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d) It is all about calculations related to random failures

SIL validation is of course necessary but it is important not to get too obsessed with the numbers.

The IEC process is order of magnitude, not a numerically precise exercise. The parameters we use to

determine the SIL (demand rates, risk reduction etc.) are in most parts rough estimates, as are the

failure rates we use in the reliability calculations. Too often I see people arguing over which

reliability modelling method to use when in reality the difference between the best to worst

approaches are second order at best. This focus on the numbers can lead to less attention being

paid to other areas of SIL validation, such as hardware fault tolerance requirements, or ensuring that

the equipment meets the safety manual constraints when demonstrating systematic compliance.

e) Operations is just about proof testing

Operations is about maintaining, and demonstrating maintenance, of the required SIL throughout

the plant life. This is much more than proof testing. It involves management of change, data

validation and collection, training and much more. Operations readiness preparation is a complex

and wide ranging subject.

4) IMPLEMENTATION SHORTCOMINGS

As a result of all or some of the factors described, projects can get into problems during execution.

Problems arise typically as a result of the following failures:

Lack of an experienced (or any) FS manager

Lack of an adequate (or any) FS management plan

HAZOP report quality and lack of clear links to all the later phases

Lack of understanding about tolerable risk definition

Lack of understanding about regulatory vs contract requirements

Contractual issues between EPC designers and operator

Poor management of change, in design and in operations

Lack of organisational connection between engineering and operations at an early stage

The first stage in minimising these potential shortcomings is by ensuring that the designer (e.g. EPC)

appoints an experienced FS manager, preferably as early as FEED or bid in order to:

Fully understand and clarify the contractual FS scope e.g. conflict of referenced standards,

full life cycle or hybrid, any client FS standards

Have a clear understanding of the regulatory and contract requirements

Ensure the project starts with a well-defined FS scope that is understood by the team. These

issues affect the design including ICSS.