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Environmental Manager

Common Mistakes When Conducting a


HAZOP and How to Avoid Them
An important part of ensuring the success of a HAZOP study is to understand the
errors that can cause the team to lose focus
Arturo Trujillo, Walter S. Kessler
and Robert Gaither
Chilworth, a DEKRA Company

ince its inception in the 1960s


and its first official publication in 1977, the Hazard and
Operability Study (HAZOP)
has become one of the most powerful tools for identifying process hazards in the chemical process industries (CPI). Utilizing systems that are
qualitative or even simplified semiquantitative, the HAZOP method has
been increasingly used, not only as a
tool for identifying process hazards,
equipment deficiencies or failures and
operability problems and assessing
their risks, but also as a tool for prioritizing actions and recommendations
for process-risk reduction. Reducing
risk is especially important in ensuring the safety of the personnel who
must work in the plant environment
each day (Figure 1).
The HAZOP methodology is a systematic team-based technique that
can be used to effectively identify
and analyze the risks of potentially
hazardous process operations. It is
the most widely used process hazard
analysis (PHA) technique in numerous industries worldwide, including
petrochemicals,
pharmaceuticals,
oil-and-gas and nuclear, and is used
during the design stages of new processes or projects, for major process
modifications and for periodic review
of existing operations.
A HAZOP is a time-consuming exercise and should be conducted in
such a way to ensure that the results
justify the effort. This article presents
some common mistakes that can
jeopardize a HAZOP teams task. Frequent or chronic occurrence of these
mistakes indicates potential gaps in
the sites process-management system. However, it is ultimately the responsibility of the HAZOP facilitator
54

FIGURE 1. HAZOP studies are useful tools in reducing process risk, and they provide safeguards against
hazardous scenarios for the personnel who must maintain and operate the plant

to correct these mistakes if or when


they occur during the course of the
HAZOP study. Therefore, the selection of an experienced facilitator is
an essential element for assuring the
success of the HAZOP. Without an
adequate depth of knowledge and
experience, the HAZOP can become
a check the box exercise.
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Benefits of a HAZOP
The advantages offered by HAZOP
over other process-risk analysis
tools are numerous, and include
the following:
It is a rigorous process; it is structured,
systematic and comprehensive
It is adaptable to the majority of CPI
and manufacturing operations, in-

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cluding those in petroleum refineries (Figure 2) and other oil-and-gas


processing plants, nuclear facilities, and specialty chemical, pharmaceutical and even high-speed
manufacturing plants
It is team-based and allows the
interchange of knowledge and experience between the participants
It helps to anticipate potential accidents or harm to employees, the
facility, the environment and the
surrounding community
It functions as a type of training for
the teams participants and leader,
who are required by the nature of
the method to look at the process
from a new perspective not just
from the perspective of how should
it run?, but also how can it fail to
run correctly?
A HAZOP is time-consuming because it requires the participation
of a multi-disciplinary team over extended timeframes. This investment
of time and personnel, often involving third parties, means that the performance of the HAZOP needs to be
optimized to maximize its value. The
following sections detail some commonly found mistakes that occur
during the planning, execution and
followup stages of a HAZOP.

Planning stage
Mistake 1: Mismanagement of
time-allotment issues. One of the
most frequent mistakes of a HAZOP
is failure to manage the time allotted for the study. A HAZOP is often
scheduled for a set amount of time,
neither by the HAZOP facilitator nor
the team, and sufficient time may not
have been allocated. Furthermore,
there may be little or no flexibility in
the schedule. An insufficient amount
of time for the HAZOP limits discussion and brainstorming and reduces
the quality of the analysis, in turn
leading to some of the mistakes discussed in more detail below.
Estimating the duration of a
HAZOP is not an exact science, and
it requires a good knowledge of the
methodology, the complexity of the
process, the nature of the risks that
can be identified up front and the idiosyncrasies of the group. Although a
HAZOP should not be open-ended in
time allotment, the ideal HAZOP has
some flexibility built into the schedule. The team leader should make an
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FIGURE 2. Many processes in the CPI are potentially hazardous if not managed correctly. HAZOP studies
seek to prioritize actions to reduce process risks, and are adaptable across a wide range of
industrial sectors

