1. Health and Safety Executive Over-pressure protection: HSE’s position Stephen Murray HSE inspector, process integrity team, Offshore Division

2. HSE’s job is to prevent people being killed, injured or made ill by work. “Those who create the risk are best placed to manage it.” Managing over-pressure protection

3. Health and Safety at Work etc Act 1974 ‘the duty of every employer to ensure … the health, safety and welfare at work of all his employees’ ‘the provision and maintenance of plant and systems of work that are … safe and without risks to health’ Managing over-pressure protection

4. Pressure relief devices are the last line of defence. PSV –inadequate sizing (Grangemouth, 1987) –recent survey 4% failed to lift Bursting disc –Gas releases through unrevealed rupture Managing over-pressure protection

5. gas Heat Exch. HP Flare Drum seawater Managing over-pressure protection

6. PAH gas Heat Exch. LSH ESD ESDV HP Flare Drum disc failure no alarm tell-tail blocked does not trip seawater pumps not tight shut-off no level indication above LSH observed pressure 4 barg Multiple failures liquid @+40m Managing over-pressure protection seawater

7. Relevant regulations: ‘identify hazards and assess risks’ (Management of Health and Safety at Work Regs, 1999) ‘maintained in an efficient state, in efficient working order and in good repair’ (Provision and Use of Work Equipment Regs, 1998) Managing over-pressure protection

8. Offshore regulations: ‘prevent the uncontrolled release of flammable substances’ (Prevention of Fire and Explosion, and Emergency Response Regs, 1995) ‘identification of safety critical elements and a verification scheme’ (Safety Case Regs, 2005) Managing over-pressure protection

9. Onshore regulations: ‘pressure system… shall be properly designed and constructed… so as to prevent danger’ (Pressure Systems Safety Regs, 2000) ‘a written scheme for periodic examination’ including ‘all protective devices’ (PSSR, 2000) Managing over-pressure protection

10. Summary, over-pressure systems: responsibility of ‘risk creator’; identify hazards & assess risks; appropriate design & construction; maintain in working order and good repair; examination or verification scheme to address condition. Managing over-pressure protection

11. Health and Safety Executive Managing over-pressure protection: HSE’s view Stephen Murray HSE inspector, process integrity team, Offshore Division