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KEY PRINCIPLES
ESSENTIAL
FEATURES
WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW
Ensure Consistent
Implementation
1. Create a written policy governing the knowledge element.
Develop and widely distribute a simple index
that clarifies accountability for maintaining
process knowledge.
2. Specify in the written policy the scope of the knowledge
element, including the various types of information and
documentation that should be created/compiled for each unit at
the facility.
3. Compile chemical hazard information, process technology
information, and process equipment information
4. Include in the written policy governing the knowledge element
what process knowledge is needed as a function of the life cycle
of a process.
Usecentral technical groups to develop and
maintain process knowledge.
Thoroughly
Document Chemical
Reactivity and
Incompatibility
Hazards
5. Include in the written policy governing the knowledge element
a specific standard for documen- tation of chemical
Document saje conditions!features that are
incorporated into the design of the process
• Review audit results to determine if any
significant gaps were identified.
Extend the process knowledge to encompass
information needed for efficient operation
Make Information
Available and
Provide Structure
See the corresponding work activities for the cornpetency
element (Section 5.3.2).
Implement a centralized database for process
knowledge.
7. File documents by equipment or type of information rather
than by capital project number, change authorization number,
date, project leader's name, an so forth.
Develop a standard template or set of forms
for recording process knowledge
8. Seek to eliminate parallel copies of process knowledge,
particularly if they are not sanctioned as part of the knowledge
element.
Createpartially completed forms or
databasesfor process knowledge.
Store Calculations,
Design Data, and
Similar Information
in Central Files
9. Retain the calculations and data that support the process
knowledge.
Create partially completed forms or
databasesfor process knowledge.
10. Develop standards for analysis methods, symbols,
terminology, and software.
Include specifications for delivery of process
knowledge in the scope of work for new capital
projects.
Provide contextfor process knowledge.
Reduce demand on engineering resourcesfor
troubleshooting, plant turnarounds, and minor
capital projects.
12. If a company policy or regulation requires a particular type
of process knowledge that does not apply toa specific unit or
process, clearly document that it does not apply and why it does
not apply.
Create company- orfacility-specific safety data
sheets.
Control or Limit
Access to Out-of-
Date Documents
13. Implementa means to control!limit access to out-of-date
process knowledge .
• Accuracy of process knowledge during periodic reviews.
14. Periodically review the accuracy of process knowledge.
• Number of times during audits or assessments that
process knowledge (or duplicate copies of reports, etc.)
must be retrieved from personal files.
15. Periodically assess the adequacy of process knowledge, and
gather new information when needed or request new information
from the competency element.
• Number of change requests initiated to ''correct"
process knowledge
Protect Against
lnadvertent Change
16. Assign persons with proper knowledge and experience to
review and approve corrections or changes to process
knowledge.
• Engineering staff time spent recreating process
knowledge.
17. Survey the organization periodically to determine if different
departments have established redundant file systems for
knowledge.
• Backlog of change requests related to completing
updates to process knowledge.
18. Maintain a protected archive of the process knowledge at a
separate facility and update the archive file on a regular basis.
• Results of random checks of process knowledge files
after change requests are closed.
19. Ensure that designers and other persons assigned to compile
and maintain information under- stand the definition of a
"change" and the scope of the management of change element.
• Average number of days required to have a drawing
revised.
• Ratio of approved change requests (involving equipment
changes) to updates to P&IDs.
• Results of periodic opinion surveys to determine if users
of process knowledge believe that it is
current and accurate.
21. Implementa means to check out copies of process
knowledge for revision.
• Results of random checks of MSDS files to determine if
they are complete, current, and accurate.
Ensure Awareness
22. Determine if employees who need to use process knowledge
thoroughly understand how to use it and how to interpret data it
contains. If gaps exist, provide suitable training.
Ensure that Process
Knowledge Remains
Useful
23. Assess whether the information is adequate to meet the
needs of the risk element and other
RBPS elements at each point in the unit's lije cycle.
• Review the facility's policy for the knowledge
element to ensure that roles and
responsibilities have been assigned. Is a
particular person, by name or job title,
responsible for maintaining each aspect of the
process knowledge?
• If any relevant projects are under way at the
time of the review, such as conversion from a
paper- based system toan electronic storage
system, determine if the project is going as
planned . If not, identify possible roadblocks
that could be cleared by management.
