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This post was last edited by Crickets_az5C8 on 2019-7-18 at 16:19. It concerns old enterprises with two key issues and one major issue: they have a DCS operating system but no SIS safety instrument system. The organization carried out a HAZOP analysis; since safety instrument functions of the type SIF are not required, is it possible to avoid carrying out SIS upgrades?
If SIF is not needed, then SIS is also not required
To access SIS, please contact 13405869073 for details
SIS should be added, as required by the headquarters
**Guiding Opinions of the State Administration of Work Safety on Strengthening the Management of Chemical Process Safety Instrumented Systems, Document No. An Jian Zong Guan San [2014] 116: (1) Chemical process safety instrumented systems (SIS) include safety interlock systems, emergency shutdown systems, as well as detection and protection systems for toxic and harmful gases, flammable gases, and fires. The safety instrumented system is independent of the process control systems (such as distributed control systems, etc.). It remains in a dormant or inactive state during normal production, but can act instantly and accurately once a situation that could lead to a safety accident occurs in the production facility, thereby stopping the production process safely or bringing it into a predetermined safe state. It must have high reliability (i.e., functional safety) as well as proper maintenance and management. If the safety instrumented system fails, it can often result in serious safety accidents; indeed, most of the major chemical (hazardous chemicals) accidents that have occurred in developed countries in recent years have been related to failures in the safety instrumented systems or improper installation of these systems. Based on the consequences and risks resulting from the failure of safety instrument functions, these functions are classified into different safety integrity levels (SIL1-4, with level 4 being the highest). Safety instrumented systems of different levels have varying technical requirements in terms of design, manufacturing, installation and commissioning, as well as operation and maintenance. At present, in China’s safety instrumented systems and related safety protection measures, various issues exist throughout the entire life cycle – including design, installation, operation, and maintenance – such as insufficient hazard and risk analysis, inappropriate design choices, unreasonable redundant fault-tolerance structures, a lack of defined inspection and testing schedules, and preventive maintenance strategies that are not effective enough. It is therefore urgent to improve the standards for managing safety instrumented systems. As the scale of chemical processing units and hazardous chemical storage facilities in our country grows, along with the increasing level of automation in production processes, it has become extremely urgent and necessary to strengthen and standardize the management of safety instrumented systems. VI. Actively promote the evaluation of existing safety instrumented systems. (14) Chemical enterprises and hazardous chemical storage facilities that operate production units or facilities classified as “two key areas and one major hazard” should, on the basis of conducting comprehensive process hazard analyses (such as Hazard and Operability Studies), determine the functions of safety instruments and the requirements for risk reduction through risk analysis, and promptly assess whether the existing safety instrument functions meet these risk reduction requirements. (15) Enterprises shall, on the basis of assessment, formulate management plans for safety instrumented systems and regular inspection and testing plans. For safety instrument functions that do not meet the requirements, relevant maintenance plans and corrective action plans must be developed, with the assessment and improvement of the safety instrument system to be completed by the end of 2019. Other chemical processing units and hazardous chemical storage facilities shall be implemented in accordance with the requirements of these guidelines. VII. Work Requirements (16) Relevant enterprises and organizations shall, in accordance with relevant laws, regulations, standards, norms, and the requirements of these guiding principles, improve their management systems and frameworks for safety instrumented systems; they should also increase financial investment to ensure that the safety instrumented systems of newly built facilities meet the requirements of functional safety standards. For safety instrumented systems in operational installations that do not meet functional safety requirements, they must be included in a remediation plan for timely correction, in order to eliminate potential accident hazards, reduce the risk of accidents, prevent their occurrence, and effectively improve the inherent safety level of the enterprise. (17) Safety supervision departments at all local levels should promptly conduct investigations and research, set work objectives, identify pilot units, define timeline requirements, and guide and urge enterprises to strengthen the management of chemical process safety instrumented systems and related safety protection measures. The functional safety assessment of safety instrumented systems, the implementation of management systems for such systems, and personnel training should all be included in the scope of safety inspections and audits. Provincial safety supervision bureaus are required to compile summaries of relevant inspection activities each year, and submit them to the Third Department of the **General Administration of Safety Supervision by the end of February each year. “Older enterprises involve two key aspects and one major issue; they lack safety instrument systems. The organization has carried out a HAZOP analysis, and since no SIF safety instrument functions are required, is it possible to skip the SIS renovation? My personal opinion is that SIS renovation is necessary
For safety instrumented systems in operational installations that do not meet functional safety requirements, they must be included in a remediation plan for timely correction, in order to eliminate potential accident hazards, reduce the risk of accidents, prevent their occurrence, and effectively improve the inherent safety level of the enterprise.
It falls under the category of two key points and one major issue, and requires entry into SIS. It should be a security review by an expert group.
In my opinion, whether to install a SIS is determined by two factors: first, the requirements of laws and regulations; second, the conclusions drawn from HAZOP analysis and LOPA risk assessment. If either of these factors indicates that a SIS is necessary, then it must be installed. The **Interim Provisions on the Supervision and Management of Major Hazard Sources of Hazardous Chemicals**, Order No. 40 issued by the State Administration of Work Safety in 2011, explicitly states that for major hazard sources of level 1 or 2 that involve toxic gases, liquefied gases, or highly toxic liquids, an independent Safety Instrumented System (SIS) must be installed. If a facility falls into this category, such a system is required regardless of its classification. Additionally, the basic requirements for safety diagnosis and management outlined in Document Su Emergency [2019] No. 53 also stipulate that hazardous chemical storage areas involving major hazard sources of level 1 or 2 that contain toxic gases, liquefied gases, or highly toxic liquids must be equipped with independent Safety Instrumented Systems. The sensing elements and actuating elements of each circuit should be installed independently, with the Safety Instrumented Level (SIL) being no lower than Level 2. For Class 1 and Class 2 major hazard sources that are not classified as toxic gases, liquefied gases, or highly toxic liquids, the requirements set by the Safety Supervision Bureau are to conduct a hazard analysis (such as Hazard and Operability Analysis) in order to determine the SIF for those systems; if no safety functions are actually necessary, then there is no need to install a SIS. The views expressed above are purely personal opinions.
First, determine whether it constitutes a primary or secondary major hazard source; each province should have relevant regulations on this. Since you have already conducted HAZOP and SIL analyses, there is no need to implement a SIS if it isn’t necessary.
Those classified as Class 1 or Class 2 major hazard sources must be integrated into the SIS system. If this standard is not met, it is necessary to engage a qualified assessment agency to carry out a HAZOP analysis and determine the LOAP level; if the SIL level cannot be achieved at SIL1, there is no need to install a SIS system. Note: Experts from the work safety supervision agency who conduct evaluations within one’s own organization (the so-called experts) are not recognized. :@:@
A HAZOP analysis cannot determine the SRS (Safety Requirements Specification); a LOPA analysis is required to determine the SIL level. If a SIF is indeed not needed, then it’s entirely possible to omit a SIS. Never spread misinformation; excessive caution is a waste.