HAZOP & gross negilgence
HAZOP & gross negilgence
(OP)
We've had a few discussions on HAZOP topics in the past.
Here's a simple question.
Do HAZOP teams consider the possibility of gross negligence from personnel? Say deliberatley de-activating a safety interlock, or removing some safety barrier, or even - heaven forbid - drunkeness?
Don't want to start a long, in-depth discussion. Just want to know if deliberate unsafe acts, or acts of gross negligence are considered. This is a distinct sub-category of human error.
If they are not considered, why not?
Here's a simple question.
Do HAZOP teams consider the possibility of gross negligence from personnel? Say deliberatley de-activating a safety interlock, or removing some safety barrier, or even - heaven forbid - drunkeness?
Don't want to start a long, in-depth discussion. Just want to know if deliberate unsafe acts, or acts of gross negligence are considered. This is a distinct sub-category of human error.
If they are not considered, why not?
Cheers,
John.





RE: HAZOP & gross negilgence
- Qualified Operating and Maintenance personnel
- Causes based on single failure
- Good operating and maintenance procedures
- Sabotage not considered
So, to come to your question, no, I would normally not consider gross negligence etc., same for terrorist acts etc.
For example, if I have a block valve, I would consider inadvertant opening or closing of the valve. However, if the valve is locked closed, I would not consider inadvertant opening. Of course, if for example a terrorist would want to open that valve it would be easy enough to break the lock... With tools that anyone can buy at the do-it-yourself store, you can cut open any vessel or line as well!
Since you also ask for the reason why not, here are my thoughts about it:
1) HAZOP must be limited somewhat and focus on high risk scenarios. This means focussing on scenarios with a medium to high likelihood and with medium to high severity consequences.
2) Gross negligence, terrorism etc. cannot be stopped by the usual HAZOP recommendations (e.g. add a protection layer, or increase effectiveness of existing protection layers), since these additional layers will be defeated as well
3) Gross negligence, terrorism etc. have to be stopped by other means, such as:
- screening of employees
- plant security/fences
- visitors to be accompanied by plant personnel
etc.
So HAZOP team can assume that here everything will be done that can practicably be done.
4) If you would allow gross negligence, terrorism etc. to be a reasonable cause for a HAZOP, the HAZOP would end nowhere. For almost every node, you would have to investigate things like:
- someone cuts open a vessel containing toxic material with an axe
- operator bypasses instrumented safeguarding and then fully opens control valve to low pressure system
- operator blinds off safety valve and then fully opens control valve to low pressure system
etc. etc. etc.
RE: HAZOP & gross negilgence
Your system should be designed for safety even in the case of gross negligence and deliberate acts given that all of your equipment is properly installed and commissioned; inspected and properly maintained.
Such incidents differ from random equipment failures and acts of god only in the timing.
RE: HAZOP & gross negilgence
HAZOP at www.curryhydrocarbons.ca
RE: HAZOP & gross negilgence
You may very well be right, but it is not an answer to the question asked. Question was whether HAZOP considers gross negligence etc.
Again, my point is that considering gross negligence in HAZOP is normally not done, and it would be impractical to do it. This doesn't mean that companies should not take sufficient measures to protect against it (screening of employees, plant security, etc.).
RE: HAZOP & gross negilgence
Indeed, there should be sufficient safeguards in place to prevent operators to inadvertantly bypass the instrumented safeguarding or blind off a relief valve.
RE: HAZOP & gross negilgence
HAZOP at www.curryhydrocarbons.ca
RE: HAZOP & gross negilgence
Once somebody explained to me an extremely crass and insulting (nevertheless useful!) categorization for employees. All employees are, in the extreme, either smart or stupid, and either hard-working or lazy. The smart+hard working ones are your gems, making you 10x in profit what they cost you in salary etc. The smart+lazy person is less productive but still valuable. The stupid+lazy guy only costs you his salary- but the stupid+hard working guy can cost you your license, your company, or even your life...Employee selection and training- and the willingness to fire the bad ones, is therefore key!
RE: HAZOP & gross negilgence
http://www.cepmagazine.org/pdf/120335.pdf
Article describes use of inherent security principles as a defense against deliberate acts, such as terrorism, sabotage, terrorism or theft.
