Joewong....We're discussing UG-140(a) (used to be CC 2211) rather than HIPS. Your right in saying that HIPS can't effectively defend against a fire scenario, but that's another subject. Vapor filled vessels, exposed to fire risks, are candidates for UG-140(a).
From your question, I'm guessing that you might be referring to UG-140(b) which allows the use of instrumentation to build a case for "overpressure by system design." That instrumentation can be HIPS but it doesn't have to be. I've heard others that interpreted it that way too, but that's an overly restrictive interpretation. It can be HIPS or it can be non-HIPS.
Personally, I think the wording could have been a little clearer. I think a lot of people are going to misinterpret UG-140(b). I'm also very surprised to find practically zero discussion on UG-140 when I search the internet. This was published by ASME last July, but I don't think a lot of folks have noticed it yet.
Regards.