HAZOP facilitator -- is it "engineering"? 6

[meldridge]

I have been presented with an "opportunity" to assist one of my company's clients by facilitating a HAZOP.

As part of the proposal, I would not be leading and scribing, but not providing recommendations (client engineers would be participants).

I do not hold a PE valid in MA (where the HAZOP would occur).

Would you consider HAZOP facilitating to be "engineering" (and to therefore require PE registration in the state where the HAZOP occurs)?

Thx in advance for any input.

 

[plasgears]

HAZOP?

 

[MiketheEngineer]

You are doing training - I think from your question. Not designing and sealing a set of plans....

PE shouldn't be required..

You are just giving ideas and recommendations....

 

[meldridge]

sorry, acronyms....

HAZOP = hazard and operability study (used in chemical industry)

group of operations and engineering meets and discusses the consequences of deviations within a process

 

[HamishMcTavish]

Having been to quite a few HAZOPs and participating in other methods of hazard identification i think it's safe to say that "facilitating" does not require you to be a registered PE. Even the participants might not need to be PE although they must definitely be qualified and experienced in order to add something meaningful to the discussions. Having said that i'm based in the UK so it might be worth asking the question to your state licencing body.

I would say to you that if you haven't done one before then don't take on the role of chairperson as it does take quite a bit of diplomacy to steer the discussions and make sure all the required material gets covered within the timescales available.

Remember the output of the HAZOP will be a documented series of hypothetical hazards that the designers will have to address (eliminating them if possible or by addressing issues of safeguards) so the records have to be well structured and the description of the hazard and possible consequences have to be as clear as possible.

If you work in the chemical industry it would probably be a 'good' experience - many people in know (in the nuclear industry) have horror stories about HAZOP meetings lasting several days but if you have someone experienced at the helm they can be a positive experience!

Good luck, HM

No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[MotorVib]

As far as I know a PE is not required for a HAZOP. I don't see why a PE would be needed you are not doing any drawings or cal's, it is your engineering opition that goes in to the HAZOP's.

Chris

"In this house, we obey the laws of thermodynamics." Homer Simpson

 

[MintJulep]

You're not a PE in MA, but are in one or more other states?

Most states will allow (or at least tolerate) out-of-state PEs participating in short-term activity.

 

[BigInch]

Its allowed. PE not required for HAZOP.

The procedure varies somewhat, but typically all HAZOP comments are taken as recommendations, or suggestions and returned to the original design team for further action. They will do a detailed review of the comments to verify necessity and/or benefit. After the detailed review, the results are passed on to the project management team for the actual decision on whether to implement a suggested revision or not.

**********************
"Pumping accounts for 20% of the world’s energy used by electric motors and 25-50% of the total electrical energy usage in certain industrial facilities."-DOE statistic (Note: Make that 99% for pipeline companies)

http://virtualpipeline.spaces.live.com/

 

[BenjaminM]

I've been though about 3 or 4 HAZOPS over the past couple of years. All sorts of fun *grins*

I dont have the standard infront of my, but CFR wants the input from several different groups involved. Engineering, techinical, operational, and management I believe are what it ask for.

For us the techinical aspect was our lab guy. What are the hazards of the chemistry of the process. What are the limits on process condiations we must stay within.

The operational aspect was our lead operators. They will often come up with problems or issues you could never dream up since they work in it day to day.

Management is self descriptive.

And lastly is engineering. I am there to make sure what they are suggesting be done makes sense. To provide insight on the process side of things. To point out anything no one else thought of.

Additionally the action items are usually disporportionately assigned to me. For better or worst.

You do not need to be a PE to perform your internal HAZOPS. However I would think you would need a PE if say you facilitated HAZOPS for other companys as a service or consultant.

 

[BigInch]

Not usually, if you do not make the final design decision. As I said above, normally the suggestions are returned to the original design team for implementation. Those that implement design changes, in cases where a PE is needed (there are many where it is not), need a PE license to do so.

**********************
"Pumping accounts for 20% of the world’s energy used by electric motors and 25-50% of the total electrical energy usage in certain industrial facilities."-DOE statistic (Note: Make that 99% for pipeline companies)

http://virtualpipeline.spaces.live.com/

 

[meldridge]

I received an official reply from MA engineering board that MA would not require PE for facilitating HAZOP.

Thanks, all, for your input.

best regards,
m

 

[dcasto]

A HAZOP can be performed by just two people per the regulations:

"The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used."

 

[HamishMcTavish]

dcasto

what regulations are you talking about - never heard of any in the uk. Do the CFR mandate the use of HAZOP?

i think a "hazop of one" with someone taking notes wouldn't be particularly useful. i agree that the amount of time spent on hazard identification should be proportional to the risks / consequences, however this sounds more like a desktop study rather than a HAZOP.

regards, HM

No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[meldridge]

dcasto is referring to US regulations 29 CFR 1910.119 (OSHA Process Safety Management [PSM]) and/or 40 CFR 68 (EPA Risk Management Plan [RMP]) and/or various US state regulations.

Specifically, PSM & RMP require a Process Hazard Analysis (PHA) which is more inclusive than a HAZOP. A PHA must also include human factors and facility siting type inquiry.

Another type of HAZOP (I was originally speaking of) is implemented at the design phase and is not covered under any US federal regulation. The design phase HAZOP is a tool that can be used to determine if we're missing anything big on a conceptual basis prior to proceeding with a design. Sometimes, there is only one engineer (designer) involved with a HAZOP, sometimes many. Frequently, operations personnel have very valuable input at this phase and assist with ensuring we have a very robust design prior to proceeding.

best regards, all.
m

 

[HamishMcTavish]

Hey meldridge,

thanks for the US legislation pointers - always useful to know!

what i was puzzled about was that the CFR etc woud MANDATE the use of one particular technique of hazard identification.

I use a variety of HAZID (HAZard IDentification) tools from HAZOP to plant walkdowns to FMEA to human factors task analysis so i'm aware of what's out there and when they are used. It just struck me as odd that it seemed that there was a general regulatory buy-in for a two person hazop where in fact (or rather my opinion) the number of people and duration should be proportional to the complexity / number of stakeholders and possible consequences.

I must have misinterpreted dcasto's post - long days at the moment

cheers, HM

No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[BigInch]

The number of engineers involved should be based on the range of competency of each engineer involved versus the range of complexity of the process. That ratio should always be >= 1

**********************
"Pumping accounts for 20% of the world’s energy used by electric motors and 25-50% of the total electrical energy usage in certain industrial facilities."-DOE statistic (Note: Make that 99% for pipeline companies)

http://virtualpipeline.spaces.live.com/

 

[HamishMcTavish]

BigInch,

Not in any way trying to teach you how to suck eggs but apart from relatively simple designs or modifications i would suggest that the figure should be higher. If a single person did carry out a desktop study then i would expect it to be reviewed by several people.

I'm no great fan of HAZOP meetings with 'umpteen participants spanning several days but the technique is SUPPOSED to capture the different viewpoints from users / maintainers / designers etc. through the lifecycle of the process / product.

Sure if one person has got that much experience then all credit to them, however it doesn't address bias / tunnel vision.

Kind regards, HM



No more things should be presumed to exist than are absolutely necessary - William of Occam

 

[BigInch]

Totally agree. Thought that's what I said, not meaning ">= 1" quite as explicit an equation as it would look out of the context of this thread topic.

**********************
"Pumping accounts for 20% of the world’s energy used by electric motors and 25-50% of the total electrical energy usage in certain industrial facilities."-DOE statistic (Note: Make that 99% for pipeline companies)

http://virtualpipeline.spaces.live.com/