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THE FIVE PITFALLS IN MANAGING

SAFETY CRITICAL ELEMENTS (SCE)
Published on September 28, 2015

Messaging

Paul Stam

Paul Stam
Sr. Consultant Asset Integrity Management at Stork Technical Services 4 articles Follow
Nederland

Asset Management Consultancy

What are SCE?

Safety Critical Elements (SCE) in the Chemical and Oil and Gas Industry are directed by a
set of (regulatory) requirements for managing physical or non-physical elements. These
elements (e.g. safety valves, lockout-Tagout procedures) represent safety barrier identified
by their purpose to prevent, control, respond or mitigate the effect of a safety or
environmental Major Accident (MA).

Why are SCE important?

The main purpose of identifying SCE and the related performance standards is to develop a
focus on critical equipment and procedures. The idea behind SCE is that it is much more
effective to manage a smaller number of unambiguous defined elements than to try to deal
with everything that can be related to safety. Most companies are not able to manage their
safety risk effectively without a structured approach and the reduction of complexity. The
SCE methodology will constitute a considerable foundation to the management of these
safety risks by the clear approach of the methodology and focus on the safety elements that
really matter if taken into account the five most common pitfalls.

The five pitfalls 

1.  SCE are not defined by assessing the probability of failures and threats.

Often we do not have hard evidence to determine the probability of hazardous events, but
we can determine the consequences of a failure or threat. Moreover In most risk based
models the probability is considered null if a hazardous event have not taken place in the
past. Of course is this no safety guarantee for the future and there is so a probability of risk.
On the other hand, from a maintenance perspective it will not be in conflict with risk based
concepts where the probability do have a significant role. SCE identification is required so
the proper resources can be allocated and activities developed to reduce foreseeable risks.
Risk based maintenance concepts could be one of those activities imposed to keep the SCE
fit for purpose, if failure and degradation information become available.

2.  SCE are not part of the elements designed to generate production or value.

There is an important difference between the elements which are designed for production or
the reduction of value loss and those which reduces the risk of a major accidents. Where the
first depends strongly on the economic and financial circumstances and targets, the SCE
may not be compromised by cutting budgets or other monetary considerations.

Secondly, in most literature SCE are also elements through which failure could cause or
contribute to a MA. This statement is questionable because even a toaster or almost all
production related equipment have the potential to cause or contribute to an MA. In most
cases fatal failure of production related equipment could cause a threat and the SCE is the
barriers that prevents the scenario that leads to a Major Accident (MA). The consequence of
using this broader definition and and misinterpretation of the relation between safety layers
(SCE) and fatal failures of production related equipment (threats) is a higher probability that
safety initiatives fail due to lack of focus and controlled complexity.

3.  SCE are not only restricted to physical equipment.

There is considerable evidence that safety procedures and the applied human safety
performance is more decisive to sustaining safety than equipment. While human induced
failures are in many cases the initial case of major accidents, equipment is often the
secondarily safety barrier to prevent or control a hazard. Moreover all failures induced by
human activities, equipment and procedures along with external threats must be considered
as a potential risk. Suitable procedures, human competencies and safety equipment must be
in place and used to avoid that a major accident.

4.  SCE identification process is more effective before commissioning.

The management of SCE is often monitored by regulatory bodies (e.g. UK, Norway, and
Denmark) introduced after the asset was built and in operation. Assessing equipment,
structures, systems and procedures and identifying SCE afterwards at this stage in the asset
lifecycle is a labor-intensive process in which a whole team of specialists (e.g. operators,
engineers, HSSE specialists etc.) is involved. In essence, this process is not as different as
other mandatory safety studies before commissioning. If the SCE requirements are clear, it is
far more logical and effective to integrate the SCE identification and the specification of its
performance standards at the commissioning stage.

5. Handling SCE is not only applicable to production and maintenance

departments.

Effective management of safety risks is strongly dependent on human capabilities. All staff
must have the competence and the motivation to prevent hazardous failures, with the correct
procedures to support. Departments who are involved in the recruitment of staff and the
outsourcing of activities are at first responsible to develop and implement procedures to
guarantee these human capabilities. Furthermore, although the introduction, monitoring and
evaluation of SCE is a primary management responsibility, safety in general is the concern
of everybody.

Finally where procedures and equipment does not replace human common sense it is also no
excuse to violate safety procedures or disregard the upkeep of SCE.

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Paul Stam 4 articles Follow
Sr. Consultant Asset Integrity Management at Stork Technical Services Nederla…
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Adebayo Selere • 3rd+ 4w

Freelance - Facilities Engineering, Process Engineering and Process/Technical Safety Consultant

Quite an interesting article.

However, in my understanding of the PHA steps by which SCEs are identified and their Performance
Standards outlined, I am of the opinion that some of the pitfalls can actually be addressed provided the
entire COMAH process are properly Operationalized. …see more

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Andrew Britten • 3rd+ 4y

HSSE Lead Advisor (East) UK at Calor Gas Ltd

I enjoyed this interesting and informative article that puts SCE into easy language. Thank you. 

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Paul Stam
Sr. Consultant Asset Integrity Management at Stork Technical Services Nederland

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