• Survey the organization to determine if any
effort exists to maintain part of the process
knowledge or closely related information in an
unofficial system.
• Review how archived (out-of-date)
documents are stored.
• Review the means used to protect process
knowledge from loss or inadvertent change.
• Interview relatively new employees to
determine if they can navigate their way
through the process knowledge that pertains
to their job duties.
• If a policy is in place to review process
knowledge prior to a risk analysis, develop a
"process knowledge report card" for the as-
found condition (i.e., number and type of
corrections required).
Assign
Responsibilities to
Competent
Personnel
6. Ensure that competent personnel are responsible for (1)
maintaining current and accurate process knowledge and (2)
reviewing changes to the process knowledge.
• The number or percent of blank records in the process
knowledge database.
• Number of PHA team recommendations that include an
indication ofless than adequate process knowledge where
the information was not available.
• Number of incident investigations that include an
element of discovery
• Is the information needed to properly
manage risk and safely operate the facility well
documented and widely understood?
• Determine how much effort has been applied
to updating existing process knowledge.
• Determine how much effort has been applied
to developing new process knowledge.
• Determine how much engineering effort is
being spent recreating lost or misplaced
information.
• Sample sorne of the data repositories, such
as drawing files, MSDS files, or equipment
records, to determine if the data exist and
appear to be current and accurate.
Electronically link the knowledge and
management of change elements.
Treat mismanagement of process knowledge
as a near miss incident.
• Frequency that process knowledge is accessed.
Fully integrate maintenance of process
knowledge into day-to-day activities.
• Is it likely that facility personnel can locate
current and accurate information that
collectively makes up the process knowledge in
a timely manner?
• Is this information accurate?
U N D E R S T A N D H A Z A R D S A N D R I S K
Ensure Accuracy
Protect Against
Physical (or
Electronic) Removal
or Misfiling
Support Efforts to
Properly Manage
Change
20. Provide a means to ensure the fidelity of process knowledge
and prevent unauthorized changes that would corrupt the
information.
8.3.3ProtectandUpdatetheProcessKnowledge
8.3.4Use
Process
Knowledge
6- P R O C E S S K N O W L E D G E M A N A G E M E N T
Make the process knowledge management
element the hub for all process knowledge.
Develop a centralized infrastructure.
Protect Knowledge
from Inadvertent
Loss
Document
Information in a
User-Friendly
Manner
11. Use tables or other highly structured methods to summarize
results and/or point to the location in the facility's files where
process knowledge can be found.
• Ifprocess knowledge is web-based, the number
orpercent of dead links.
• Number of instances in which maintenance planners or
purchasing agents cannot locate specifi- cations or similar
data.
• Results of periodic surveys to determine if users of
process knowledge believe it is accessible.
• Number of PHA team recommendations that include an
indication ofless than adequate process knowledge where
the information actually was available.
Define the Scope
6- P R O C E S S K N O W L E D G E M A N A G E M E N T
6-PROCESSKNOWLEDGEMANAGEMENT
6-PROCESSKNOWLEDGEMANAGEMENT
8.3.1MaintainaDependablePractice8.3.2CatalogProcessKnowledgeinaMannerthatFacilitatesRetrieval
KEY PRINCIPLES
ESSENTIAL
FEATURES
WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW
Document the
lntended Risk
Management System
1. Establish and implement formal procedures to manage risk. Use standard documentation forms.
2. Determine when HIRAs should be performed Use standard checklists.
3. Specify the allowable time before the risk assessment of an
operating process is revalidated in the
risk system.
Provide model studies.
4. Determine the types and severity of consequences to be
addressed in the program,
5. Determine the process systems and chemicals to be
addressed in the program.
6. Determine the mínimum objectives of each required analysis.
Determine the
Physical Scope of
the Risk System
7. Develop a list of units and activities to which the risk system
applies.
8. Define the roles and responsibilities for risk activities.
9. Assign a job function as the owner of the risk system to
monitor its effectiveness on a routine basis.
10. Provide awareness training on the risk system to all affected
employees and contractors.
11. Provide detailed training to all employees and contractors
who are assigned specific roles within the risk system.
12. Define the basis for judging risks and risk tolerance.
13. Address the criteria for selecting risk control measures in the
HIRA procedure.
14. Maintain current risk tolerance criteria.
15. Keep a running status of all HIRA reviews.
16. Establish risk performance and efficiency metrics.
17. Provide input to interna! audits of risk practices based upon
the HIRA performance metrics.
