(84c) Retrofitting New Standards into Existing Facilities Is Not Always as Easy as It Seems

Process Safety related safety standards are often updated, or new standards are developed, following incidents, near misses, or new advances in the safe design of chemical facilities. Whether these new standards should be implemented into existing facilities then becomes an issue that the Process Safety, Engineering and Operating communities need to address. On the surface it would appear that all new safety standards should be applied to existing facilities. However, sometimes the answer is not intuitively obvious because the existing facility may have a very different design approach and design basis to newer facilities producing similar products; therefore it may not be practical, or safe, to blindly introduce new standards into older, existing facilities.

This paper outlines an approach to ensuring that practical operability issues and process safety risks are adequately accounted for when considering the introduction of new standards. Of particular importance are having the issues reviewed by senior Technical and Operations managers' familiar with the design and operation of both the new and the existing facilities.

New engineering standards should not be automatically retroactively applied to existing facilities. During the writing stages of the standard, both Engineering and Operations personnel are actively involved in the standards writing to ensure that practical and safe operation are assured for both new and existing facilities. The final standard may have one design approach for new facilities and several potential approaches for existing facilities depending upon the design. Once the standard has been approved by the writers, it is then subject to review by a Retrofit Standards Committee that ensures that the correct mix of skills was involved in the writing of the standard and that adequate layers of protection are applied to systems that cannot implement new standards because of design or installation differences. This committee requires that the retrofit decision, and any requirements, be considered and be documented during the writing of the standard, taking into account incidents, near misses, etc.