estimate of the time required for the


team based on the process description and preliminary count of HAZOP
nodes (specific portions or topics of
the study process) so that managers
are aware of the degree of personnel
commitment that will be required.
Mistake 2: Incomplete, inaccurate
or unavailable process safety information. Another common mistake during a HAZOP is not having
all the prerequisite process safety
information (PSI) and other valuable
information available, including outof-date or incomplete information.
This is especially critical regarding
piping and instrumentation diagrams
(P&IDs), current standard operating
procedures (SOPs) and appropriate
data on flammability, combustibility,
reactivity, toxicity and electrostatic
properties of materials in all forms
and phases, as well as compatibility of chemicals with each other and
with the processing equipment. If the
HAZOP is conducted by an external
facilitator, it is the responsibility of the
owner of the process to verify the integrity of the PSI.
Related to this, it is not acceptable
that participants attend the HAZOP
for the purpose of obtaining information on a process or project. HAZOP
participants should be well prepared
to contribute to the discussion and
have all requisite background information with them. It is the responsibility of the facilitator to instruct all
participants that they must come to
the HAZOP prepared.

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Mistake 3: Incorrect size of HAZOP


team. The HAZOP team should be
limited in size, ideally five to seven
people, excluding the HAZOP facilitator and the HAZOP scribe or secretary. A team that is too large can
easily lose focus, dwell on a subject
or issue too long, or be disruptive. It
is human nature that all participants
seek to present their perspectives,
but this can lead to excessive discussion. A group that is too small will
not likely include the right expertise
or provide enough different perspectives to evaluate the process hazards and controls adequately or in
the right detail.

Execution stage
Mistake 4: Lack of focus during
the meeting. A HAZOP is a complex exercise that requires the concentrated and coordinated contribution of all the members of the team.
Distractions should be minimized
in order to ensure and maintain the
teams focus. Therefore, team members should not be allowed to come
and go into and out of the meeting,
take phone calls, answer emails,
or discuss issues not related to the
HAZOP during the sessions. Use of
an offsite venue may be helpful to
prevent plant operations from becoming a distraction.
It is the responsibility of the HAZOP
facilitator to maintain the focus of the
group and keep the HAZOP process
moving by allowing some open discussion on the issue, node and con55

FIGURE 3. It is crucial that a HAZOP be explicitly targeted for the specific process in question, and not
based on previous HAZOPs for similar processes, as process safety information and controls may have
recently changed

sequence at hand, but not letting it


get out of control. Sufficient (but not
excessive) breaks for participants to
eat and drink and conduct activities
not related to the HAZOP, such as
checking their emails and voicemails, should be planned and coordinated. The HAZOP room should
be free from cellphones, and distractions like texting during the HAZOP
exercise should be forbidden.
Mistake 5: Preventing the team
from brainstorming. Another frequent mistake in HAZOPs is to restrict the brainstorming exercise,
which is, after all, the basis (and the
power) of the method. The most
common issues in this area include
the following:
Omitting key words, parameters
or even nodes, with the argument
that an upper bound for the consequences in this node can be
easily identified, and these maximum consequences are protected
by safeguards. This clearly means
that steps or phases of the HAZOP
procedure will be skipped, and
some process hazards may not be
identified. This violates the HAZOP
methodology and overall purpose
of conducting the HAZOP in the
first place. Although on many occasions, strict application of the
methodology will not identify any
hazardous scenarios other than the
obvious ones, which have already
been listed up front and used as
an argument for omitting any further analysis. Nevertheless, sometimes a non-obvious scenario will
56

be identified that constitutes the


purpose of the HAZOP, and this is
where it demonstrates its power
Carrying out a superficial review of
the combinations of key words and
parameters, listing the most obvious, and often repetitive, causes of
deviation without going into detail.
In other words, repeating the same
causes, parameter after parameter
and node after node, instead of
conducting a more in-depth analysis and discussion
Carrying out HAZOPs using some
form of prior information prebuilt templates or the HAZOP
from a similar project, for example.
Again, what the HAZOP is meant
to do is analyze the possible specific risk scenarios (especially the
non-obvious ones) of the process
or project being studied at the time
of the HAZOP (Figure 3). While one
can refer to, or reference previous
material, the HAZOP is to be conducted based upon the current
facility or process, and the equipment, process or controls may have
changed since the last HAZOP
In practice, the quality of a HAZOP
is influenced by the ability of the
HAZOP leader to ask the appropriate questions to ensure that the
team identifies all the hazards of the
process being studied, not only the
most obvious hazards. This ability
is based on the leaders experience
with the HAZOP technique and his or
her technical skills in process-hazard
identification, as well as human error
and equipment failure potential. It is
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the responsibility of the HAZOP facilitator to manage the team and