Gather and Use
Appropriate Data to
Identify Hazards and
Evaluate Risks
18. Consider all of the types of information necessary to properly
evaluate risks within the scope of the risk element.
Audit RBPS elements during HIRA preparation.
19. Use appropriate HIRA methods.
20. Specify (1) issues that must be addressed in a review
regardless oftechnique used and (2) quality parameters for
review results.
21. Specify the qualifications for participating in HIRAs.
22. Provide a description of necessary disciplines needed on a
HIRA review team for each type of analysis.
23. Use qualified leaders.
Include team members from otherfacilities
tofoster cross-learning.
24. Train team leaders and participants in the use of risk
tolerance criteria.
Conduct virtual meetings.
• Verify that HIRA forms are being properly
completed.
25. Conduct HIRAs at an appropriate level of rigor
commensurate with the level of detail that is available for the
process life cycle stage.
Select analysis methods based on hazards and
potential consequences.
26. Address the appropriate technical risk issues based on the
available information at that stage of the process life cycle.
Limit discussions to analysis scope and
threshold severity
27. Address inherent safety issues in an appropriate fashion
considering the stage of the process life cycle.
Automate parts of the analysis.
28. Document the hazards, risks, and recommendations from
the analysis in a formal report.
29. Document the risk control measures.
• Percentage of recommendations for administrative
controls, active engineered controls, passive engineered
controls, and inherently safer alternatives.
Manage analysis depth based on risk ranking.
• Ratio of actuallosses to risk tolerance criteria.
• Number of recommendations per study or per year.
Select Appropriate
Risk Control
Measures
31. Define preferred risk controls. • Number of recommendations per revalidation.
the standards that were applied.
Review all high consequence scenarios.
Communicate
Important Results to
Management
32. Inform management of the risks identified and the
recommendations for risk reduction.
• Number of recommendations unresolved by their due
date.
Document the
Residual Risk
33. Document the residual risk for each operation, unit, and
facility.
• Percentage of repeat recommendations.
Resolve
Recommendations
and Track
Completion of
Actions
34. Address HIRA recommendations and document their
resolution, including specific actions that address the
recommendations. Prioritize actions based on risk and benefit.
• Average time corrective actions require for completion.
Communicate
Results lnternally
35. Communicate risks to potentially affected personnel,
including contractors.
• Percentage of recommendations rejected by
management.
• Management exceptions to risk criteria (accepting
higher risk).
• Investigate any serious incidents in units
that were considered low risk.
• Residual risks.
Maintain Risk
Assessment Records
37. Archive the HIRA results, along with key materials and
information used by reviewers.
• Internal!external risk communications.
• Determine whether recommendations are
made for every scenario with an unacceptable
risk score and for most scenarios that are
marginally tolerable.
• Determine whether the risk judgments by
different teams, areas, and departments are
consistent with the risk tolerance guidelines
and each other.
• Determine whether risk studies are unduly
optimistic in claiming credit for engineered
controls that are not included in the asset
integrity program.
• Determine whether risk studies incorrectly
list failures of protective systems as causes of
the upsets they protect against, for example,
failure of the firewater system as the cause of
a fire.
• Determine whether the latest versions of
applicable resources (e.g., checklists, report
templates) are being used.
• Review the HIRAs scheduled for current
processes or projects to determine whether
they are appropriate for their stage in the life
cycle.
• Review the amount of overtime required for
team resources to participate in the HIRAs.
• Verify that the knowledge element is up to
date for scheduled analyses.
• Verify that adequate resources, including
appropriate subject matter experts, are
available for upcoming HIRAs.
• Investigate any unexpected delays in
starting scheduled HIRAs, and determine
whether delays were caused by a lack of
information , a lack of leadership or expert
resources, or poor planning.
• Verify that the actual losses, as tracked
through the incidents element, are consistent
with the HIRA predictions and corporate risk
tolerance criteria.
• Investigate whether incidents have occurred
that were not anticipated in HIRAs, or if
anticipated, whether the controls were
inadequate.
• Investigate any audit findings of risk
program deficiencies and determine whether
corrective actions have been implemented.
• Determine whether the resolution activities
of any recommendations are overdue or have
been repeatedly rescheduled.
