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In the UK, operators of hazardous installations have a legal obligation to demonstrate that the risks they present to people and the environment are being managed and are as low as reasonably practicable (ALARP).  Such hazards and risks are typically regulated through the Control of Major Accidents Hazards Regulations 2015 (COMAH), although operational sites which fall outside of COMAH still have this legal obligation.  A key aspect of demonstrating ALARP is to understand what risks are present, what more you could do to reduce the risks and to show compliance with accepted good practice.

Functional safety is a part of overall safety, relating to the process and the basic process control system (BCPS), which depends on the correct functioning of the Safety Instrumented Systems (SIS) and other protection layers. Functional safety work provides an assurance that a SIS gives sufficient risk reduction to meet its required integrity level and offers the necessary protection from an identified hazardous scenario. Consequently, achieving functional safety is an important aspect of the plant’s overall basis of safety and a key requirement of making an ALARP demonstration.

Functional safety is achieved by adopting a lifecycle approach which details all activities pertaining to functional safety, from initial identification of hazards through to specification, design, installation, commissioning, operation, maintenance and change / decommissioning.  The accepted good practice for functional safety is detailed in the British Standards BS EN 61508 (Functional Safety of E / E / PE Safety related systems) and BS EN 61511 Functional Safety – Safety Instrumented Systems for the Process Industry Sector; each describe the safety lifecycle in detail.  In 2017 these documents were updated and included the following key changes:

  • Mandatory requirement for competency assessment
  • Functional Safety Assessment (FSA) Stage 4 and 5 now mandated
  • On-going performance of the SIS to be monitored
  • Introduction of Systematic Capability
  • Requirement for an independent person to perform a Functional Safety Audit
  • Requirement for an impact assessment upon modification of a SIS

Through the COMAH Regulations and review of associated COMAH Safety Reports, the UK Health and Safety Executive will assess the performance of operational sites with respect to functional safety and compliance with accepted good practice.  HFL Consulting can assist clients in all aspects of the SIS safety lifecycle from the development of management systems and assessment of risk through to the design, operation and maintenance phases. By offering an independent view, HFL Consulting will help ensure that sites correctly apply the accepted good practice to engineer plant and processes to a standard which is appropriate for the levels of risk presented.