the HAZOP study process to ensure
that the team stays focused and that
no nodes or hazards are missed by
the team.
Mistake 6: Mistaking the tools for
the process. The HAZOP spreadsheet should not be viewed as a
questionnaire whose boxes all have
to be filled in, even with numerous
repetitions of scenarios. The combination of pairs of key words and parameters is not intended to be an end
in itself, but to encourage discussion
and identify deviations from the desired state. As would be expected,
the same deviation generally causes
the alteration of more than one process parameter, and therefore could
be entered in more than one place in
the spreadsheet. An obvious example is a distillation column, in which
pressure, temperature, composition
and flowrate (of reflux, for example)
are clearly interrelated. Hence, any
change in one of the parameters
automatically causes responses and
changes in the others.
It is not as important for all the
spreadsheet boxes to be filled in
as it is for the HAZOP group to work
effectively in identifying all the possible deviations. A HAZOP table is
not and should not be a form-filling
exercise. Rather, it should guide and
structure strategic brainstorming discussion with the intent of identifying
all hazards and operability problems
that may injure employees (Figure 4),
cause damage to property and assets, impact the community or cause
environmental damage.
Mistake 7: Misrepresenting or
misunderstanding
safeguards.
Documentation of effective and appropriate safeguards is a key step
in the PHA teams decision whether
additional process-risk reduction
is required for a specific scenario.
Examples of safeguards that are
neither effective nor appropriate are
given below:
Local instruments that are never
checked by field operators
Alarms that fail to give the operator
sufficient time to effectively halt the
consequences of the deviation.
Examples include the following:
Alarms that fail
Very generic alarms that are
activated in numerous differ-

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ent situations. In this case,


the operator has to diagnose
which of the multiple options he or she is faced with,
thereby losing valuable time
for action
Alarms that are activated frequently, often for trivial reasons,
and that therefore tend to be
ignored by the operators
Alarms where no specific
operator
response
has
been given in procedures
and training
Cascades of alarms, where
first-in is not obvious
or indicated

Pressure-relief systems (such as


safety valves and rupture discs) that
were not designed for the case and
process conditions being studied.
Obviously, the purpose of a HAZOP
is not to verify the correct design of
pressure-relief systems. Nevertheless, if there is reasonable doubt,
a recommendation should be issued to check that the scenario for
which it was listed as a safeguard
was one of the cases of design for
the relief device or system
Operating procedures cannot be
considered safeguards when the
cause giving rise to the scenario is
human error, which presupposes
that the procedure has not been followed properly
Mistake 8: Excessive recommendations. Some HAZOP groups believe that they should issue a recommendation for any scenario that has
negative consequences, whether a
hazard scenario, equipment failure or
operability problem. This is not in the
spirit of the HAZOP method. What a
HAZOP aims to do is identify all of
the hazardous scenarios, determine
the associated risk for each particular scenario and check whether the
process has been duly protected by
the safeguards, and only if there is
not adequate protection, propose
recommendations for doing so.
Mistake 9: Irrelevant recommendations. Sometimes, people will
suggest and utilize HAZOP recommendations as a way to obtain approval for an operational or plant
design improvement that is not necessarily directly related to the safety
of personnel or the release of a hazardous chemical. In many cases,
these changes have already been
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evaluated and ruled out for various


