Major Hazard Facilities. Preparing and Managing a Safety Report

Transcription

1 Major Hazard Facilities Preparing and Managing a Safety Report

2 Overview The seminar has been developed to provide: Context with the MHF Regulations An overview of what is required by an employer who needs to prepare and maintain a safety report. 2

3 Some Abbreviations and Terms AFAP - So far as practicable ER or ERP - Emergency response or Emergency response plan HAZID Hazard Identification HSR - Health and safety representative MHF - Major hazard facility as defined in the Regulations MA - Major accident OHS -Occupational health & safety Employer - Employer who has management control of the facility SMS - Safety management system SRO Safety report outline 3

4 Topics Covered In This Presentation Introduction Preparing a safety report What makes a good safety report Safety report outline - Core components Potential pitfalls Key success factors Managing and maintaining a safety report Review and revision Safety report for a new project 4

5 Preparing a Safety Report Project Management Management Commitment and Support Understand Requirement s Planning Consultation & Communication So this is what s required Resources, Tools and Systems 5

6 Management Commitment and Support The safety report should feature in, and be consistent with, business goals and objectives The process is resource and time intensive so commitment for significant funding and employee time is required Consistency with company policy, philosophy and objectives is necessary to maintain and sustain a compliant safety report Essential that upper management show strong commitment, drive the process and provide the environment for the facility to develop, implement and maintain the safety report 6

7 Know The Regulatory Requirements Read the Regulations!!! Be sure to interpret the Regulations in the context of your facility Define the relationships between the safety report / MHF requirements and other OH&S management activities Clarify any points of the Regulations that are not understood. Do this early as several matters require compliant practice from the very beginning of the activity (eg consultation) The MHF Regulations are relatively simple to grasp albeit difficult to comply with 7

8 Safety Report Planning Proper planning is an essential element in preparing a safety report An effective plan will cover all aspects of safety report development (or review and revision) including important aspects such as consultation 8

9 Safety Report Planning Definition of tasks to be completed What do you need to do? Definition of constraints in place What resources do you have access to, funding available, regulatory timeframes etc Definition of task inter-relationships What has to come first, which tasks rely on information from another task, what are the constraints on availability of resources? etc Identification and allocation of resources to each task Who is needed to complete each task? What other projects/tasks are competing for the same resource? What tools, equipment or systems will you require? What data will you generate and how will you store, use and manipulate this data? What resources will you use to monitor progress? 9

10 Safety Report Planning Other elements in the safety report plan: Estimation of task completion times and definition of task milestones in overall project schedule Consultation and reporting plan for the project who needs to be involved, who needs to be informed? A clear project organisation structure detailing roles, responsibilities & reporting lines for project activities 10

11 Safety Report Planning Safety report outline for new safety reports Review/revision plan for update of an existing safety report Employees and HSRs should be briefed on the proposed plan to achieve a common understanding and agreement of what is required Acceptance by upper management of the resource requirements, process, and commitment is essential 11

12 Resources, Tools and Systems Safety report development is a resource intensive process Expect that high levels of employee participation are needed Plant operators, maintenance personnel, plant managers, engineers, OH&S personnel, consultants, support personnel, administrative personnel, HSRs, contractors and corporate managers are all likely to be involved to a significant extent Often spin-off projects are identified to address deficiencies in related support systems (e.g. training systems, document management systems, IT systems) Core safety report development roles are not always best served by part time roles 12

13 Resources, Tools and Systems Attempt to identify early any important tools which may be required. For example, are CAD drafting facilities required to update drawings? Will access to certain database information be required? What reference materials must be sourced? Early consideration on how to record, store, manipulate and use the vast quantity of data generated from the safety report development process is recommended Where existing systems, tools etc are to be used for the safety report tasks, it is prudent to verify early that those systems and tools will provide compliant outcomes If the systems and tools of third parties (e.g. consultants) are to be utilised, the employer should include tasks to test and verify the adequacy of these for achieving a compliant safety report 13

