Autopro Blog

Legislated Process Safety Management: What You Need to Know

August 08, 2018

by

As you may already be aware, part of a Process Safety Management (PSM) plan follows IEC 61511 (or the equivalent) in order to meet some of the PSM elements. One of the questions I am asked most often is whether compliance to IEC 61511 is mandatory and, up until now, the answer for Canada has been no.

However, according to the 2018 version of the Canadian Electrical Code (CEC), Canadian process industry players will soon be required to comply with IEC 61511. For Alberta producers that date is February 1, 2019. This is a six month buffer to comply with a standard that, in reality, is not as well understood as it should be.

What is IEC 61511 and IEC 61508?

IEC 61511 is an industry specific standard (also known as a “child” standard) from the overarching IEC 61508 (Functional Safety of Electrical/ Electronic/ Programmable Electronic Safety-related Systems). There are several industry specific standards under the IEC 61508 umbrella, such as IEC 62061 – which refers to the functional safety of electrical, electronic, and programmable electronic control systems, IEC 61513 – which refers to nuclear power plants instrumentation and control systems, etc.

IEC 61508, specifically parts 2 and 3, is commonly referred to as a product certification standard. Products used in Safety Instrumented Systems applications, or SIS for short, are often referred to as “SIL rated” or “SIL certified”. This means that an independent 3rd party has done an inspection and completed a detailed review of the product’s components, manufacturing and design management to determine the suitability for use in a particular Safety Integrity Level.

While projects could use IEC 61508 (specifically part 1) as the design basis, it is much more common to use IEC 61511. This is likely part-and-parcel to the ease of readability and increased understanding due to the process specific nature.

What is Process Safety Management?

Using the CSChe PSM Standard, Process Safety Management is comprised of 12 elements in which IEC 61508 plays a somewhat significant role in only a handful of, and a much lesser role in the remainder. Process safety on the whole should not be seen as the responsibility of a single discipline or department. True success requires multidiscipline and interdepartmental participation. A classic example of this is the HAZOP process where a multidiscipline team brainstorms the design to identify causes, consequences and safeguards. This is part of both the IEC and PSM standards.

Simply following IEC 61511 does not mean compliance to a PSM program, however, it can be used to demonstrate compliance to some of the elements and sub-elements. In the United States, the US Department of Occupational Safety and Health Administration, US Department of Labor (OSHA) has deemed IEC 61511 as “Recognized and Generally Accepted Good Engineering Practices”. Similarly, here in Canada, IEC 61511 is considered an industry best practice by many major players in the process industry.

IEC 61511, IEC 61508 and the 2018 Canadian Electrical Code

The 2018 version of the CEC has incorporated both IEC 61508 and IEC 61511 (normally thought of as a process safety, or SIS/SIL standard) into Appendix A of the Code.

Some companies have taken the position that this is a good thing for Canadian industry, while others hold a different view point in that a roll out of this magnitude should be done over a longer period of time with educational opportunities. One thing is certain, six months is not enough time for all of the process industry players to become compliant. This also leaves other industries in a grey area, such as machine safety. It is unclear at this time if they will be required to comply because IEC 62061 is also under the IEC 61508 umbrella.

I have reached out to the CSA Group, the standards development organization who publishes the CEC, to get history and clarification on the decision to include these two standards in the CEC. They stated that the intent was to incorporate an internationally recognized standard for product certification. Given that intention, it is logical to include parts 2 & 3 of IEC 61508 into the CEC. However, as IEC 61511 is intended for the process industry as a whole and is not focused on products, its inclusion does not seem to fit the intent.

At the time of writing this blog, I am waiting for clarification from CSA on the specific intent of the inclusion of IEC 61511, and if a statement will be issued with respect to the status of these standards. Once I have clarification, this blog will be updated. It is my hope that Appendix A will be revised to include only parts 2 & 3 of IEC 61508 and withdraw the remaining standards (and parts of standards) that are not specific to product certification.

Implementing IEC 61511 and IEC 61508 in the Process Industry

As it currently stands, companies operating processes (oil and gas, chemical, etc.) will be required to demonstrate compliance to IEC 61511 as of February 1, 2019 for all new installations, which is an extremely tight timeline.
 
In addition, the process safety community in Canada is relatively small. As this becomes a regulatory requirement, competency is likely to become an issue as a result of the enormous demand that will exist for process safety professionals needed to consult to industry, implement and maintain the systems and documentation required, and perform regulatory audits.

It is my view that it is impractical to enforce this requirement with too little time, too few competent resources, and at a time when our industry is feeling economical pressures

In the end, we all want a safe workplace, however rushing compliance-based activities to meet an impractical date will not accomplish the desired goal and may indirectly create environments that breed a false sense of security.

What is the Path Forward?

There is little doubt that this issue will raise awareness within the Provincial Authorities Having Jurisdiction (AHJ) with respect to the implementation of any process related safety standard, and ultimately, the decision to move forward with IEC 61511 rests with them. It is my hope that discussions will follow, and, with adequate industry input, enough time can be allowed for companies to comply.

Autopro is committed to engaging the appropriate individuals within CSA and other relevant regulatory bodies to ensure that a realistic dialog with industry stakeholders takes place, and if the implementation is going to happen, that a timeline to match is developed.

If you wish to engage in this conversation, please reach out to me or your Autopro Business Development Manager. I can be contacted directly by email at r%60l/jn%7Bl%60A%60tunqsn/b%60

.