Are NFPA standards enough?

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SECTION: ISSN: 0018-8190

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(NFPA) 85 standard addresses the design, installation and operation of single- and
multiple-burner boilers and other fired equipment. The NFPA 86 standard addresses
similar issues for ovens, furnaces and fume incinerators. These codes are intended
to prevent fires, explosions and implosions of equipment. Part of  NFPA 85
outlines requirements for safety interlocks (Table 1). Interlocks protect the
fired equipment from operating in dangerous modes. These standards are
prescriptive; they stipulate specific equipment requirements such as a double
block and bleed valvefor a gas fuel train.

Some HPI operating companies view implementing specified interlocks as

satisfying requirements for functional safety. While the NFPA listed interlocks
are a good start to evaluating such hazards associatewith fired equipment, they do
not ensure that the risk has been reduced to a tolerable level. Several key
concepts are not fully addressed by NFPA 85 including consequence severity and
equipment reliability.
Consequence severity. A key element missing is an evaluation of the
consequence for a hazard. It is important to consider the magnitudeof the
consequence to ensure that the risk is sufficiently reduced. The location of fired
equipment has a direct impact on the severity of the consequence. For example,
consider two identical boilers--one is located in a remote area of the plant,
and the other is centrally located near offices and manned work areas. If
interlocks, operation and maintenance are identical, then the frequency of an
accident wouldtheoretically be the same. However, the consequence of the accident
would be much higher for the boiler located in the more heavily manned area.
This is why it is important to do a risk assessment on each piece of equipment.
Equipment reliability. The NFPA standards do not set specific requirements for
the equipment used in the safety interlocks. There is guidance on some equipment,
such as programmable logic controller (PLC)and flame detectors; yet, it is not
complete. To ensure that the interlocks provide the require risk reduction two
things are needed a target risk reduction and reliability calculations for the
interlocks. Quantifying the consequences associated with the hazard and
comparingit to tolerable risk guidelines will address the first issue. Reliability
calculations that consider the equipment selected, testing intervals, testing
effectiveness and mission time of the system will confirm if the interlocks are
providing the required risk reduction.
The achieved risk reduction will vary greatly, depending on how the
interlocks are implemented. To illustrate the impact of interlock design, consider
a typical NFPA compliant interlock implemented in twodifferent ways (Table 2). The
first interlock is implemented with a pressure switch and control relays, while
the second interlock is done with a safety-rated transmitter and PLC. Both
interlocks have identical valve configurations. The first interlock achieves a
risk reduction of only 12 while the interlock that contains the safety-rated
transmitter and PLC achieves a risk reduction of 270. Clearly, both approaches can
be considered an interlock for low pressure, but the one that takes advantage of
safety-rated equipment provides much greater risk reduction.
Best practice. A best practice seen in the field is a blended approach and
yields a solution that includes the strength of NFPA standards and IEC
61511/ ISA S84.00.01. This approach includes:
Verify that all pertinent NFPA interlocks are implemented
Include fired equipment in process hazard analysis
For hazards with significant consequences, do a formal safety integrity level
(SIL) selection
As indicated by the SIL selection results, treat the affected NFPAinterlocks as
safety instrumented functions (SIFs).
Create safety requirement specifications (SRSs) and perform SIL verifications
per IEC 61511.
This approach satisfies the requirements of the NFPA standards andprovides
alignment with the emerging functional safety standards. HP