clearly documented, easily referenced and well-rehearsed spillage and disaster
contingency management plans are to be kept ready for easy access any time to
authorised personnel.

Monitoring and measurement


Evolve a Management SHE Planner calendar (Illustrative)
The calendar items can include:-
Licences status.
Pollution samplings frequency.
Pressure vessel/Lifting appliances checks.
Statutory inspections follow up status.
Internal audit schedule.
Other audits programme.
Electrical audit.
Open issues review.
Earthpit checks.
Lightning protection checks.
Electrical relays checks.
Transformer oil checks.
Environmental audits.
Environment Statement submission.
PM Plan compliance/deviations.
Condition monitoring programmes –Pipelines in a planned and progressive
manner, including the Painting programme.
Non-Destructive tests.
Fire & Safety Equipment inspection status.
Safety committee meeting.
Mock drills.
Training.
Medical examinations.
World/National Safety day/Environment day.
Continual improvement measures, Objective setting based on Key Focus area

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Internal /External audits based on standard templates
Audits well structured and scheduled periodically will enable timely detection of
potential hazards and proactively take preventive actions from incidents emerging.

Illustrative contents of well structured audits


5-Star
AUDIT ELEMENTS:
Safety Organisation:
Policy, Strategy, EHS Training & development, Inspection systems,
Contractors’ safety, Permits system, Internal safety audits, Safety organisation,
Committees, Safety promotional and publicity activities.

Management control systems:


Equipment control systems, Engineered controls/Built-in safety,
Pressure vessels/Lifting appliances, Hazardous material control,
Electrical installation safety, Personal safeguards, Hand & power Tools.

Fire control systems:


System integrity and certification, Proactive fire prevention measures, Emergency
planning, communication and response, Hydrocarbon storage area safeguards.

Measurement control systems:


Reporting systems, Incident investigation procedures, Performance measurement
systems and display

Workplace implementation:
Industrial Hygiene—Lighting, Ventilation, Noise, Heat, Fumes/Vapour Containment,
Housekeeping, Waste Management.

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Process Safety Management: (Code of Federal Regulations 1910-119 USA)
Process safety information
Process hazard analysis
Standard operating procedures
Training
Contractor control
Pre-start up safety review
Mechanical integrity
Non-routine work authorisation
Management of change
Investigation of incidents
Emergency preparedness
Compliance audit
Employee participation
1.

If the Organisation Safety culture is at a stage to adopt Audits under International


Safety Rating System, it enables reference benchmarking

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The elements of OSH: BIS 14489
Occupational Safety and Health Policy
OS & H Organisation set up
Education and training
Employees’ participation
Motivational & promotional measures
Safety Rules & manual
Compliance with statutory requirements
Risk Assessment including hazard identification
Safety inspections
Housekeeping
Machine guarding
Electrical and Personal safeguarding
Ventilation/Illumination/Noise
Environment monitoring
Medical examinations
Safe operating procedures
Work Permits
Fire Prevention/protection/and fire fighting systems
Emergency preparedness plan
Management of change
Transportation of hazardous substances
Waste treatment
Storage area safety
Contractor safety systems
Safety for customers
Accident reporting and analysis
First aid facilities
PPE
Improvement Plans

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Conclusion
It is rather strange but true that the High-risk industry particularly those handling
Toxics, Flammables, Corrosives, Explosives, Radioactive, Biohazard boast of some of
the best-known safety records in relation to the hazard involved. But the performance
is sometimes obscured by adverse publicity, particularly when it involves genuine
community concerns of Safety/Health and Environment.

Reliance on information data banks, in-house and external expertise and applying a
logical approach to incident prevention can only bring cheer.
Despite the risk analysis by any method, incident free operation involving
hazardous substances still remains a challenge.

Safety is an on-going process. Regular audits using standard risk analysis methods
and build up of a Database (MIS-Management Information System) will ensure that,
the quest for betterment is never ending.

Credits:
Statutory regulations
Standards and Codes
Code of Federal Regulations
Publications
Wikipedia
AIChE
Engineers Tank Manual
HMSO
National Safety Councils
Events and occurrences
Best industrial practices
Professional handshakes

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List of abbreviations
AFNOR Association française de normalisation (French Standards)
AIChE American Institute of Chemical Engineers
API American Petroleum Institute
ASME American Society of Mechanical Engineers
ASTM American Society of Testing Materials
BIS Bureau of Indian Standards
BSI British Standards Institution
DCS Distributed Control System
DGR Dangerous Goods Regulations
DIN Deutsches Institut für Normung German Standards
EU European Directives
HARA Hazard Analysis and Risk Assessment
HAZOP Hazard Operability
HMSO Her Majesty’s Stationery Office
IBC International Bulk Cargo
IBR Indian Boiler Regulations
ICMA Indian Chemical Manufacturers Association
IER Indian Electricity Rules
IMO International Maritime Organisation
IPR Indian Petroleum Rules
IS Indian Standards
JISC Japanese Industrial Standards Committee
JSA Job Safety Analysis
LSA Logical Sequence Approach
NEC National Electric Code
NFPA National Fire Protection Association
NOC No Objection Certificate
OISD Oil Industry Safety Directorate
PDCA Plan, Develop, Check and Act
PLC Programme Logic Controllers
PPE Personal Protective Equipment
SCADA Supervisory Control and Data Acquisition
SOP Standard Operating Procedure
UNI Ente Nazionale Italiano di Unificazione (Italian)

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