reasons. While a HAZOP can and
should include recommendations related to operational and maintenance
issues, the HAZOPs sole intent is for
the identification of issues, not to find
a solution to the problems or redesign the facility. All recommendations
are made for further investigation and
design considerations. Therefore, the
actual HAZOP is not the best time
or place to deal with these types of
issues. They should be further investigated offline in the correct setting,
and should include the appropriate
personnel in the discussions.
Mistake 10: Excessively lax recommendations. When making recommendations in a HAZOP, it is very
important to utilize the proper wording. Since the HAZOP team is composed of knowledgeable people,
recommendations should be made
that involve action. Two words that
are highly over-utilized are recommend and consider. Recommend is already used in the title for
the column and most of the time, the
teams brainstorming makes up the
consideration aspect of the recommendation being proposed. If additional risk analysis is required, consider is an appropriate phrase.
There are often multiple ways to reduce risk and the teams time should
not be spent analyzing alternatives.
Another common phrase seen in
many HAZOP recommendations is
Further study on what needs to be
done in order to... which in reality
is not specific and can be left open
for interpretation. Most of the time,
recommendations that involve an
action and have a specific purpose
should be made. Start recommendations with strong action words,
such as install, investigate,
graph, or add. Additionally, when
wording recommendations, if a recommendation is being made for a
specific reason, include that reason
in the recommendation so it is not
forgotten when the HAZOP report
is written or is being reviewed. The
following are good examples of wellworded recommendations:
Install a pressure gage and transmitter on the overhead line L12 of
the distillation column to increase
the SIL level from 1 to 2
Graph the P/T curve for the reaction process and add the accept-

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FIGURE 4. HAZOP studies intend to provide a comprehensive index of the hazards and operability
problems that may cause damage or put employees in danger

able operating range. Utilize this


chart to set appropriate process
alarm and shutdown points
It should be noted how these two
recommendations are very specific
action items and also include the
reason for the action.
On some occasions, there may
be two or more divergent opinions,
and a consensus cannot be reached
during the HAZOP itself. In this case,
both recommendations should be
included in the HAZOP and left for
further investigation or evaluation
by the company, based upon the
information from the HAZOP. For
scenarios such as these, the best
solution after further investigation
and research is completed may
be something not even mentioned or
thought about in the HAZOP itself.
Again, it should be reiterated that
except for a few unique situations,
such as the divergent opinion case,
recommendations should be clear,
specific, not open to interpretations
and include the reasoning at the time
that the HAZOP was conducted.
Mistake 11: Trying to solve the recommendation or design the solution during the HAZOP. Another
common mistake that can delay the
HAZOP and cause the group to lose
its focus is trying to solve the problem or redesign the process listed
in the recommendation during the
HAZOP study itself. This is most
common when process-design engineers are team members and they
desire to make the process perfect.
Unless it is a clear and easy solution,
many recommendations require further investigation or other actions to
complete the task, alleviate or minimize the hazard, and close out the
action item based upon the recommendation. It must be remembered
that a HAZOP is a brainstorming
57

exercise with knowledgeable process personnel from different areas


of the plant, whose task is to identify
hazards or hazardous scenarios and
make practical recommendations
to alleviate or minimize the hazardous scenarios or consequences.
As previously stated, not all recommendations have clear-cut solutions,
and the HAZOP time should not be
wasted with actions that may require
research and further investigation
that only one of the participants, or
a qualified expert, can resolve in the
quiet of his or her own office. Even
HAZOP-recommended changes to a
process should be subjected to the
sites management-of-change (MOC)
process to prevent the introduction
of new hazards. It is not uncommon
for an incident to be triggered by a
change made for safety reasons.
The HAZOP can and should result in
a list of actions or recommendations,
with the designation of someone responsible for carrying them out, but
not necessarily the final solution or
re-engineering of the plant.

Followup stage
The output of the HAZOP study is
the set of recommendations that are
usually presented to management in
a standardized report format. At this
stage, site management is responsible for responding to each recommendation according to local or site
requirements and the requirements
of applicable standards, such as the
U.S. Occupational Safety and Health
Administration (OSHA) Process Safety
Management (PSM) standard Title
29, CFR Part 1910.119. Site procedures should include regular followup
reports to track recommendations
to their resolution.
Mistake 12: Failure of management to act promptly on each recommendation. Site management
must evaluate each recommendation
according to its technical feasibility,
the risk-reduction benefit versus total
cost of implementation, availability of
alternative solutions and other factors. The PSM standard allows rejection of a PHA recommendation only
for specific causes. Good industry
practices dictate that management
takes prompt action on each recommendation and ensures that all recommendations are tracked to final
resolution and closure.
58

