Let me unpack that statement with you. 

Throughout an Australasian operating facility’s life, it is required to have its risks in a SFARP / SFAIRP state. That is, their risks are eliminated or reduced so far as is reasonably practicable. 

Let’s assume we started out strong, having entered operations with a clear understanding of our risks and controls, and with a design that had been demonstrated to be SFAIRP. How do we proactively stay there? 

What we do budget for

• One. We budget, schedule, implement and govern our proactive maintenance processes for our controls. 
• Two. We budget, schedule, implement and govern our training to keep our competencies healthy for operating plant, maintaining plant, modifying plant, and emergency preparedness. 
• Three. We carry some corrective maintenance budget and prioritise repairs of critical controls. 
• Four. We budget for those years we know that we need to revalidate our safety assessments (hazard analyses, bowties, etc.) In revalidating our assessments, we go through SFAIRP demonstration, and we identify gaps
• Five. We proactively audit process safety processes and controls, we investigate process safety events, and we identify gaps. 

What is the real issue?

Gap closure requirements from items 4 and 5 break the budget.  

They prompt some of the most challenging conversations. Why? 

As we step through SFAIRP assessments years into operations, we find that the answers to questions we had previously asked ourselves about our risks, have CHANGED, and we are no longer at SFAIRP. So, we need to ask for resource to move our facility to a SFAIRP state. That’s the law. And more importantly, that is the ethical thing to do. 

It is at this point that we are commonly faced with the frustration of others who don’t understand why a facility that was good enough to put into operation several years ago, no longer ‘cuts the mustard’. (Frustration arises too, that 'capacity to pay' is not a consideration for SFAIRP.)

Then the exhausting budget justification efforts begin for subsequent years to enable the prioritised risk reductions to be implemented. Quite often, with a residual disgruntled sentiment towards the process safety engineer that always asks for more, continuing to permeate each time one of those projects is discussed. 

Hence, I believe that no one is truly budgeting for SFAIRP – proactively. 

There a pervasive belief that a SFAIRP design, maintained to its design, remains SFAIRP for perpetuity.

Where is this written? Where is this taught? This is not fair on the process safety advocates who have to debunk such a myth, often repeatedly. I am still ruminating on possible root cause for this belief existing. Is it linked to perspectives brought from prescriptive regulatory regimes? Regardless of its source, the belief needs to be dismissed.

THIS online INTRODUCTION TO BOWTIES course is suitable for anyone who may use or develop bowties.	Find out about our upcoming DEMONSTRATING SFARP/SFAIRP training course HERE!	Our 2-day HAZOP LEADER course is IChemE approved, find out more HERE!

What should we anticipate?

Why do I believe that we should always expect the SFAIRP goalposts of individual risks to shift? 

• What we know about the hazards with which we work, does change with time. Incidents occur internally and externally, and learnings are shared. We find risks we may not have previously been aware of, or existing risks are now understood better, and their ranking changes. Whenever a major incident investigation report or its learnings are shared, we should proactively be assessing whether the knowledge we have gained that is relevant to our processes warrants change to maintain SFAIRP.

• What is required were you to be building against current standards and codes, that impact process safety, will change with time. Standards and codes are updated from industry experiences, and sadly, often learning from loss events. Can a business afford to learn the same lesson? Whenever a standard or code relevant to our facilities' design bases is updated, we should proactively be assessing whether the update warrants change to maintain SFAIRP.

• Similarly, industry good practice evolves with time. We may claim how great we are to our shareholders, but may have diverged a fair way from ‘good’ without realising until we asked the deliberate question. Keep connected to industry and the improvements others are making that you can learn from and adopt. 

• Technology advances rapidly, and the tools to control risk do get better, and cheaper. What was not reasonable nor practicable several years ago, may actually now be of significant value. Be willing to challenge whether your knowledge of costs and available technologies is actually current. Things that may not have been reliable in service decades ago, (e.g. gas detectors), may now actually be remarkably effective. Stay up to date. Or at least be willing to be updated by those in your organisation that know. 

Where to next?

If you are struggling to navigate SFAIRP, register for our upcoming Demonstrating SFAIRP course HERE.

(For future discussion: Should we start to have a SFAIRP line item in our budgets that is sacrosanct, and reserved for the risk reduction efforts that are required over the life of a facility? Why not?)