14 Availability of Resources The significant effort and time commitment required to complete activities such as hazard identification and risk assessment can be wasted if all relevant facts and knowledge are not available Early consideration and coordination with many people is generally required An objective evaluation of available skills is necessary to ensure additional expertise can be sourced where necessary A low tolerance approach to workshop non-attendance is often required from senior management level. Workshops may be arduous, time consuming and often repetitive. Management and HSR support is required to overcome this Plant and corporate managers need to agree and commit to the safety report program, and manage conflicting demands on resources accordingly 14

15 Project Management The safety report plan needs to not only be defined, but also tracked and monitored to ensure successful completion by the due date and within all constraints Good project management is required to ensure tasks are completed on schedule, over-runs are identified early and rectified, barriers to achieving compliance are identified and overcome Consider the need for dedicated project resources (e.g. Safety Report Manager) to ensure process is not derailed by conflicting responsibilities 15

16 Quality Assurance A great deal of effort and resource is expended by facilities in developing and documenting safety report components. It is important that this effort is accurately reflected in the final documentation Facilities should be careful to ensure data presented in their submitted safety report is: Accurate Consistent Unambiguous Complete 16

17 Safety Report Outline (SRO) Core Components Safety report philosophy Scope of work to be undertaken Resources, timetable, milestones Key definitions and criteria (risk, property damage) Methodology statements (HAZID, risk assessment etc.) Details of the scope of consultation that will be undertaken The emergency plan 17

18 SRO Core Components - Safety Report Philosophy Inherent risks within the facility Chief methods of ensuring safe operation at the facility Description of safety management system Safety culture within the organisation 18

19 SRO Core Components Description of Methods The methods chosen for hazard identification and risk assessment are likely to have a major impact on resource requirements and timeline Identify these early in the safety report planning The methods used should align with the approach to safety adopted at the facility 19

20 SRO Core Components - Consultation The MHF Regulations require you to consult with employees and external stakeholders during the development of the safety report The safety report outline should describe: Who will be consulted How the consultation will occur How the information from the consultation will be included in the safety report 20

21 SRO Core Components - Consultation Who do you have to consult? 7 main groups of people HSRs Employees Emergency Services Municipal Council(s) Non-employees who enter the facility (e.g. contractors) Local Community Other persons who may reasonably suspect risk to their health and safety 21

22 SRO Core Components - Emergency Plan Emergency Plans exist because things can go wrong and preparation is needed for such an event Emergency Plans are more than response procedures; they also include the supporting framework of training, resources, performance measures and drills etc Consultation with all emergency services is necessary (because they have a role to play in combating incidents and provision of resources) Emergency Plan must be adopted as a control measure and as such the development of meaningful performance measures and indicators is required 22

23 What Makes a Good Safety Report? All parts of the Regulations are systematically addressed Early momentum is established High levels of employee involvement Wide and varied expertise has been made available Thinking outside the established norms Challenging the status quo The safety report process is integrated into facility improvement plans and business processes Safety report is owned, understood and managed by the MHF The safety report process provides clear benefits to stakeholders 23

24 What Makes a Good Safety Report cont Clear and consistent links between MAs, Hazards, Risk, Controls, Emergency Plan, SMS and Performance Monitoring Regimes Implemented control measures, SMS, performance monitoring regimes etc are sustainable given the size and complexity of the facility Documentation captures corporate memory The process is logical and simple don t over complicate 24

25 What Makes a Good Safety Report cont The safety report demonstrates that: The employer fully understands the facility s processes/systems The employer understands the facility s risks Appropriate control measures have been selected and implemented to reduce risks AFAP at the facility Systems are in place to manage each MA to ensure risks continue to be reduced AFAP The employer has systems to keep the control measures working to their stated performance level The employer has in place processes for reviewing and revising, as needed 25

26 Some Potential Pitfalls and Mistakes Not taking time to understand the Regulations properly Inadequate planning Wasting time and resources redoing work unnecessarily Over committing to controls and systems which cannot be reasonably sustained Do things to look impressive but which don t add real value to the business Not using valuable information already available (e.g. independent audits etc) Overlooking mitigative controls and the need to maintain them 26