RE: HAZOP & gross negilgence
since 2 decades I work as a risk consultant for the oil&gas industry and never ever a client or authority requested to include acts of gross negligence into a HAZOP. I agree fully with the arguments of Guidoo that the inclusion of negligence and terrorism is another topic and should be analysed/solved with other suitable tools and methods.
Cheers
Wolfram
RE: HAZOP & gross negilgence
RE: HAZOP & gross negilgence
Good luck,
Latexman
RE: HAZOP & gross negilgence
HAZOP is an absorbing topic. It's not like some strict code, such as the building code or fire code. It seems to me that one HAZOP team may do the job slightly differently to another. That's OK.
The article Guidoo referred to is worth reading. (Thanks, Guidoo) It seems to me that a grossly negligent act can be considered by the HAZOP team, but deliberate, persistent sabotage has to be addressed by other means. The grossly negiligent employee probably only commits a single negligent act and means no harm. The saboteur might commit sevearal acts and has the intention of causing harm.
The article offers common sense precautions against attack, but you can't help but feel it is all futile against determined attackers. For instance, there's a suggestion that valves be padlocked. A boltcutter overcomes that security measure. Can we hide information about petrochem facilities? You can't hide tanks. Pipelines have to be signposted to warn excavators.
The author of the article is Dr Paul Baybutt. My interest in HAZOP started when I saw Dr Baybutt give evidence as an expert witness in a high profile trial relating to a gas plant fire. He argued that HAZOP depends on the quality of the team and you cannot guarantee the outcome.
Made good sense to me. The jury decided otherwise. They decided that a HAZOP would have identified, beyond reasonable doubt, a particular hazard.
The various questions I've asked about HAZOP all arose from that case. Like, how far do you go down the chain of consequences? and do you consider multiple, simultaneous failures?
Cheers,
John.
RE: HAZOP & gross negilgence
Several options exist for revising the question. There are many hazards not addressed by HAZOP. For example, HAZOP is used in most oil, gas, refinery, petrochemical and inorganic chemical processes. HAZOP covers process safety issues. However, the keywords often do not address the hazardous electrical area classification issues. HAZOP may not address area monitoring for combustible gas, toxic gas or flame detection. HAZOP is not likely to address lighting levels. It goes without saying that the specific HAZOP techniques are not ideal to address industrial safety, sobotage or neglegence.
Codes and standards exist to cover many of these safety issues. Laws exist to cover sabotage. However, some of process hazards due to potential errors or sabotage may be addressed by the HAZOP process. For example, an experienced team might notice that a process loop has a startup line that could eliminate cooling thus cause heating which could lead to a process reaction or equipment failure.
The HAZOP results are to CONSIDER potential changes. Usually no directives are made during the HAZOP. With the potential hazard noted, engineers later review the comments and determine the solution that avoids the hazard.
I hope that this adds some clarification to the excellent post by Guidoo and others.
John
RE: HAZOP & gross negilgence
Your post does help, as have all.
It seems to me that HAZOP is a well understood process by those who apply it, although there are differences regarding specific purposes and goals. That seems OK to me.
There is a European Community standard for HAZOP and I don't think it contradicts anything mentioned here.
It's reassuring that there has been no great divide, merely "we do it this way" comments.
How would you like the performance of your HAZOP study to be assessed by a jury?
Cheers,
John.
RE: HAZOP & gross negilgence
Review API 750, Management of Process Hazards for example. This standard recommends the order of process hazard analysis priorities.
For existing facilities the priority sequence follows:
a. High SHI value or large quantities of toxic, flammable, or explosive substances.
b. Proximity to a populous area or a plant location where large numbers of workers are present.
c. Process complexity, including strongly exothermic reactions or secondary reactions.
d. Severe operating conditions, such as high temperatures or pressures, or conditions that cause severe corrosion or erosion.
For a new process or facility, the standard recommends consideration of the following:
a. Previous experience with the process.
b. Design circumstances, such as shorter-than-normal design periods or changes in the design team or the design itself after the project is under way.
Read various process management codes and standards to obtain the flavor of the more common hazard analysis requirements. Assure compliance with 29 CFR 1910.119 (Process Safety Management) if applicable.
Good Luck.
John