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HSE Design Reviews and Action Close-out

HSE design reviews and the management close-out of resulting actions are an important part of an engineering project lifecycle and may incur the expenditure of a substantial number of man-hours.

The close-out of actions from HSE design reviews may require changes to be made to the developed plant design (rework) or require the incorporation of additional safeguarding measures, both incurring additional project cost and potentially delay to project schedule. Approaches to managing action close-out including the use of a risk register, are considered.

Failure to adequately prepare for HSE design reviews, poor review execution, and/or poor follow-up can, if not adequately controlled, result in significant disruption to a project, leading to delays in the project schedule and additional man-hour expenditure.

HSE Design Reviews and Action Close-out service flowchart showing project phases: PreFEED, FEED, Detailed Design, Construction, Commissioning, and Operating, with reviews such as HAZID, HAZOP, and Safety Review.
Project phases and associated reviews

A design project typically progresses through a number of phases, with each phase developing a more detailed design. At a number of points in the project, design HSE reviews are conducted. For illustration, an overview of typical project phases and some of the associated design HSE reviews is shown in Figure 1. A summary of some of the different types of HSE design reviews is provided in Table 1.

A table outlining HSE design reviews across project phases, including FEED and Detailed Design, focusing on hazard identification and operability using key documents like flow diagrams, plot plans, and safeguarding narratives

Action close-out

Successfully completing a review is not enough, the review actions then need to be closed or the review will not have achieved its objectives.

Management of Actions

While some review actions can be implemented almost immediately after a review, others cannot be closed until much later in the project. Any method of tracking action close-out needs to recognize this to be effective. Simply circulating lists of actions open for more than three months is not effective if some actions may not be closed for 15 months. The identification and expediting of open actions needs to be done on the basis of the required close-out date.

Actions need to be auditable. The recorded response to an action should provide information on how the action was implemented, what documents and drawings were updated, and when. Actions also need to be appropriate. Review actions are distributed to the relevant engineers for close-out, with the interpretation of the action often left to the individual engineer, especially if he/she was not present in the review. A check is therefore needed that the action close-out is an adequate response to the action. This check may be a review by the project design safety engineer, but some projects have more rigorous assurance involving review and sign-off of each action by the client and contractor. The approach should be decided early enough to ensure that adequate resources are in place at the right time.

Management of change

In almost all projects, the design continues to develop after each HSE design review is completed, and each design modification threatens to introduce new hazards and invalidate earlier reviews. An effective management of change process is required to safeguard the integrity of the design. Each proposed design change needs to be subjected to review before implementation, and where required, a HAZOP team should be reconvened to assess the change. Reconvening the same team may be difficult.

When the project reaches the end of the design phase, a final safety review is required. The purpose of the Final Safety Review is to confirm that all of the project design has been subjected to HSE design review, all design-related actions have been closed and all design changes post review have been subjected to a management of change review. This review should include an audit of the project’s management of change procedure for assurance that the procedure has been implemented effectively on the project. It is important that any field changes are also subject to review, and they occur after a ‘Final Safety Review’.

Some of the review actions may be for implementation by the operating company and fall outside the main project scope, and some means of transferring these, and the responsibility for their closure, to the operating company will be needed. A record of their transfer is also needed. Even after transfer, it may be prudent to continue to monitor these actions and remind the client of the need to close all actions.

After the project moves into the construction phase, further design changes may be made by the site engineering team, and therefore an effective management of change is required to the point of handover to the client. If the site team does not have sufficient technical capability and knowledge of earlier project design HSE reviews, then continuing support of the management of the change process will be required from the original design team to ensure an adequate assessment of the impact of changes.

Finally, before plant start-up is the pre-startup safety review. It is recommended this review should include another Final Safety Review focusing on the management of change since the earlier ‘Final Safety Review’ and the close-out of remaining actions relating to start-up and operation.

Conclusions

HSE Design Reviews are an important part of a project, and their successful execution requires much effort, skill and experience.

Elixir Engineering personal consider the below points as key requirements to conduct an effective review: 

  • The review meeting is the tip of the iceberg: do not forget that more resources are needed for the preparation beforehand, the issuing and updating of review reports and the significant effort in closing-out actions.
  • Team composition is key to an effective review: for a good review the knowledge must be in the room.
  • There are many different forms of design HSE review. The purpose of the review and the review methodology must be clearly communicated to all attendees.
  • Do not change objectives part way through a review. Agree on the purpose and approach to the review before the review starts, and agree on the approach to action close-out.
  • HSE design reviews consider the HSE aspects of the design. They are not intended to be design reviews and if they turn into design reviews the effectiveness of their intent is compromised.

Elixir Engineering follows internationally accepted best practices listed above through the development and use of its own engineering procedures. These include:

  • A procedure defining the requirements for engineering reviews at each project phase.
  • Procedures for each type of engineering review. For example, a procedure for HAZOP addressing requirements for attendees, team members’ roles and responsibilities, methodology for batch and continuous reviews, and action close-out.  
  • Procedures for the management of change during the design, construction and commissioning phases, including Final Safety Review and Pre-Startup Safety Review.

The use of procedures ensures that current best practice is followed and allows for the continuous review and development of work practices. Knowledge gained can be captured, encouraging better project execution and safer plant design.

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