Mistake 13: Failure to update


HAZOPs when process knowledge
changes. A HAZOP worksheet is a living document. Ideally, it reflects managements current knowledge of the
process hazards, the consequences
of those hazards and the controls
necessary to reduce the process risk
to a tolerable level. HAZOPs lose their
effectiveness over time when they are
not updated promptly.
Changes in process safety information should result in a PHA review
through the site MOC procedure. The
review will identify any new causes of
a process deviation or operability issues, changes in safeguards for previously documented hazard scenarios,
and possibly new or revised recommendations to address the hazards.
Recent accidents or near misses
on a site process, or a similar process
elsewhere, should trigger a HAZOP
review to ensure that the same or
similar scenario has already been
considered and documented during the most recent HAZOP and that
effective controls are in place to prevent a similar incident from occurring
in the future.

Additional applications
For the sake of simplicity, this article
has focused on common mistakes
observed during the use of the HAZOP
methodology. The discussion in this
article can be equally applied to other
scenario-based methodologies, such
as what-if analyses, which can be
carried out at very early stages of the
process lifecycle HAZOP is typically reserved for late-design stage
or later-lifecycle stages when more
detailed PSI is available. The specific
PSI that is available and the expertise
needed for other hazard evaluation
methodologies may be different, but
the types of mistakes discussed here,
and their prevention, are very similar.

Closing thoughts
OSHA recognizes the HAZOP technique as an acceptable methodology
for conducting PHAs of processes
covered by the PSM standard. Other
regulators around the world also accept the HAZOP methodology as
appropriate for analyzing the existing and potential hazards of a complex process that involves a highly
hazardous substance.
The HAZOP methodology repreCHEMICAL ENGINEERING

sents an extremely powerful tool for


the identification, semi-quantification
and mitigation of risks in CPI production facilities with continuous, batch
or semi-batch processes.
The biggest inconvenience of this
technique is its relatively high cost, in
terms of time and people who need
to be involved and participate in the
brainstorming sessions. This high
cost means that the HAZOP needs
to be carried out to optimum effect,
avoiding the sorts of mistakes that
have been discussed in this article. It
is the responsibility of the HAZOP facilitator to make sure the group stays
focused and does not commit any
of these mistakes. Finally, the selection of a knowledgeable and experienced PHA facilitator is a crucial element for assuring the success of the
n
HAZOP process.
Edited by Mary Page Bailey

Authors
Arturo Trujillo is managing director of Chilworth Amalthea, the
Spanish subsidiary of the process
safety division of DEKRA (Npols
249, 4 planta 08013 Barcelona,
Spain; Phone: +34-931-426-029;
Email: arturo.trujillo@dekra.com).
He has facilitated more than 200
HAZOPs, and his specialities include SIL and LOPA. Prior to working at Chilworth, he served as a division manager at
Technip Iberia and as engineering director at Asesora
Energtica. He attended Universitat Politcnica de Catalunya and received a Ph.D. from Johns Hopkins University.
Walter S. Kessler is a senior process safety consultant at Chilworth
Technology Inc. (113 Campus
Drive, Princeton, NJ 08540;
Phone: 832-492-4358; Email:
walter.kessler@dekra.com).
Kessler has 20 years of experience in the petroleum refinery,
gas-processing, specialty-chemical, pharmaceutical, manufacturing and HVACR (heating, venting, air conditioning and
refrigeration) industries, including five years performing
process-safety engineering functions. He was instrumental in the design and construction of several refinery, gas and chemical processing facilities, designing a
pharmaceutical filling process and also has experience
in Six Sigma and lean manufacturing.
Robert L. Gaither is a senior process safety specialist at Chilworth
Technology Inc. (113 Campus
Drive, Princeton, NJ 08540;
Phone: 732-589-6940; Email:
robert.gaither@dekra.com).
Gaither has more than 28 years of
experience in company operations,
regulatory compliance, management consulting and process
safety and risk management. He has led organizations at
site, division and corporate levels to achieve record
safety performance and significant cost savings. Gaither
is trained in HAZOP and SIL/LOPA facilitation. He holds a
Ph.D. and is a certified safety professional (CSP).

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