Regulatory confusion, fear uncertainty and doubt (FUD)
In my blog, I always try to relate to you things I am seeing and hearing in the marketplace that have an effect on how you go about resolving alarm management issues. I've lately been amused by the efforts of vendors to scare people with their interpretation of upcoming regulatory requirements.
There's a lot of FUD being distributed out there. Sales people use FUD as a short term for Fear, Uncertainty, and Doubt. FUD is a sales tactic popularized in the 70's to help non-technical sales people sell technical items. It is employed to try to frighten you into buying a product out of fear of cleverly described consequences.
In this case, it's a perceived need to meet a looming regulatory situation that may or may not exist. Lately, I have been bombarded with questions about these looming regulatory issues, and some competitors have begun to sow the seeds of doubt (D) about whether you will be able to meet these regulatory requirements. Canadian vendors tend to do that. They must have a lack of regulations up there in the tundra. It's always exciting to a vendor when they believe you might be required to buy their product by legal mandate. And at this point in time, there are several vendors lurking and hoping that you will be forced to buy something from them soon. So, without selling the issue short, I will try to allay those fears, and tell you what might be coming, and how you should prepare to deal with it.
Firstly, most government regulations follow the guidelines of "best practices" or "most available" technology. There is a term often overused called RAGAGEP. It stands for Recognized And Generally Accepted Good Engineering Practice. This is what the government expects of you- nothing more and nothing less. OK- sometimes they stretch a bit and get into practicing some "political" science that doesn't necessarily conform to thermodynamic principles, but that's it for the most part. So, assuming I'm talking to good engineers, I will continue with what that might mean in the area of alarm management, with a light on previous regulations.
I will start by highlighting some past regulations with which we should all be familiar. Let's look at drug testing. The government did not tell us HOW to do drug testing when they started requiring its presence in the workplace. Instead, they said essentially "make a plan" and "work that plan". And here are some guidelines about what we think works. So, at small companies that sell software, they adopted the policy that if somebody exhibited abnormal behavior, they would send them for drug testing. I used to have a sales manager who joked that if they did any more, they would chance losing half their staff, and perhaps would never be able to hire.
At the other end of the spectrum are companies who performed highly dangerous jobs which involved the public. They instituted a drug screen on hiring, and regular drug screenings throughout your work life. They had more at stake should an employee be at the root of a drug-related incident.
Similar to this has been environmental regulations. If you were running a plant in the middle of a highly populated area that could put out phosgene gas, or fuming nitric acid, or some other dangerous thing (like Carbon Dioxide?), then they wanted continuous monitoring of your sources to see that you would not cause a meltdown. If you were operating an 8-cylinder compression station in the middle of nowhere, perhaps you could be ignored (at least in the first round of regulations). And essentially, your need to measure was regulated by whether you were in an attainment, or non-attainment region. Yes, that had a bit of political science behind it, so we'll ignore that one.
From these, I think you can see a regulatory pattern. Alarm overload has proven to be responsible for contributing to major industrial incidents. Alarm overload needs to be watched more closely in situations where it might lead to an incident which costs human life, or health, or contributes to environmental waste. Do you operate a plant producing highly volatile chemical compounds in the middle of a municipal environment? If so, then you will need to keep a closer eye on your alarms. Do you operate a plant that may only cost you money if it shuts down? In this case, your observance of alarm management may be dependant on self-protection from capital loss. And there will be everything in between.
At a minimum, companies will be expected to quantify alarm issuance as a function of operator loading. They will be expected to show how they monitor those loads, and how they mitigate issues should they arise. There are a myriad of ways to slice that problem up. In some cases, this may mean simply counting the alarms, and issuing a report. In others, it may mean a full-blown alarm management effort with complete rationalization of processes for cause, consequence and corrective action on each alarm. It may mean all alarm priorities need to be properly set, and the alarm philosophy is available for review by inspectors should they come to your site.
I think you will be able to tell which one of these categories you operations will most likely fall into. Mostly, its just a matter of common sense. If you need a guide, examine your environmental category, and the relative amount of required regulation should be approximately on par with where you stand there compared to your peers.
In any case, as a blatant commercial statement, TIPS stands ready to serve you wherever you stand in this broad spectrum of regulatory issues. We adhere tightly to the ISA SP-18 concept that alarm management is a lifecycle issue, not just a project where you rationalize alarms and leave. We offer a full-range product suite that allows everything from simple alarm logging to full-blown alarm resolution and automated regulatory reporting systems. Call us and we'll help you get something in place that will address these issues when they begin to take effect.
I would sugest you get started with alarm logging at the very least and see where that leads you. It is not expensive, and the data it produces can prove extremely valuable for both alarm reduction efforts, and process upset forensic analysis. In any case, it will provide you the precursor data for any regulatory requirements that might be enacted down the line. It will inform you just how much work you might have ahead of you when regulations actually come into existence.
