Rostekhnadzor Order No. 533 – changes and decision

Rostekhnadzor issues numerous regulatory legal acts (RLA), and during work with the "Regulatory Guillotine" mechanism, it is planned to change, cancel or develop over 180 RLA. Order No. 533 issued on December 15, 2020, aroused keen interest among all those involved in industrial safety by virtue of their activities, as it has a significant impact on the vital activity of hazardous production facilities (HPF). Rostekhnadzor Order No. 533 approved updated "General Rules of Explosion Safety for Explosive and Fire-Hazardous Chemical, Petrochemical and Oil Refining Industries" that came into force on January 1, 2021.

Objectives of Order No. 533

The Rules establish requirements for ensuring explosion safety of technological processes, buildings, structures and technical devices used (located) at hazardous production facilities (HPF).

The Rules establish categories of explosion hazard of technological blocks, as well as methods for determining these categories:

• when developing technological processes, designing, constructing, operating, reconstructing, technical re-equipment, major repairs, conservation and liquidation of HPF;
• when manufacturing, installing, adjusting, servicing, diagnosing and repairing technical devices used at facilities;
• when conducting industrial safety expertise of documentation for technical re-equipment, conservation and liquidation of HPF;
• when justifying safety: HPF, technical devices, buildings and structures;
• when declaring industrial safety of HPF.

What's New in Order No. 533 of 2020

What is the novelty of this document, what should operators of hazardous production facilities undertake to comply with the requirements of the new Rules, if the previous Rules adopted by Rostekhnadzor order No. 96 of March 11, 2013 have not lost their relevance?!

1. Hazard and operability analysis (HAZOP) is now required at all stages of the life cycle of high-risk facilities (HPF).
2. The need to apply safety integrity level (SIL) has appeared.
3. The Rules of Order No. 533 specify the list of hazardous production facilities to which explosion safety requirements apply.
4. Many references given in the Rules have been canceled within the framework of work with the "Regulatory Guillotine" and replaced with current references to RF Laws, Technical Regulations of the RF and EAEU.

Hazard and Operability Analysis – One of the Key Points in Order No. 533

In Order No. 533, the topic of hazard and operability analysis (HAZOP), which is necessary at all stages of the HPF life cycle, was voiced in a new way.

The Rules establish categories of explosion hazard of technological blocks, as well as methods for determining these categories at all stages of the HPF life cycle.

Appendix 1 of these Rules regulates the application of HAZOP and describes the methodology for conducting this analysis using keywords and their combinations: "no", "more", "less", "same as", "other", "other than", "reverse", "pressure", "temperature", "composition", "maintenance", "failure". It is assumed that the use of keywords by performers will help identify deviations. Essentially, this is the "HAZOP" method, detailed in GOST R 27.012-2019 - Hazard and Operability Analysis (HAZOP).

Safety Integrity Level – New Requirement for Emergency Protection Systems at HPF

A large chapter in the Rules is devoted to organizing the emergency automatic protection system (EAP) at HPF, in which for the first time in a regulatory legal document of Rostekhnadzor, the need to apply safety integrity level (SIL) appears.

SIL must be applied when designing EAP systems and is determined based on hazard and operability analysis of safety circuits, taking into account the risk arising from its failure. The SIL calculation methodology itself is described in standards GOST IEC 61508 and GOST IEC 61511, which have been gradually implemented in Russia since 2007. These standards regulate activities in the production, design, construction and use of emergency protection systems (EAP). According to the Law "On Technical Regulation", the application of these standards is voluntary. However, since the reliability indicator of EAP system functions appeared in the Rules, application becomes mandatory. This approach will significantly increase the degree of protection of our hazardous production facilities.

What is SIL and How to Determine It

The EAP system consists of multiple instrumental protection functions, which in turn are formed from logical chains of devices "Sensor – Decision Device - Executive Element". The purpose of this function is to timely stop the process and bring it to a safe state in case of danger. The reliability of the instrumental protection function is characterized by the safety integrity level, consisting of 4 categories: SIL1, SIL2, SIL3 and SIL4. The higher the SIL level, the more reliable the instrumental protection function.

The new Rules require calculating the SIL level depending on the existing risk and explosion safety category of the technological block of the HPF. Unfortunately, there is no simple formula for calculating SIL. This is a long and thorny path, but possible.

GOST IEC 61511 regulates the methodology for determining the target (minimum required) SIL level:

• applying hazard and operability analysis (HAZOP) methodology;
• assessing independent protection layers using LOPA methodology;
• determining the target SIL level for each instrumental protection function of the EAP system.

Practical Application of Risk Analysis (HAZOP)

Determining Target Safety Integrity Level (SIL)

To obtain the target SIL value, it is necessary to go through several sequential steps shown in Fig. 3.

For conducting the analysis, a team of experienced specialists with HAZOP and LOPA methodology knowledge is required. Typically, this group is formed from the following specialists:

1. HAZOP, LOPA meeting chairman (experienced senior process engineer);
2. Meeting secretary;
3. Process engineer;
4. Operation engineer for specific structures and equipment with deep knowledge of procedures and information about process safety;
5. Mechanical engineer;
6. Instrumentation and control engineer;
7. Occupational safety, industrial safety and environmental protection engineer;
8. Other specialists as needed.

The meeting chairman and secretary are certified specialists for conducting HAZOP and LOPA sessions. Other working group participants may be representatives of the Customer at the HPF where the hazard and operability analysis is conducted.

Personnel Training for Emergency Situations

One important point in the Rules is training and practicing skills on computer simulators for personnel managing processes at HPF that include blocks of categories I and II explosion hazard. The simulator algorithm must include technical regulation parameters for operation and hazard and operability analysis of HPF, based on which critical situation modeling can be performed.

Industrial Safety Declaration

It is important to remember that HAZOP is a mandatory component of the Industrial Safety Declaration of HPF, in accordance with Federal Law No. 116 "On Industrial Safety of Hazardous Production Facilities", to ensure full activity at all stages of the facility's life cycle. The diagram in Fig. 4 shows that for conducting industrial safety expertise of HPF, an Industrial Safety Declaration is required, which must include HAZOP (Article 14, paragraph 1 of Federal Law 116).

Contractor Selection

Based on the above, it can be stated that hazard and operability analysis becomes a cornerstone in ensuring safe operation of HPF and harmonious relations with government regulatory bodies.

What should HPF operators do in this situation - HAZOP must definitely be done, but who can conduct HAZOP, LOPA, SIL sessions in accordance with Order No. 533? Two scenarios:

When choosing a contracting organization, it is important to consider accumulated experience in various industries: petrochemicals, mining, oil and gas exploration and production, etc. This will help conduct work more economically and make the facility safer.