What You Need to Know About Facility Siting and Revalidation
By Michael Weinberg, ABS Group Project Manager, Advanced Engineering
What is Revalidation?
One of the key required components of the facility siting cycle is revalidation. In its simplest form revalidation is a verification of the hazards assessments and the occupied buildings, accounting for any large site changes, such as new process units. As stated in 29 CFR Part 1910.119 section e.6, revalidation is required every 5 years based on the original study’s completion date. In addition to providing a safe working environment, there are several other benefits with revalidation.
Owner/operators may have performed a variety of detailed assessments and/or preliminary hazard assessments for potential process or site changes. Revalidation provides an opportunity to combine these various studies into a single document. This can make it easier for owner/operators to maintain a clear picture of the site’s current facility siting status and avoid conflicting or overly burdensome conclusions based on separate documents that lead to unjustified or unnecessary mitigation costs.
Revalidation also provides the ability to take into account risk or hazard mitigation implementations since the previous study was issued. This also minimizes the need to maintain multiple documents to capture the site’s current facility siting status. A single consolidated document makes it easier to respond to and explain current site and remediation status to regulatory bodies (e.g., OSHA).
After the screening level study, sites may perform hazard assessments for planned new units or even a variety of preliminary units. These studies are frequently based on general layouts and process information. Even for assessments based on 90% complete models, revalidation provides an excellent opportunity to ensure that assumptions and idealized processes properly match the as-built product.
A specific timeframe for implementation of a mitigation plan is not specified in the API or CCPS guidance documents; although, CCPS points out that such implementations can take “several years” but should be implemented “promptly” like other PHA findings. So, remediation timelines can extend beyond the required 5-year revalidation cycle. Revalidation serves as a valuable tool to benchmark the progress of the remediation effort and to determine if the remediation plan needs a course-correction based on changing conditions.
Over time a site's ownership may change. New management may have different policies and standards regarding the performance of facility siting, such as different evaluation criteria or differences in adopted
Industry accidents provide lessons learned that may influence or have a direct impact on facility siting. A specific example would be the generation of API 753 for portable buildings after the 2005 BP Texas City incident. Likewise, the 2005 Buncefield accident highlighted the potential for surrounding foliage to support an unexpectedly severe VCE. All of these conditions may be a reason to evaluate and revise the existing hazard criteria.
Another value gained by revalidation is assessing the effectiveness of the MOC system to identify changes to the site that influence facility siting. MOC is a challenge for most sites to effectively keep track of changes to personnel, buildings, and processes. Effective MOC necessitates that personnel
Finally, revalidation can also incorporate lessons learned from onsite explosions, fires, toxic releases or near-misses. If an accident has occurred, it is likely that a safety system has been implemented. The safety system should be evaluated to see if it can address other previously identified scenarios. Near-misses can also be evaluated as accidents to quantify their hazard potential if not properly mitigated.
What to Expect During Revalidation
Revalidation should start with a reassessment of the current owner/operator’s policies and procedures. This is followed by consideration of historical events in
Benefits of the Facility Siting Cycle
When considered as a whole, the benefits from revalidation include:
- Consolidating various preliminary or detailed studies into a single revised facility siting study to generate a coherent picture that can enable the owner to optimize mitigation plans
- Taking credit for operational changes and mitigations implemented
- Benchmarking the progress of the facility siting remediation plan
- Evaluating and revising existing hazard criteria
- Taking advantage of modeling, software and methodology improvements to illustrate reduced hazards
- Assessing the effectiveness of the MOC system to identify changes to the site that influence facility siting
While revalidation can sometimes be treated in a cursory manner, there are many opportunities and advantages available to owners and operators during the facility siting process.
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