If you would like an accounting of the existing regulations, and what they might mean to you, contact us directly and we will give you our latest listing of where regulatory issues currently stand.
There's a lot of FUD being distributed out there. Sales people use FUD as a short term for Fear, Uncertainty, and Doubt. FUD is a sales tactic popularized in the 70's to help non-technical sales people sell technical items. It is employed to try to frighten you into buying a product out of fear of cleverly described consequences.
In this case, it's a perceived need to meet a looming regulatory situation that may or may not exist. Lately, I have been bombarded with questions about these looming regulatory issues, and some competitors have begun to sow the seeds of doubt (D) about whether you will be able to meet these regulatory requirements. Canadian vendors tend to do that. They must have a lack of regulations up there in the tundra. It's always exciting to a vendor when they believe you might be required to buy their product by legal mandate. And at this point in time, there are several vendors lurking and hoping that you will be forced to buy something from them soon. So, without selling the issue short, I will try to allay those fears, and tell you what might be coming, and how you should prepare to deal with it.
Firstly, most government regulations follow the guidelines of "best practices" or "most available" technology. There is a term often overused called RAGAGEP. It stands for Recognized And Generally Accepted Good Engineering Practice. This is what the government expects of you- nothing more and nothing less. OK- sometimes they stretch a bit and get into practicing some "political" science that doesn't necessarily conform to thermodynamic principles, but that's it for the most part. So, assuming I'm talking to good engineers, I will continue with what that might mean in the area of alarm management, with a light on previous regulations.
I will start by highlighting some past regulations with which we should all be familiar. Let's look at drug testing. The government did not tell us HOW to do drug testing when they started requiring its presence in the workplace. Instead, they said essentially "make a plan" and "work that plan". And here are some guidelines about what we think works. So, at small companies that sell software, they adopted the policy that if somebody exhibited abnormal behavior, they would send them for drug testing. I used to have a sales manager who joked that if they did any more, they would chance losing half their staff, and perhaps would never be able to hire.
At the other end of the spectrum are companies who performed highly dangerous jobs which involved the public. They instituted a drug screen on hiring, and regular drug screenings throughout your work life. They had more at stake should an employee be at the root of a drug-related incident.
Similar to this has been environmental regulations. If you were running a plant in the middle of a highly populated area that could put out phosgene gas, or fuming nitric acid, or some other dangerous thing (like Carbon Dioxide?), then they wanted continuous monitoring of your sources to see that you would not cause a meltdown. If you were operating an 8-cylinder compression station in the middle of nowhere, perhaps you could be ignored (at least in the first round of regulations). And essentially, your need to measure was regulated by whether you were in an attainment, or non-attainment region. Yes, that had a bit of political science behind it, so we'll ignore that one.
From these, I think you can see a regulatory pattern. Alarm overload has proven to be responsible for contributing to major industrial incidents. Alarm overload needs to be watched more closely in situations where it might lead to an incident which costs human life, or health, or contributes to environmental waste. Do you operate a plant producing highly volatile chemical compounds in the middle of a municipal environment? If so, then you will need to keep a closer eye on your alarms. Do you operate a plant that may only cost you money if it shuts down? In this case, your observance of alarm management may be dependant on self-protection from capital loss. And there will be everything in between.
At a minimum, companies will be expected to quantify alarm issuance as a function of operator loading. They will be expected to show how they monitor those loads, and how they mitigate issues should they arise. There are a myriad of ways to slice that problem up. In some cases, this may mean simply counting the alarms, and issuing a report. In others, it may mean a full-blown alarm management effort with complete rationalization of processes for cause, consequence and corrective action on each alarm. It may mean all alarm priorities need to be properly set, and the alarm philosophy is available for review by inspectors should they come to your site.
I think you will be able to tell which one of these categories you operations will most likely fall into. Mostly, its just a matter of common sense. If you need a guide, examine your environmental category, and the relative amount of required regulation should be approximately on par with where you stand there compared to your peers.
In any case, as a blatant commercial statement, TIPS stands ready to serve you wherever you stand in this broad spectrum of regulatory issues. We adhere tightly to the ISA SP-18 concept that alarm management is a lifecycle issue, not just a project where you rationalize alarms and leave. We offer a full-range product suite that allows everything from simple alarm logging to full-blown alarm resolution and automated regulatory reporting systems. Call us and we'll help you get something in place that will address these issues when they begin to take effect.
I would sugest you get started with alarm logging at the very least and see where that leads you. It is not expensive, and the data it produces can prove extremely valuable for both alarm reduction efforts, and process upset forensic analysis. In any case, it will provide you the precursor data for any regulatory requirements that might be enacted down the line. It will inform you just how much work you might have ahead of you when regulations actually come into existence.
If you would like an accounting of the existing regulations, and what they might mean to you, contact us directly and we will give you our latest listing of where regulatory issues currently stand.
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