Learn how to remove uncertainties in facility siting studies by addressing key factors, such as blast overpressure and protection, managing risks and incorporating blast-resistant control rooms
The U.S. petroleum refining industry in 2024 comprised over 130 operational refineries, managed primarily by large organizations with robust safety practices and structured facility siting studies (FSS). However, the chemical sector is much broader, with thousands of plants of varying sizes, from large-scale operations to smaller, independent facilities. Many small to mid-sized facilities, especially those operating independently, have not conducted a proper FSS, a practice more commonly adhered to in larger refineries. However, as with any industrial facility, the Occupational Health & Safety Administration (OSHA; Washington, D.C.; www.osha.gov) requires facility siting to be addressed within a Process Hazard Analysis (PHA). OSHA also requires revalidation at least every five years, or more frequently if significant site changes occur. Among these small to mid-sized companies, the adoption of comprehensive FSS may be less consistent, often due to resource constraints or limited regulatory pressures. A key trend observed in the market is the increasing focus on multi-hazard assessments, particularly within the chemical sector.
The FSS is a necessary part of operations, and with proper understanding and preparation, these activities can be effectively managed. It is important for small- and mid-sized chemical companies to be fully aware of the requirements of these studies and approach them with due diligence. At the same time, larger chemical companies should also recognize that they can challenge established processes, potentially improving the outcomes to better align with their operational needs. In fact, feedback from clients reveals widespread dissatisfaction with FSS outcomes, with concerns that the studies are being manipulated to create an undue dependency on a specific solution.
Demanding a good facility siting study
Independent engineering, procurement and construction (EPC) firms have encountered situations where the results of the FSS were revisited and risks were found to have been reassessed without clear justification. Such instances point to a broader need for organizations to maintain transparency and consistency in how these studies are conducted and interpreted.
This underscores the importance of fostering greater awareness within health and safety, as well as process-safety management teams, about the methodologies and standards that underpin an effective FSS. Building this understanding equips all stakeholders to critically evaluate findings, ensure accuracy, and promote decisions that genuinely enhance safety while remaining objective and balanced.
It is extremely important to obtain FSS information from independent sources that lack a vested interest in selling solutions, and chemical companies should ensure that they fully understand the content of their reports. An effective FSS should be clear and accessible, presenting results in a format understandable to those with basic industry knowledge. Additionally, it should include preliminary mitigation concepts, guiding end users in developing and prioritizing their mitigation plans.
A comprehensive FSS should not only identify hazards and threats but also offer a foundational understanding of risk — particularly around occupied buildings — and include a conceptual analysis of risk relative to potential mitigation costs. This baseline helps organizations prioritize and make informed decisions, paving the way for follow-up engineering and targeted mitigation strategies.
Chemical facilities of all sizes
The importance of FSS is widely recognized by larger companies with complex operations, who routinely conduct these studies across both their refinery and chemical divisions. However, when small or independent companies are either unaware of the need for these assessments or choose to overlook them, assuming that their operations can continue without these formal evaluations, they can put themselves in the path of significant risks. Even well-established companies sometimes overlook the required five-year renewals, potentially leaving facilities vulnerable to unidentified or emerging risks. While many companies complete an initial study, it is essential to maintain an up-to-date assessment to reflect any operational or regulatory changes.
In cases where siting studies reveal multiple areas for improvement, companies may worry about the cost or feasibility of addressing all issues immediately. Nonetheless, regulatory bodies like OSHA are often reasonable and understand the practical challenges of addressing every issue at once. A phased approach, such as implementing a ten-year improvement plan, can be an effective solution. By addressing one project at a time, companies can demonstrate a commitment to improving safety and compliance. This incremental approach allows companies to move in the right direction, ensuring continuous progress in risk management while keeping projects manageable.
The value of second opinions
While it may seem efficient to continue with the same consultant for obtaining an FSS, relying on one provider may limit the value gained from the renewal process. Each renewal should ideally take a fresh approach, with the provider building on the original findings but also re-evaluating risks with updated methodologies and insights. New consultants will review past reports, ensuring continuity, but may also bring alternative perspectives that can add value. Regularly obtaining competitive quotes for renewals can help companies identify the best approach and ensure they are maximizing the effectiveness of their FSS.