27 Some Potential Pitfalls and Mistakes Failing to carry forward changes into all relevant parts of the safety report (e.g. Emergency Plan) Inconsistencies between different parts of safety report or between different sources of information Losing sight of the big picture unbalanced focus on certain aspects Losing sight of the overall objective of the regime Failing to make safety report compliment overall business objectives 27

28 In Conclusion - Keys to a Successful Outcome Adequate Planning and Education Understand the requirements in the Regulations and know what compliance looks like Don t over complicate at the start Test processes and methods of documentation before starting Identify resource needs early and consider how on-going maintenance of the safety report will be managed 28

29 In Conclusion - Keys to a Successful Outcome Involve the right people Commitment from senior management Appropriate depth & range of experience Suitably qualified people Operations staff, those who; are exposed to the hazard are the ones most likely to be impacted by, or contribute to an incident understand the true variance in operating conditions and environments 29

30 In Conclusion - Keys to a Successful Outcome Clarity and Consultation People understand what they are doing and why. It is essential to included ongoing consultation with employees Everyone exposed to hazards or involved in management of the risk needs to understand; The hazards The risk The controls The relationship between them The safety report should form the basis of training and operating procedures Key documents are updated and available 30

31 In Conclusion - Keys to a Successful Outcome Cultural Match It is important that the process and methods used will work successfully within the organisation and the way it functions E.g. Don t use highly technical approaches if that is not what you usually do Ensure that controls are appropriate to the capability of the facility to manage them 31

32 In Conclusion - Keys to a Successful Outcome Sustainability Need to remain focused on the facilities ability to sustain both: The processes introduced The outcomes from the process (new controls) Ongoing resource requirements need to be considered before starting 32

33 In Conclusion - Keys to a Successful Outcome Belief in the Outcomes Focus on improving safety, not simply compliance (regulatory or internal) Effective real consultation & stakeholder ownership Preparedness to challenge established norms Process and procedure for resolving issues and agreeing assumptions Transparency of the process 33

34 In Conclusion - Keys to a Successful Outcome Continuous Improvement Focussed effort for continuous improvement in all aspects of the safety report and its supporting systems 34

35 Managing A Safety Report 35

36 Managing a Safety Report The facility has been given a licence for 5 years Management congratulates all Everyone breathes a sigh of relief Onto the next project Let the safety report sit in the draw until the next investigators visit or licence renewal period 36

37 Managing a Safety Report After all, the licence confirms: Risks are in control and There are management systems in place to deal with all of the required issues covered by the Regulations Tempting yes But WRONG! 37

38 Managing a Safety Report What are the key things to be addressed on an ongoing basis 38

39 Managing a Safety Report The safety report should become integrated into the daily management activities of an MHF The safety report process will have identified all of the performance parameters required for managing the risk from each MA How to use the information to keep the risk from each MA as low as practicable? 39

40 Managing a Safety Report How to validate that controls identified in the safety report are: Implemented? Functional? Meeting the performance standards nominated Changes to circumstances are handled in accordance with the safety report process requirements A system must be in place to verify all of these issues in an explicit and transparent manner 40

41 Managing a Safety Report The control measures need to be managed through an audit system by the employer and documented in such a manner that allows the performance of every control to be verified The overall performance of every control managing an MA should therefore be audited 41

42 Managing a Safety Report Hazard Identification Safety Management System Risk Analysis Non-MAs (ie OH&S) Major Accidents Define Control Activities Performance Requirements Implementation Demonstration of Adequacy 42

43 Managing a Safety Report The SMS becomes the primary means of managing safety As with the concept of management systems, if it is stated to do something, then it should be verified Performance indicators should be developed to measure the success or otherwise 43

44 Reviewing and Revising The effectiveness of the SMS can be measured through a specifically developed auditing process Safety management system Audit and verification process Control activities performance standard Demonstration of adequacy 44

