Plant modification / Change procedures

This Technical Measures Document refers to the Plant Modification and Change Procedures.

Related Technical Measures Documents include:

The relevant Level 2 Criteria are:

Safety Management systems

The Chemical Industries Association Safety Advisory Group outlines the following good practice related to plant modification / change procedures:

The procedure should draw reference to:

Good industry practice requires that process and plant modifications should not be undertaken without having undertaken a safety, engineering and technical review. This review should be traceable and identify changes proposed to the following factors:

A form of risk assessment should then identify what hazards have been created by the change that may affect plant or personnel safety, and what action can be implemented to reduce or eliminate the risk. Additional hazards that may be introduced which need to be considered are fire, explosion and loss of containment.

Changes may affect other parts of the plant which may be quite remote from the source of the change. Therefore all parts of the plant should be considered in undertaking hazard identification and risk assessments.

Factors that are crucial to the success and safe implementation of a plant modification procedure include:

HAZOP

Various stages of Hazard and Operability Study are generally undertaken. These are summarised in the following table:

HAZOP study Description
1 Identify major hazards and check for availability of key hazard data
2 Coarse HAZOP using flowsheet and block diagram
3 Full HAZOP on frozen P&I diagram
4 Check that all intended actions have been implemented, including hardware and software
5 Pre-commissioning check including statutory requirement
6 Safety audit after a few months operation

These are equally applicable to plant modifications as new plant. However, written procedures should be in place to determine what level of HAZOP (if any) should be applied. These procedures should take account of:

A conventional hazard and operability study will identify potential hazards, but gives no likelihood of an incident occurring, or the loss suffered. The methodology has been developed to address likelihood and risk to assist in resource and priority allocation. Where hazards are not eliminated by actions placed during the HAZOP, Hazard analysis should be employed to determine if the risk is acceptable.

Preliminary Hazard Analysis (PHA)

Preliminary hazard analysis is performed as the first step in a hazard assessment. The essential stages of a systematic procedure to maintain a safe manufacturing situation include:

These stages should be applied:

Operating procedures during change

Poor management and control of changes to plant and process often results in increased risk to plant, people and environment. Consequently, control of operating procedures during change is a critical task. Only authorised personnel should amend existing operating procedures or issue temporary operating instructions during plant or process changes. It is good practice for the operating procedures to be authorised by representatives from several different departments. These may include:

An assessment of change to risk should be an integral part of generation of procedures. The degree of control of change will depend upon whether the proposed change may be classed minor and major procedural changes

Commissioning procedures

Commissioning procedures are covered in more detail in the Technical Measures Document on Operating Procedures.

The continued integrity of the plant needs to be upheld by adequate maintenance, inspection and avoidance of unauthorised design or operational changes. To avoid hazards caused by modifications, it is necessary that any proposal for change be identified, and that the proposal is formally authorised after, after technical investigation, by competent personnel of senior status. Modifications should be designed, constructed, inspected, tested and proved to have achieved the design intent and should be maintained at least to the standard of the design criteria required by the process.

Decommissioning procedures

The requirements for decommissioning will vary depending upon the nature of the plant items to be decommissioned and the duty the plant items fulfilled. Operating procedures should be provided for decommissioning of hazardous plant in the same way as for commissioning. These procedures should be subject to hazard review and risk assessment. General measures that should be adopted for a common approach to decommissioning include:

Status of guidance

Plant modification and maintenance procedures are covered in general guidance, however, no guidance is available that specifically covers plant modification. Most companies usually adopt internally generated plant modification procedures that have been developed through:

Codes of Practice relating to Plant modification

Further reading material

Case Studies illustrating the importance of Plant modification / Change procedures

2021-10-06