A common perception is that using the same company for each FSS simplifies the process. While there is some merit to this — such as a certain familiarity with the facility — it is not necessarily the most efficient or effective choice. Over time, personnel changes within a consultancy are inevitable, meaning that new team members will often need to familiarize themselves with the facility from scratch, even if the same firm has been used consistently over many years. As part of this process, each consultant will reference past reports and documentation, ensuring continuity regardless of whether the same company is retained.
To ensure optimal outcomes, it is advisable for chemical plants to consider a range of providers for their facility siting studies, exploring the various approaches and expertise available. This practice not only broadens the perspective applied to each study but can also lead to potential improvements in quality, insight, and overall cost-effectiveness.
Independent advice
Independent advisors play a crucial role in guiding companies through the facility siting process, particularly for organizations that require clarity on how to interpret and act upon findings from their FSS. While these advisors may not conduct the studies themselves, they often work with trusted and reputable partners to help clients obtain unbiased and objective assessments.
Once a facility siting study is completed and preliminary risks are identified, advisors can assist in developing appropriate mitigation strategies. For instance, if a study finds that an existing building does not meet safety standards for a blast zone, options may include relocating personnel, retrofitting the existing structure, or replacing it with a safer alternative. Temporary and permanent solutions need to be explored to account for various operational requirements. For example, temporary relocations may be necessary during retrofitting, while permanent replacements might involve constructing safer, compliant buildings.
Advisors also support clients in addressing more complex scenarios, such as managing safety concerns across multiple at-risk buildings. Recognizing that it may not be feasible to address all issues simultaneously, they can help prioritize mitigation efforts by providing rough-order cost estimates and discussing phased action plans. These plans allow organizations to align safety measures with their budgets and operational goals.
By offering clear recommendations and practical strategies, independent advisors enable decision-makers to present well-structured plans for risk mitigation to leadership teams. This approach ensures that safety improvements are executed efficiently and effectively, minimizing risks to personnel and operations while meeting regulatory requirements.
Official guidance on managing hazards
OSHA’s 29 CFR 1910.119 standard mandates Process Safety Management (PSM) requirements for facilities with highly hazardous chemicals, emphasizing safe facility design, emergency response, and reducing potential hazards. The American Petroleum Institute’s (API) Recommended Practices (RP) 752 and 753 work in conjunction with this standard, offering specific guidelines for building siting and construction in hazardous environments, with the goal of mitigating risks from explosions, fires, and toxic releases.
API RP 752 covers permanent structures, while RP 753 focuses on portable buildings like trailers. Both standards outline a risk-based and consequence-based approach to site buildings at safe distances from hazardous processes. For example, permanent buildings near high-risk areas should be robustly constructed to withstand potential blast impacts, while temporary buildings should be situated further from these areas whenever feasible.
The recent 2024 updates to RP 752 and RP 753 enhance guidance on managing hazards, including improved risk assessment methods to support better-informed siting decisions and integrating new protective measures for personnel safety in response to evolving industry standards. These updates are part of API’s commitment to refining safety standards as operational needs and safety technology advance.
In facility safety planning, it is important to distinguish between prescriptive and performance-based approaches. A prescriptive approach relies on predefined company standards that specify fixed distances for placing buildings in relation to potential hazards. This method is often used by companies that do not conduct the FSS. In contrast, more sophisticated organizations typically adopt a performance-based approach, where the FSS plays a key role. This method involves identifying hazards through detailed analysis and developing customized mitigation plans tailored to the specific risks of the facility.
Additionally, many companies are increasingly incorporating Quantitative Risk Assessments (QRA) alongside or instead of simplified FSSs. A QRA provides a more refined and data-driven evaluation of risk, helping reduce the conservatism often present in traditional analyses. This results in mitigation plans that are not only safer but also more practical and aligned with the facility’s day-to-day operations.
Regulation or recommended practice?