45 Reviewing and Revising The auditing process is considered essential to demonstrate Continuing compliance with the safety report Effectiveness of all the processes and systems For the facility The employer can develop a schedule for auditing the SMS elements and each of the MA controls identified in the safety report throughout the year Undertake the audit and report on outcomes 45

46 Reviewing and Revising Example Performance indicator In Place Effective Corrective Actions Pressure Safety Valve (PSV) Passes test within acceptable +/- kpa limits PSV confirmed, correct location, correct set pressure and relief path open to correct location PSV test records indicate that it is within test interval PSV passed pop test before last recalibration i.e. it was effective when removed for overhaul If failure was noted, what reporting of control failure was done What corrective action was identified Have corrective actions been completed 46

47 Reviewing and Revising It is natural that with any system there will be opportunities for improvements to be made to the safety report process Such improvements could relate to: Feedback from employees regarding training Performance of controls (positive or negative) Management of change Emergency response exercises Training Incidents that occur Communications with Regulator 47

48 Reviewing and Revising Feedback from various sources will enable the safety report to be continually used as a key management business platform for the MHF It will provide demonstration to all stakeholders of how the process is working It will aid transparency and continued demonstration of adequacy that the safety report is fit for purpose 48

49 New Projects 49

50 New Project How do we achieve the right outcome? New Project! Safety Report Requirements Project Lifecycle 50

51 New Project MHF issues need to be considered as early as possible during a project lifecycle Decisions taken at early stages of a project will have an impact on the MA profile of the facility good and bad The employer needs to focus on short, medium and long term issues required for the safety report during project development 51

52 New Project Concept Design Construction Commission Major hazard issues should be considered during each step in the project life cycle Important decisions at the concept phase can impact upon the overall risk profile of the facility throughout its life Production Decommission Disposal 52

53 New Project It is cheaper to fix an issue at the design phase than the operational phase Retrofitting control measures or fundamental design changes during the operational phase: Is always more expensive Places a very large burden financially on operational budgets Delays the facility from reaching the designed throughput targets If the process is well structured, the reasons for specific controls adopted and rejected can be documented corporate memory The corporate memory approach is extremely valuable 53

54 New Project Potential Issues For example, XYZ company engages a contractor for developing a project on a lump sum basis and the project requires MHF licensing In many cases the contractor will engage a resource to deal with MHF requirements 54

55 New Project Potential Issues Possible Project Organisation XYZ Company EPC Contractor Sub contractor 1 Sub contractor 2 MHF Resource 55

56 New Project Potential Issues The question for all concerned is how can the objectivity of a safety report development be achieved without competing elements of the project being compromised? The key to a successful outcome is how the contract is set up between XYZ company and the contractor 56

57 New Project Potential Issues Conflicts of interest can easily occur there are many examples of this and the end result would be costly for both XYZ company and the contractor MHF issues that arise which are outside the basis on which the contractor s lump sum price was developed will need to be addressed as opposed to being ignored This may lead to protracted delays between employer (XYZ company), contractor and regulator 57

58 New Project Potential Issues Start the safety report early -at the concept phase Clearly defined responsibilities, accountabilities and authorities Establishment of milestones Establishment of key criteria and methods Contractual arrangements Resources (internal versus external) Clearly defined deliverables 58

59 New Project Potential Issues The contractual arrangement should address: Commitment of client Contractual and planning arrangements Resources (internal versus external) Clearly defined deliverables Establishment of milestones Establishment of key criteria and methods Clearly defined responsibilities, accountabilities and authorities Start the safety report early (at the concept phase) 59

60 Questions? 60

61 Supporting Slides Emergency Plan 61

62 SRO Core Components - Emergency Plan An emergency response plan is a mitigative control that may prevent an incident from escalating to a more severe outcome 62

63 SRO Core Components - Emergency Plan Develop your EP/ERP based on your credible Major Accident Scenarios Involve all emergency services in the consultative process Ensure involvement of council and community Simplify procedures Develop and implement performance standards that will value-add to the emergency plan Conduct exercises based on the plan 63