• Verify that recommendations are being
resolved in a timely manner, particularly for
simple recommendations, such as adding a
caution statement to a procedure.
• Investigate any long delays between the end
of analysis meetings and the issuance of the
report.
Consolidate small studies.
Develop and use HIRA subject matter experts
(SMEs).
Provide appropriate team composition.
Provide administrative support to document
HIRAs.
Diversify analysis methods.
• Considering the pool of qualified leaders and
team members, investigate whether only a few
individuals are actually participating in the
• Verify that the scope of the HIRAs is broad
enough to capture the full range of risks.
• Determine whether HIRA methods are being
selected based on the risk of units and
activities.
Use an independent risk study leader.
Expand the analysis scope to include economic
impacts
Review previous incidents.
• HIRA resource demand and team efficiency.
Define and enforce stage gatesfor projects.
Train designers in process safety principies.
Apply the Risk
Tolerance Criteria
30. Address the options that teams have in making decisions in
the HIRA procedure.
Communicate the
Results Externally
36. Inform stakeholders, including emergency management
agencies, of the hazards and risks identified, the
recommendations for risk reduction, and the residual risks.
Ensure that HIRA
Participants Have
Appropriate
Expertise
lntegrate HIRA
Activities into the
Life Cycle of Projects
or Processes
Clearly Define the
Analytical Scope of
HIRAs and Ensure
Adequate Coverage
Involve Competent
Personnel
Make Consistent
Risk Judgments
Verify that Risk
Practices Remain
Effective
U N D E R S T A N D H A Z A R D S A N D R I S K
Compliance with standards instead of
independent analyses.
Consolidate and automate corrective action
tracking.
Prioritize corrective actions based on risk.
Maintain current HIRAs.
9.3.3AssessRisks
andMakeRisk-
basedDecisions
9.3.4FollowThroughonAssessment
Results
7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S
Perform HIRA
Activities to the
Appropriate Level of
Technical Rigor
Commensurate with
the Life Cycle Stage
and the Available
Process Information
Prepare a Thorough
HIRA Report
• Number of qualified HIRA leaders, scribes, and
participants.
• Number of audit findings.
• Percentage of intended revalidations that require the
study to be completely redone
• Number of HIRAs of each type that are overdue.
Select Appropriate
HIRA Methods
• Technique used
• Time required to issue a HIRA report.
• Number ofHIRAs of each type scheduled.
7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S
7-HAZARDIDENTIFICATIONANDRISKANALYSIS
7-HAZARDIDENTIFICATIONANDRISKANALYSIS
9.3.1MaintainaDependablePractice9.3.2IdentifyHazardsandEvaluateRisks

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PSM RM - Understand hazards and risk

  • 1. KEY PRINCIPLES ESSENTIAL FEATURES WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW Ensure Consistent Implementation 1. Create a written policy governing the knowledge element. Develop and widely distribute a simple index that clarifies accountability for maintaining process knowledge. 2. Specify in the written policy the scope of the knowledge element, including the various types of information and documentation that should be created/compiled for each unit at the facility. 3. Compile chemical hazard information, process technology information, and process equipment information 4. Include in the written policy governing the knowledge element what process knowledge is needed as a function of the life cycle of a process. Usecentral technical groups to develop and maintain process knowledge. Thoroughly Document Chemical Reactivity and Incompatibility Hazards 5. Include in the written policy governing the knowledge element a specific standard for documen- tation of chemical Document saje conditions!features that are incorporated into the design of the process • Review audit results to determine if any significant gaps were identified. Extend the process knowledge to encompass information needed for efficient operation Make Information Available and Provide Structure See the corresponding work activities for the cornpetency element (Section 5.3.2). Implement a centralized database for process knowledge. 7. File documents by equipment or type of information rather than by capital project number, change authorization number, date, project leader's name, an so forth. Develop a standard template or set of forms for recording process knowledge 8. Seek to eliminate parallel copies of process knowledge, particularly if they are not sanctioned as part of the knowledge element. Createpartially completed forms or databasesfor process knowledge. Store Calculations, Design Data, and Similar Information in Central Files 9. Retain the calculations and data that support the process knowledge. Create partially completed forms or databasesfor process knowledge. 10. Develop standards for analysis methods, symbols, terminology, and software. Include specifications for delivery of process knowledge in the scope of work for new capital projects. Provide contextfor process knowledge. Reduce demand on engineering resourcesfor troubleshooting, plant turnarounds, and minor capital projects. 