Factors to consider before postponing statutory inspections

It has long been an ambition across the process and energy sector to increase the amount of remote and autonomous operations, with a view to both decreasing costs and increasing safety. It is a trend that the sector has been moving towards for some time, but the current challenges faced by business, not least the increase in employees working remotely, have thrust those ambitions into the spotlight.

As the current public health crisis continues to challenge businesses and communities  around the world, many companies have limited their operations to minimise the spread of this virus. While businesses are being directed to limit site work to meet social distancing guidelines, the need remains to ensure that assets continue to operate safely as well as ensuring that they meet all regulatory requirements. 

Even those trying to operate at full capacity are often not fully staffed on site and have been forced to make some drastic changes to working patterns. This does not usually affect the people operating the plants, but the support staff, technical people, and managerial, most of whom are working remotely. This can also affect maintenance teams who are often reduced in numbers and need to maintain social distancing. Working patterns have also changed with some operators working extended shifts, so employees work the same hours but over just three days. All of these can have an impact on maintenance and inspection. 

Harnessing remote

ABB Inspection have always been able to provide support to customers remotely, but we will still have a local inspector who will physically have to look at equipment on site, and that is still going to be required in some format. We are looking at a variety of technologies such as recording photographic or video images so that the on-site inspector can consult with an expert at the base or a remote hub. Another option we are investigating is utilizing drones to capture imagery. There will always be a physical site visit in one form or another, but it is about minimising that requirement and collecting as much information as possible in the time on site.

There will always be a physical site visit in one form or another, but it is about minimising that requirement 

Where we go on site, we are focusing on facilities that are performing what the government calls critical services. The challenge there is not carrying out the inspection itself but the availability of ancillary services to support the inspection, such as scaffolders, insulators, and maintenance teams to prepare for inspection.

A planned approach to regulatory inspections

The traditional arrangement for regulatory inspections is that they would be carried out to a pre-planned schedule that is organised to minimise the impact on production. When a statutory inspection is scheduled, this approach assumes that the resource required is available. In the current climate, that resource is much more difficult to obtain, particularly if overnight stays are required.

The present situation has not heralded a change in requirements when it comes to statutory Pressure Systems Safety Regulations 2000 (PSSR) inspections, but the Health and Safety Executive (HSE) did issue some new guidance notes. The PSSR covers the safe design and use of pressure systems. The aim is to prevent serious injury from the hazard of stored energy (pressure) as a result of the failure of a pressure system or one of its parts.

Within these regulations, there has always been the ability to postpone an inspection if it is deemed safe to do so. However, despite that provision being available, operators have been reluctant to do that because if you do postpone, you have to write to the HSE. Many operators consider informing the HSE they were postponing examinations might focus greater attention on their operations. The current situation has changed that sentiment, and operators are asking how we can do postponements, and it is safe to do so.

The inspection dilemma

In a recent webinar, ABB polled participants regarding inspection and shutdown deferrals. In this survey, just over half of the companies were intending to defer individual inspections or a shutdown with a further third still to decide. The biggest concern they expressed was that the current pandemic will cause an infection of plant personnel, leading to a lack of resources now or possibly later in the year. Most companies (91 percent) are therefore intending to postpone their shutdowns with 37 percent aiming for a deferral of three to six months, a further 29 percent going for six to nine months and 26 percent for nine to 12 months. The biggest issue with delaying a shutdown is seen as deferring statutory inspections at 58 percent, plant availability/reliability (22 percent), or plant HSE issues (14 percent).

The biggest concern expressed was that the current pandemic will cause an infection of plant personnel, leading to a lack of resources now or possibly later in the year

Source

The right approach

For an inspection postponement, you review past inspection records and make a judgment of how a system is going to fail and when it does what the consequences will be. Is it going to be a minor leak of a chemical that is not hazardous, or potentially is it going to be a large leak of a toxic or flammable chemical? It is a risk assessment process but involving third-party inspection bodies, such as ABB. Considering how it is going to fail is not a simple tick box risk assessment; you do need to think about your risk and consequences. 

For onshore facilities, under PSSR, postponement of equipment inspection can be carried out (according to Reg 9(7)) subject to agreement between the ‘competent person’ and the ‘user’ if this does not give rise to danger; there is only one postponement made for any examination; the enforcing authority is notified by the ‘user’ in writing before the due date.

Postponement of equipment inspection under the Control of Major Accident Hazards Regulations (COMAH) is essentially the same as PSSR, where relevant good practices must be adopted as a minimum except that there is no specific requirement for notification to the HSE.

For offshore installations, the HID Inspection Guide Offshore – Inspection of Maintenance Management is useful and states, “If inspection of items cannot be completed, there should be an assessment of the risk this presents. Where the risk is acceptable, a deferral may be possible.” 

Considering how it is going to fail is not a simple tick box risk assessment; you do need to think about your risk and consequences

Inspection deferrals have always been part of ABB expertise, certainly for the companies where we conduct inspections. A technical case for inspection needs to be prepared for submission to the HSE. This involves considering the required postponement period, inspection history, maintenance, and operating history, and data availability. Then using the collected data, predicting what deterioration will occur and whether this will remain within acceptable limits up to the next inspection.

Our experience is that around 30 percent of postponements will require further mitigating actions such as additional inspection, operational monitoring, changes to the mode of operation, de-rating of equipment, restricted personnel access, and contingency planning in case of failure.

It is likely that not all inspections can be postponed. Some items will be high risk or approaching the end of life where a technical justification for deferral cannot be made. For large numbers of items, an approach based on criticality assessment can be used to focus resources more effectively on higher risk items.

Whatever strategy is adopted to ensure compliance, it is vital that whoever has responsibility for operating the plant understands the risks of not doing inspections. If you want to postpone inspections, that is a risk, it may be an exceedingly small risk, but the operators must understand what that risk is. And sometimes that may mean that they must put in place some mitigation actions while operating a system or piece of equipment that has not been inspected. It is all about understanding the risk and controlling it.

Martin Brown is principal lead consultant, integrity management at ABB Energy Industries, UK