A Total Compliance Approach

How to choose the most effective and cost efficient route to compliance for your plant?

By Wesley O’Shea, Project Manager, Pilz Ireland

Process Safety, Machine Safety, EMC, ATEX and Pressure Equipment are all commonly used buzzwords within the Industrial Safety Community. Depending on the application, the installation and the hazards present, varying approaches and techniques have been developed to cater for the identification of hazards and the reduction of risk posed by plant and equipment. Organisations now have a choice of techniques including Risk Assessment, HAZOP, SIL Determination, Basis of Safety Analysis, Electrical and Mechanical Integrity Reviews etc. along with a range of legislation; Machinery Directives new 2006-42-EC or old 98-37-EC, Process Safety EN 61508 or EN 61511, Safety Category or Safety Integrity Level. How does an organisation choose the most effective and cost efficient route to compliance?

Whether purchasing new plant or equipment, making modifications or upgrades – the target must be ‘Total Compliance’. In trying to achieve total compliance, the customer is faced with the unenviable task of defining all Legislation and Standards applicable to his/her project and then determining how to coherently identify and address all risks across a range of engineering and organisational disciplines.

Traditionally, plant and equipment were defined as either a Machine or a Process and subsequently a Machine Risk Assessment or HAZOP would follow. However the defining line is not so clear and often hazards and compliance requirements were only partially addressed or even missed. The industry is now moving towards Total Compliance via a more holistic approach.

This holistic approach promotes the use of a standalone team with the internal competency to carry out a full Compliance Assessment of the plant/machine/equipment. The Compliance Assessment encompasses, hazard and operability, machine safety, explosion risk, functional safety etc., carried out by a single team, through a single assessment and delivered in a single report. It is easy to imagine the savings achievable by this approach when we consider the potential for reduction in meetings, documentation review cycles, action prioritisation and so on.

To demonstrate this Total Compliance approach we will take the example of a customer in the Pharmaceutical industry. During the planning stages of an upgrade project whereby a batch manufacturing area was due to undergo a full control system retrofit incorporating the purchasing of new auxiliary process equipment, it was decided a Total Compliance Approach was necessary in order to manage the project from both a process safety and machinery safety aspect. The combination of Machine CE Marking, Process Control Hazards, Functional Safety Requirements and Explosion Protection was proving a significant challenge to the plant engineering and EHS departments. The challenge was how to best address all mandatory requirements of relevant legislation in a timely and cost effect manner. The traditional approach of having several teams working on HAZOPs, Machine Risk Assessment, SIL determination and Explosion Protection would have paralysed the project both from a cost and time perspective.

The Total Compliance Assessment team systematically reviewed the plant compliance status in a single assessment. So rather than having a HAZOP, then a Risk Assessment, then a SIL meeting, a single combined assessment covered all areas. The Total Compliance Assessment team analysed E&I drawings, P&IDs, PFDs, Hazardous Area Classifications, Machinery requirements, Safety Critcial Loops and EMC and Noise implications for surrounding personnel and equipment. Following the onsite assessment, a single report was delivered to the customer, this report provided an identification of all risks along with a single prioritised action listing. As a result of this integrated approach, the customer estimated that the duration of this project stage was reduced by approximately 40% with a comparable saving on resource requirements.

As part of our Safety Engineering Services, Pilz offers our ‘Total Compliance Assessment’. This assessment offers our customers a one stop solution for all plant and equipment whether new or old. No longer does the customer need to decide between Machinery Directive or ATEX Directive, between HAZOP or Risk Assessment: Our ‘Total Compliance Assessment’ covers all areas in a combined multidisciplinary approach, Several Areas – One Assessment: Total Compliance.