12. If a company policy or regulation requires a particular type of process knowledge that does not apply toa specific unit or process, clearly document that it does not apply and why it does not apply. Create company- orfacility-specific safety data sheets. Control or Limit Access to Out-of- Date Documents 13. Implementa means to control!limit access to out-of-date process knowledge . • Accuracy of process knowledge during periodic reviews. 14. Periodically review the accuracy of process knowledge. • Number of times during audits or assessments that process knowledge (or duplicate copies of reports, etc.) must be retrieved from personal files. 15. Periodically assess the adequacy of process knowledge, and gather new information when needed or request new information from the competency element. • Number of change requests initiated to ''correct" process knowledge Protect Against lnadvertent Change 16. Assign persons with proper knowledge and experience to review and approve corrections or changes to process knowledge. • Engineering staff time spent recreating process knowledge. 17. Survey the organization periodically to determine if different departments have established redundant file systems for knowledge. • Backlog of change requests related to completing updates to process knowledge. 18. Maintain a protected archive of the process knowledge at a separate facility and update the archive file on a regular basis. • Results of random checks of process knowledge files after change requests are closed. 19. Ensure that designers and other persons assigned to compile and maintain information under- stand the definition of a "change" and the scope of the management of change element. • Average number of days required to have a drawing revised. • Ratio of approved change requests (involving equipment changes) to updates to P&IDs. • Results of periodic opinion surveys to determine if users of process knowledge believe that it is current and accurate. 21. Implementa means to check out copies of process knowledge for revision. • Results of random checks of MSDS files to determine if they are complete, current, and accurate. Ensure Awareness 22. Determine if employees who need to use process knowledge thoroughly understand how to use it and how to interpret data it contains. If gaps exist, provide suitable training. Ensure that Process Knowledge Remains Useful 23. Assess whether the information is adequate to meet the needs of the risk element and other RBPS elements at each point in the unit's lije cycle. • Review the facility's policy for the knowledge element to ensure that roles and responsibilities have been assigned. Is a particular person, by name or job title, responsible for maintaining each aspect of the process knowledge? • If any relevant projects are under way at the time of the review, such as conversion from a paper- based system toan electronic storage system, determine if the project is going as planned . If not, identify possible roadblocks that could be cleared by management. • Survey the organization to determine if any effort exists to maintain part of the process knowledge or closely related information in an unofficial system. • Review how archived (out-of-date) documents are stored. • Review the means used to protect process knowledge from loss or inadvertent change. • Interview relatively new employees to determine if they can navigate their way through the process knowledge that pertains to their job duties. • If a policy is in place to review process knowledge prior to a risk analysis, develop a "process knowledge report card" for the as- found condition (i.e., number and type of corrections required). Assign Responsibilities to Competent Personnel 6. Ensure that competent personnel are responsible for (1) maintaining current and accurate process knowledge and (2) reviewing changes to the process knowledge. • The number or percent of blank records in the process knowledge database. • Number of PHA team recommendations that include an indication ofless than adequate process knowledge where the information was not available. • Number of incident investigations that include an element of discovery • Is the information needed to properly manage risk and safely operate the facility well documented and widely understood? • Determine how much effort has been applied to updating existing process knowledge. • Determine how much effort has been applied to developing new process knowledge. • Determine how much engineering effort is being spent recreating lost or misplaced information. • Sample sorne of the data repositories, such as drawing files, MSDS files, or equipment records, to determine if the data exist and appear to be current and accurate. Electronically link the knowledge and management of change elements. Treat mismanagement of process knowledge as a near miss incident. • Frequency that process knowledge is accessed. Fully integrate maintenance of process knowledge into day-to-day activities. • Is it likely that facility personnel can locate current and accurate information that collectively makes up the process knowledge in a timely manner? • Is this information accurate? U N D E R S T A N D H A Z A R D S A N D R I S K Ensure Accuracy Protect Against Physical (or Electronic) Removal or Misfiling Support Efforts to Properly Manage Change 20. Provide a means to ensure the fidelity of process knowledge and prevent unauthorized changes that would corrupt the information. 