Last week we introduced API 2350 Edition 4, an industry standard created by the American Petroleum Institute. API 2350 outlines the minimum requirements needed to comply with the latest best practices to prevent tank overfills in petroleum facilities. We mentioned that new to this edition is the requirement for a management system. Today, we would like to talk about that further.
Management systems help organizations reach their objectives through defined processes and activities. They are the written instructions that must be followed by the individuals in an organization. Many companies use management systems to comply with regulations, meet environmental standards, and reduce accidents.
The purpose of implementing a management system in regards to API 2350 is to ultimately eliminate tank overfills. The management system required by the standard is referred to as an overfill prevention process (OPP). Even though API 2350 requires an overfill prevention process it does not provide specifics as far as how to develop or implement one.
However, like most other management systems it is vital that top management play the primary role in endorsing and supporting an OPP. This way, processes for all of the OPP components listed below will be implemented using a formal corporate program structure:
- Formal risk assessment
- Formal written operating procedures and practices including safety and emergency response procedures
- Trained and qualified personnel
- Functional equipment
- Scheduled inspection and maintenance programs for instrumentation
- Systems to address both normal and abnormal conditions
- Management of change process
- A system to deal with overfill near misses and incidents
- A system to share lessons learned
The purpose here is to ensure that management systems are formally integrated into the core of a company’s operations. The investigation into the Buncefield Incident specifically referenced that the “management systems in place […] relating to tank filling were both deficient and not properly followed […]”
So to be in compliance with API 2350, a formal system must be documented consisting of the principles found within the standard.
Next week we will go into further detail on what is involved in performing a risk assessment on your tanks. Don’t hesitate to contact us with questions. We will be happy to help.