In the high-stakes environment of industrial facilities, safety regulations and industry guidelines play crucial roles in mitigating hazards. While OSHA regulations are legally binding and enforceable, standards from organizations like API are generally considered “recommended practices” (RPs). Though not legally mandated, these RPs are widely regarded as the standard for safe operations, making them, in effect, a form of de facto industry law. Failure to follow such guidelines can expose companies to significant risks, both in terms of employee safety and financial liability.
Facility siting studies are an essential tool in managing risk in volatile environments. These studies assess potential hazards (such as fire, explosion, and toxic exposure) and establish safety zones, helping companies prioritize protective measures. Even though operators might go years without an incident, these environments carry an inherent level of risk, much like the need to wear a seatbelt — often unnecessary, but essential when a problem occurs. In case of an accident, adherence to RPs strengthens a company’s legal defense by demonstrating compliance with industry-accepted safety practices.
The cost of implementing the FSS and recommended safety upgrades, though sometimes seen as burdensome, pales in comparison to the financial, legal and reputational damage that can result from a significant accident. Proactively addressing these risks helps companies avoid costly legal issues and protects both employees and assets. Adopting these practices is essentially an insurance policy for risk mitigation, balancing practical safety measures with the unavoidable hazards of industrial operations.
Balancing risk of hazards
In FSS, the challenge of accurately assessing hazards, especially fire threats, is critical to ensuring both safety and operational feasibility. These studies typically identify and quantify potential threats, such as blast, fire, and toxic exposures, and use these assessments to establish risk zones within a facility. However, the assumptions driving these evaluations, particularly if overly conservative, can lead to inflated risk estimates and costly, impractical mitigation recommendations.
For instance, while fire hazard assessments are a crucial component of facility siting, the reliance on highly conservative data inputs can skew results. When overly conservative models categorize entire facilities as high fire-risk zones, despite a minimal history of fire incidents, companies may face recommendations that necessitate costly and extensive upgrades. Examples include requirements to replace general-purpose electrical equipment with explosion-proof alternatives across large areas of the facility. This not only increases costs but also limits operational flexibility and impacts the types of equipment that can be used, affecting overall productivity.
This approach of conservative input data illustrates the need for balance. Facilities should ensure that hazard assessments reflect realistic conditions, avoiding excessive conservatism that drives unnecessary expenses. A critical evaluation of siting study inputs can help achieve a balance, where mitigation strategies are aligned with actual risk levels. In doing so, companies can adopt effective safety measures that are both feasible and appropriately scaled to their operational needs, optimizing resources while maintaining rigorous safety standards.
Conclusion
A recurring issue related to FSS activities with large producers is a reliance on a single, often unquestioned data source, which may lead to ineffective or suboptimal business decisions. By repeatedly accepting results without critical evaluation or considering alternative insights, these companies risk implementing strategies that do not fully align with operational needs. This “rinse, wash, repeat” approach, especially among major operators, can foster complacency and inhibit innovation.
Moreover, smaller operators may face similar complacency but could benefit substantially by re-evaluating hazards with fresh perspectives. Many producers might realize cost savings by avoiding overestimated risks or by sourcing diverse assessments that better match the true scope of hazards. This shift could not only optimize expenditures but also enable broader project allocations, facilitating enhanced safety investments without compromising effectiveness.
For small and mid-sized chemical companies, enhancing FSS practices could bring substantial benefits, such as improved hazard identification and optimized risk management. While major operators generally implement rigorous safety measures across both their refining and chemical divisions, they too can benefit from periodically reassessing and challenging the outcomes of their studies. Ideally, the needs of facilities across the size spectrum should be appropriately addressed, offering insights relevant to all players in the industry. This approach encourages best practices in FSS and promotes a culture of continuous improvement and safety across the board. Ultimately, while safety remains paramount, accurate and critically assessed data allow companies to balance risk management with efficient resource allocation, potentially unlocking funds for additional safety measures or other projects.
Author
Phillip Lange is the custom project sales manager at RedGuard, where he has spent more than 17 years helping industrial clients solve complex safety challenges with modular building solutions. Over the years, Lange has been involved in nearly every phase of the business — from drafting and estimating to engineering, product development, production/logistics, and leading custom projects. His experience spans a variety of high-risk industries, including petrochemical, defense, space exploration and portable storage.