8.3.3ProtectandUpdatetheProcessKnowledge 8.3.4Use Process Knowledge 6- P R O C E S S K N O W L E D G E M A N A G E M E N T Make the process knowledge management element the hub for all process knowledge. Develop a centralized infrastructure. Protect Knowledge from Inadvertent Loss Document Information in a User-Friendly Manner 11. Use tables or other highly structured methods to summarize results and/or point to the location in the facility's files where process knowledge can be found. • Ifprocess knowledge is web-based, the number orpercent of dead links. • Number of instances in which maintenance planners or purchasing agents cannot locate specifi- cations or similar data. • Results of periodic surveys to determine if users of process knowledge believe it is accessible. • Number of PHA team recommendations that include an indication ofless than adequate process knowledge where the information actually was available. Define the Scope 6- P R O C E S S K N O W L E D G E M A N A G E M E N T 6-PROCESSKNOWLEDGEMANAGEMENT 6-PROCESSKNOWLEDGEMANAGEMENT 8.3.1MaintainaDependablePractice8.3.2CatalogProcessKnowledgeinaMannerthatFacilitatesRetrieval
  • 2. KEY PRINCIPLES ESSENTIAL FEATURES WORK ACTIVITIES ELEMENT METRICS WAYS TO IMPROVE EFFECTIVENESS MANAGEMENT REVIEW Document the lntended Risk Management System 1. Establish and implement formal procedures to manage risk. Use standard documentation forms. 2. Determine when HIRAs should be performed Use standard checklists. 3. Specify the allowable time before the risk assessment of an operating process is revalidated in the risk system. Provide model studies. 4. Determine the types and severity of consequences to be addressed in the program, 5. Determine the process systems and chemicals to be addressed in the program. 6. Determine the mínimum objectives of each required analysis. Determine the Physical Scope of the Risk System 7. Develop a list of units and activities to which the risk system applies. 8. Define the roles and responsibilities for risk activities. 9. Assign a job function as the owner of the risk system to monitor its effectiveness on a routine basis. 10. Provide awareness training on the risk system to all affected employees and contractors. 11. Provide detailed training to all employees and contractors who are assigned specific roles within the risk system. 12. Define the basis for judging risks and risk tolerance. 13. Address the criteria for selecting risk control measures in the HIRA procedure. 14. Maintain current risk tolerance criteria. 15. Keep a running status of all HIRA reviews. 16. Establish risk performance and efficiency metrics. 17. Provide input to interna! audits of risk practices based upon the HIRA performance metrics. Gather and Use Appropriate Data to Identify Hazards and Evaluate Risks 18. Consider all of the types of information necessary to properly evaluate risks within the scope of the risk element. Audit RBPS elements during HIRA preparation. 19. Use appropriate HIRA methods. 20. Specify (1) issues that must be addressed in a review regardless oftechnique used and (2) quality parameters for review results. 21. Specify the qualifications for participating in HIRAs. 22. Provide a description of necessary disciplines needed on a HIRA review team for each type of analysis. 23. Use qualified leaders. Include team members from otherfacilities tofoster cross-learning. 24. Train team leaders and participants in the use of risk tolerance criteria. Conduct virtual meetings. • Verify that HIRA forms are being properly completed. 25. Conduct HIRAs at an appropriate level of rigor commensurate with the level of detail that is available for the process life cycle stage. Select analysis methods based on hazards and potential consequences. 26. Address the appropriate technical risk issues based on the available information at that stage of the process life cycle. Limit discussions to analysis scope and threshold severity 27. Address inherent safety issues in an appropriate fashion considering the stage of the process life cycle. Automate parts of the analysis. 28. Document the hazards, risks, and recommendations from the analysis in a formal report. 29. Document the risk control measures. • Percentage of recommendations for administrative controls, active engineered controls, passive engineered controls, and inherently safer alternatives. Manage analysis depth based on risk ranking. • Ratio of actuallosses to risk tolerance criteria. • Number of recommendations per study or per year. Select Appropriate Risk Control Measures 31. Define preferred risk controls. • Number of recommendations per revalidation. the standards that were applied. Review all high consequence scenarios. Communicate Important Results to Management 32. Inform management of the risks identified and the recommendations for risk reduction. • Number of recommendations unresolved by their due date. Document the Residual Risk 33. Document the residual risk for each operation, unit, and facility. • Percentage of repeat recommendations. Resolve Recommendations and Track Completion of Actions 34. Address HIRA recommendations and document their resolution, including specific