64 SRO Core Components - Emergency Plan When an emergency occurs, the first steps taken will have an impact on the outcome (consequences) The outcome can be minimised by having control measures and systems in place to mitigate the consequences of an emergency situation This takes: Planning Evaluation Adequacy of systems in place Training It is an ongoing process over the lifetime of the MHF 64

65 SRO Core Components - Emergency Plan Emergency planning is a cyclical process The plan should be: Dynamic and interactive Ensuring ongoing relevance to the needs of the facility and all stakeholders by continual: Monitoring Review Consultation 65

66 Causes Outcomes SRO Core Components - Emergency Plan Preventative Control Measures Mitigative Control Measures MA Elimination Prevention Reduction Mitigation measures measures measures measures Hazards Controls Controls Land-use Emergency planning response Consequences 66

67 SRO Core Components - Emergency Plan Aim of the Plan Provide a system and resources to protect people, property and the environment To minimise adverse impact on people, property and the environment Objectives of the Plan Comprehensive, yet concise, simple and flexible 67

68 Emergency Plan Contents - Example 68

69 Emergency Plan Site and Hazard Detail Links the risk assessment outcomes to the emergency plan Identifies personnel resourcing issues Details assumptions Details the combating resources available on site Details Emergency Response Plans 69

70 Emergency Plan Site and Hazard Detail Assumptions affecting the emergency plan: Assumptions on the availability of resources and services and the execution of responses within an estimated time frame Assumptions should be evaluated and contingency plans developed when assumptions fail or cannot be justified Typical assumptions include: Availability of external resources Response time of emergency services Correct operability of equipment Key personnel will be available on site at time of incident Personnel will be competent to undertake duties as detailed in the plan Fire water containment capability 70

71 Emergency Plan Site and Hazard Detail Estimation of Consequences: The effects/impacts can be estimated from information available on material released, operating conditions, facility layout, nature of the surroundings and environmental conditions: Nature and rate of material released Radiated heat generated by a fire Blast generated by an explosion Toxic concentration in the atmosphere Escalation potential 71

72 Emergency Plan Site and Hazard Detail Estimation of Consequences: Once the analysis of the scenario has occurred, the emergency response scenario information can be presented in a consistent format Format is site specific but must meet the needs of those expected to use the information including site and emergency services personnel. 72

73 Example Emergency Response Plan Emergency Response Plan Ref Number: ERP-1 Unit Name: Plant A: Crude Unit Equipment No. P-XYZ-001 Incident Title: Pump Pool Fire CHEMICAL DETAILS Typical Product Kerosene UN Number 1223 Flash Point 46 o C Typical Inventory 50 m 3 Product POOL FIRE POTENTIAL CONSEQUENCES JET FIRE Hole Size 25 mm Hole Diameter NA mm Spill Diameter 7 m Product State NA EQUIPMENT PROTECTION PRIORITY D-456 T-789 Butane Storage Drum Kerosene Storage Tank EQUIPMENT PROTECTION PRIORITY NA NA Fire Consequences FIXED FIRE FIGHTING EQUIPMENT IN VICINITY Fire Hydrants 3 Deluge Systems (Total) 1 Fire Monitors 3 Deluge Systems (Detail) D-456 Butane Storage Drum Foam / Water Monitors 0 Foam ADDITIONAL FIRE EQUIPMENT/RESOURCES REQUIRED Portable Monitors 2 2 Hose Lengths 6 Foam Cannons 1 Pumpers 0 Foam POOL FIRE FOAM/WATER REQUIREMENT FOAM REQUIREMENT WATER REQUIREMENT Concentrate 1,200 L (3%) Water For Foam 1,200 L/min Application Time 15 min Water For Cooling 5,600 L/min Foam Sol n Flow Rate 580 L/min Supplementary 2,400 L/min Full Foam Supply 20,000 L Total Water Flow Required 9,200 L/min JET FIRE WATER REQUIREMENT Water For Cooling 0 L/min *Supplementary 0 L/min Water For Jet Impingement 0 L/min Total Water Flow Required 0 L/min Fire Fighting Equipment Foam and Water Requirements 73

