Consolidation of Peruvian Process Safety Standards and Regulations for the Hydrocarbon Production and Processing Industries

Massive growth in natural gas and associated hydrocarbons brought state-of-the art technology to the on-shore production and processing of these natural fossil fluids in Peru since the early 2000’s.

Peruvian legislators and regulators were challenged to adapt existing local legislation to meet the requirements of reducing inherent hazards and safety risks at the design, startup, and routine operation stages of these new industrial plants.

As a result, there are a few of old local standards and legislation, some were partially modified, and also newer locally issued standards and legislation meant for just specific units of the hydrocarbon production and processing operations.

Worldwide the consensus since mid 1980’s has been to consolidate all industry process safety regulation under one body of standards and norms to ensure methodical approach to every industrial development since its inception at the drawing board.

It is our proposal to consolidate the Peruvian standards, regulations and legislations to achieve the highest possible quality standards of process safety according to the latest standards available to the industry.

It is our understanding that it becomes a common problem to many development nations in that national regulations applied to industrial safety is usually separated into several different bodies of legislation, issued during several decades, mostly citing industry standards that might be dated. This is the current case in Peru, and most likely applies also to many countries in similar developmental situation. E.g. Argentina, Brazil, Bolivia, Ecuador, to mention some of them.

Since many of the participants of this CCPS event, have their professional practice in some of these countries, and we feel it could be of their interest to consider this concept of an all encompassing regulation covering the need of reducing the hazard and risk exposure of industries related to chemicals and hydrocarbons.

This study has considered existing Peruvian standards and legislations, as it stands applicable to the hydrocarbon extraction, production, transportation, fractionation, refining, and industrial distribution for intermediation and industrial users.

The stepping-stones for an all-encompassing body of process safety normative are the recognized and generally accepted good engineering practices (acronym RAGAGEP). In Peru as in most developing nations current legislations for safe design of process installations apply the widely accepted North American engineering standards, like published by:  ASME, API/ANSI, ASTM, IEEC, NFPA, NACE, AIChE.

This paper utilizes the same philosophy adopted in many industrial nations around the world by developing a local Safety Process Management standard regulation, starting with the keypoints found in API RP 750, 29 CFR 1910.119, 40 CFR 68, USA-EPA RMP, UK-COMAH 2015, and UE Directive 18-2012 (SEVESO III)

The proposed sequence of process safety implementation is in part based on the model adopted by Australia on HIPAP Number 9 – Safety Management – 2011:

I) PRELIMINARY IDENTIFICATION OF HAZARDS AND RISKS ASSESSMENT

II) SAFE PROCESSES AND OPERATION DESIGN

III) SAFETY DURING CONSTRUCTION, COMMISSIONING AND STARTUP

IV) OPERATION AND MAINTENANCE SAFETY MANAGEMENT

V) EMERGENCY PROCEDURES AT HAZARDOUS INDUSTRIAL FACILITIES

VI) PROCESS SAFETY INDEPENDENT AUDITING: LEADING AND LAGGING INDICATORS, AUDIT PROCEDURES AND FOLLOW-UP

VII) DE-COMMISSIONING AND ABANDONEMENT SAFETY PROCEDURES

VIII) PROCESS SAFETY CERTIFICATION AND CERTIFICATION RENEWALS FOR HAZARDOUS INDUSTRIAL FACILITIES

IX) BOUNDARIES, LIMITATIONS, AND DEADLINES APPLICABLE TO NON-CERTIFIED HAZARDOUS INDUSTRIAL FACILITIES

X) PERMANENT COMMISSION FOR INDUSTRIAL PROCESS SAFETY MANAGEMENT REGULATION IMPROVEMENT