actions that address the recommendations. Prioritize actions based on risk and benefit. • Average time corrective actions require for completion. Communicate Results lnternally 35. Communicate risks to potentially affected personnel, including contractors. • Percentage of recommendations rejected by management. • Management exceptions to risk criteria (accepting higher risk). • Investigate any serious incidents in units that were considered low risk. • Residual risks. Maintain Risk Assessment Records 37. Archive the HIRA results, along with key materials and information used by reviewers. • Internal!external risk communications. • Determine whether recommendations are made for every scenario with an unacceptable risk score and for most scenarios that are marginally tolerable. • Determine whether the risk judgments by different teams, areas, and departments are consistent with the risk tolerance guidelines and each other. • Determine whether risk studies are unduly optimistic in claiming credit for engineered controls that are not included in the asset integrity program. • Determine whether risk studies incorrectly list failures of protective systems as causes of the upsets they protect against, for example, failure of the firewater system as the cause of a fire. • Determine whether the latest versions of applicable resources (e.g., checklists, report templates) are being used. • Review the HIRAs scheduled for current processes or projects to determine whether they are appropriate for their stage in the life cycle. • Review the amount of overtime required for team resources to participate in the HIRAs. • Verify that the knowledge element is up to date for scheduled analyses. • Verify that adequate resources, including appropriate subject matter experts, are available for upcoming HIRAs. • Investigate any unexpected delays in starting scheduled HIRAs, and determine whether delays were caused by a lack of information , a lack of leadership or expert resources, or poor planning. • Verify that the actual losses, as tracked through the incidents element, are consistent with the HIRA predictions and corporate risk tolerance criteria. • Investigate whether incidents have occurred that were not anticipated in HIRAs, or if anticipated, whether the controls were inadequate. • Investigate any audit findings of risk program deficiencies and determine whether corrective actions have been implemented. • Determine whether the resolution activities of any recommendations are overdue or have been repeatedly rescheduled. • Verify that recommendations are being resolved in a timely manner, particularly for simple recommendations, such as adding a caution statement to a procedure. • Investigate any long delays between the end of analysis meetings and the issuance of the report. Consolidate small studies. Develop and use HIRA subject matter experts (SMEs). Provide appropriate team composition. Provide administrative support to document HIRAs. Diversify analysis methods. • Considering the pool of qualified leaders and team members, investigate whether only a few individuals are actually participating in the • Verify that the scope of the HIRAs is broad enough to capture the full range of risks. • Determine whether HIRA methods are being selected based on the risk of units and activities. Use an independent risk study leader. Expand the analysis scope to include economic impacts Review previous incidents. • HIRA resource demand and team efficiency. Define and enforce stage gatesfor projects. Train designers in process safety principies. Apply the Risk Tolerance Criteria 30. Address the options that teams have in making decisions in the HIRA procedure. Communicate the Results Externally 36. Inform stakeholders, including emergency management agencies, of the hazards and risks identified, the recommendations for risk reduction, and the residual risks. Ensure that HIRA Participants Have Appropriate Expertise lntegrate HIRA Activities into the Life Cycle of Projects or Processes Clearly Define the Analytical Scope of HIRAs and Ensure Adequate Coverage Involve Competent Personnel Make Consistent Risk Judgments Verify that Risk Practices Remain Effective U N D E R S T A N D H A Z A R D S A N D R I S K Compliance with standards instead of independent analyses. Consolidate and automate corrective action tracking. Prioritize corrective actions based on risk. Maintain current HIRAs. 9.3.3AssessRisks andMakeRisk- basedDecisions 9.3.4FollowThroughonAssessment Results 7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S Perform HIRA Activities to the Appropriate Level of Technical Rigor Commensurate with the Life Cycle Stage and the Available Process Information Prepare a Thorough HIRA Report • Number of qualified HIRA leaders, scribes, and participants. • Number of audit findings. • Percentage of intended revalidations that require the study to be completely redone • Number of HIRAs of each type that are overdue. Select Appropriate HIRA Methods • Technique used • Time required to issue a HIRA report. • Number ofHIRAs of each type scheduled. 7- H A Z A R D I D E N T I F I C A T I O N A N D R I S K A N A L Y S I S 7-HAZARDIDENTIFICATIONANDRISKANALYSIS 7-HAZARDIDENTIFICATIONANDRISKANALYSIS 9.3.1MaintainaDependablePractice9.3.2IdentifyHazardsandEvaluateRisks