(82e) Lessons Learned in Auditing Automated Systems for PSM Compliance

The process industry has rapidly adopted automation to improve product quality and production rates, to reduce the potential for operator error, and to decrease manpower requirements. Process industrial automation includes many systems, such as production controls and alarms, safety systems, and mitigation systems. New technology often brings production, product quality, and cost performance benefits. However, new technology also demands more effort and expertise throughout the equipment's installed life. The more programmable electronics that are involved in the equipment's operation, the more prone to systematic flaws the system becomes, which can lead to unpredictable operation. Reliable automation leads to safer operation. Poorly implemented or poorly maintained - automation can lead to significant hazardous events impacting people, the environment, and assets.

A safety instrumented system is a subset of "safety systems" which are covered by OSHA 1910.119 (1). Safety systems are subject to assessment for compliance with specific OSHA process safety management (PSM) requirements, as well as applicable recognized and generally accepted good engineering practices (RAGAGEP). PSM requirements address five general subjects:

- Planning

- Hazard and Risk Analysis

- Design Basis

- Maintenance Procedures

- Operating Procedures

Each subject is presented with references to specific OSHA PSM paragraphs. The highlighted issues and gaps are an amalgam of this author's observations over the last 12 years since ANSI/ISA 84.01-1996 (2) was issued by ISA. If you recognize aspects of your own facility in my observations, consider this confirmation of the reality of what is presented and a challenge for you to overcome.