Automated SAFE Chart Methodology: A Way To Manage Compliance With OSHA Process Hazard Analysis Regulations
Authors: Axworthy A.T. , Wood T.B. 
Published: October 2008

Amoco Production Company's Risk Assessment Tool Set (RATS) will significantly improve the effectiveness and reduce the cost of implementation of Amoco's process safety management program. The goal of the project is to reduce manpower requirements for process safety management by 10% to 25%. RATS will be used company-wide, onshore as well as offshore, by formalizing and automating a SAFE chart methodology (SCM) based on the API recommended practice 14C. Other work in the area of automating process safety management focuses on document management and report templates. RATS, in contrast, uses rules to evaluate process configurations and automatically generate the required evaluation reports.

Background

API RP-750, entitled "Management of Process Hazards: recently promulgated OSHA 1910.119, and section 304 of the 1990 Clean Air Act Amendments address chemical process facility information requirements, focusing on a comprehensive chemical process safety management program. California, New Jersey, and several other states have added similar safety documentation regulations.

Several process hazard analysis (PHA"also commonly called process safety analysis) procedures are available, such as Fault Tree Analysis, Failure Mode & Effects FMEA), Hazard and Operability (HAZOP) studies, safety system checklists, and What-if studies. OSHA has not specified any single approved method, but has taken a flexible approach wherein the owner must select the most appropriate method of analysis for his facility.

Current Process Hazard Analysis of Petroleum Production Facilities

The most common safety analysis (or PHA) procedure for petroleum production facilities is the API recommended practice 14C (API 14C). This procedure features an extensive checklist of safety considerations for the typical field process equipment routinely used in offshore oil and gas production and processing.

Rather than use a generalized HAZOP or What-if analysis technique for each process equipment unit in the facility, the API 14C procedure (essentially a combination of HAZOP deviation guide words and an FMEA format) defines a customized safety analysis for each major process unit type commonly used in petroleum production processing.

The process equipment failure modes considered in API 14C are generally limited to internal process-generated conditions. External events (such as a pipe rupture due to adjacent crane collapse) or maintenance events (such as cutting into a flowing line) are not considered directly in the API 14C procedure.

The U.S. Department of Interior's Mineral Management Service requires offshore petroleum production safety documentation to follow the API 14C format. Corresponding process safety documentation are not routinely prepared for onshore petroleum operations, but the use of the same recommended safety protective devices is relatively common.

Therefore, compliance with API 750 may be accomplished by restructuring onshore petroleum safety management documentation to coincide with offshore documentation. Compliance with OSHA and EPA regulations will require additions to these basic documents.

API 14C:The Common Denominator for Compliance

API 750 states that the process safety (hazard) analysis should use an "orderly, systematic approach following one or more methodologies such as API 14C or ...".