74 Example Emergency Response Plan Site Plan Pool Fire Heat Flux with Wind (4.7 kw/m 2 for personnel accessibility) Heat Curve irrespective of wind direction 74

75 Emergency Response Command Structure & Personnel Identifies roles for individuals within the emergency plan Identifies: Who is in charge What personnel should do Why they do it When they do it Who is communicating with whom How to contact persons, organisations or additional resources 75

76 Emergency Response Command Structure & Personnel Roles and responsibilities needs to clearly detailed and should to be consistent with the Command Structure Role statements need to be available for all positions and persons need to be familiar with their role and also their contingency role (if any) 76

77 Emergency Plan Notifications On site personnel Off site facilities Emergency services Applicable authorities 77

78 Emergency Plan Notifications Information required by fire services when responding to a notification should be fit for purpose i.e. for Chemical Spill Type and scale of the spill (eg within bund or uncontained) Name of the substance involved UN Number Estimated quantity 78

79 Emergency Plan Resources The plan must identify all resources available on site that are available for use during an emergency Where the equipment/material (foams, neutralisers, etc) are located or how they are to be obtained Fixed fire fighting systems should be explained, in particular their design intent (eg. Deluge systems -cooling or mitigation) & method of activation Flow rates and water supply duration should also be detailed 79

80 Emergency Plan Evacuation Procedures These procedures must enable any person on site to understand what is expected of them and what actions they are required to undertake The procedures must explain who is responsible for accounting for personnel and how it is to be achieved (links to Command Structure) 80

81 Emergency Plan Isolation Procedures Control Isolation Points: Provides details for the isolation of: Utilities (gas, water and electricity) Road Traffic Isolation points need to be identifiable, accessable and maintained 81

82 The Emergency Plan as a Control Measure The emergency plan must be included among the control measures adopted under Regulation Need to identify appropriate Performance Indicators and Standards that will ensure the on-going effectiveness for each individual control, to enable ongoing assurance. Indicators of failure need to be identified Actions to be taken in reporting any such failure Other corrective actions to be taken in the event of any such failure. 82

83 Emergency Plan Example Performance Standards Emergency response personnel are nominated and manned on all shifts Response plans are in place for all emergency scenarios Emergency response personnel training is current Emergency response resources are available, capable and tested Drill/exercises are conducted according to the schedule 83

84 Emergency Plan Example Performance Indicators % of fire equipment inspected and tested as per schedule Evacuation of non essential personnel to assembly point within 7 minutes Notification to Emergency Services within 2 minutes of potential major accident being identified Emergency Response Team to assemble within 3 minutes of alarm Emergency response plan exercises are completed within one month of scheduled date 84

85 Emergency Plan - Testing What is the desired outcome of conducting an emergency exercise? To be able to demonstrate so far as is reasonably practicable that in the event of emergency (eg MA), the mitigation control measures will work as expected to reduce the likelihood of injury to all persons and restrict damage to plant, equipment and local community to a minimum. 85

86 Emergency Plan - Testing What else is tested in an emergency exercise? Alarm and communications systems Call-out of internal/external emergency personnel Critical emergency equipment availability Evacuation procedures Ensure participation of appropriate emergency services. 86

87 Emergency Plan Testing Desktop Exercise Useful training for familiarisation with procedures and site emergency issues Can identify resource limitations, issues and knowledge amongst personnel May not adequately test communication, site evacuations processes or equipment accessibility. Desktop exercise should not be used as the means of compliance with Regulation 9.53(4) 87

88 Emergency Plan Testing Simulated MA Scenario Will test effectiveness of evacuation procedures Coordination between onsite procedures and emergency services Extended test of onsite/offsite communication systems Tests capability of emergency services to response Identify limitation/restrictions in equipment access 88