Process Safety Performance Indicators. Neil Macnaughton Process Safety Specialist Ineos Manufacturing Scotland Ltd

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1 Process Safety Performance Indicators Neil Macnaughton Process Safety Specialist Ineos Manufacturing Scotland Ltd

2 Personal Background Graduated in Chemical Engineering in 1983 Worked with ICI, BP and now Ineos Full time process safety role since 1998 Ongoing role in promoting process safety on refining and petrochemical complex at Grangemouth Member of Scottish CIA pilot on process safety performance indicators ( ) Contributor to development of HSG 254 Member of OECD Expert Working Group on process safety performance indicators Member of UKPIA working groups on Process Safety and Process Safety Performance Indicators

3 Content of presentation What do I mean by a PSPI? Why the interest in PSPIs? How do they fit in with other monitoring activities? Possible approaches to PSPIs What might PSPIs look like? Why are they important?

4 What do I mean by PSPIs? A subset of the metrics gathered by an organisation Monitored periodically to give a indication of how the organisation is managing its major hazards Need to include a combination of input and output measures (leading and lagging)

5 Longford gas plant explosion (1998) Andrew Hopkins Lessons from Longford Esso regarded itself as a safety conscious company. Following standard industry practice, it used lost-time injury frequency rate as its principal measure of safety performance, and in terms of this measure Esso's level of safety was enviable. Measuring safety in terms of lost-time injuries or total recordable injuries is inherently problematic in hazardous industries. An airline would not make the mistake of measuring air safety by looking at the number of routine injuries occurring to its staff. Baggage handling is a major source of injury for airline staff, but the number of injuries experienced by baggage handlers tells us nothing about flight safety.

6 BP Grangemouth (2000) BP Grangemouth Competent Authority Report (2003) Major accident hazards should be actively managed to allow control and reduction of risks. Control of major accident hazards requires a specific focus on process safety management over and above conventional safety management. Companies should develop key performance indicators (KPI s) for major hazards and ensure process safety performance is monitored and reported against these parameters.

7 BP Texas City (2005) Baker Report (2007) BP primarily used injury rates to measure process safety performance at its U.S. refineries before the Texas City accident. Although BP was not alone in this practice, BP s reliance on injury rates significantly hindered its perception of process risk. BP tracked some metrics relevant to process safety at its U.S. refineries. Apparently, however, BP did not understand or accept what this data indicated about the risk of a major accident or the overall performance of its process safety management systems. As a result, BP s corporate safety management system for its U.S. refineries does not effectively measure and monitor process safety performance.

8 Other incidents What price knowing.?

9 The goal of PSPI s To support the prevention of a loss of primary containment by focusing attention on critical areas of the management system.

10 PSPIs the new in thing? Muted response until Baker report Not much happened in immediate aftermath of Longford (only permeated BP in late 2000) Limited response to Grangemouth incidents probably confined to UK and UK trade associations CIA and HSE produce HSG 254 UKPIA produce report for refining industry OECD produced guidance (2003) Guidance on Developing Safety Performance Indicators related to Chemical Accident Prevention, Preparedness and Response Main US focus comes on the back of Texas City API, AIChE/CCPS, NAS, etc., etc.

11 Limitations of PSPIs Collecting PSPIs is a waste of time unless the right people: Understand the question the PSPI is asking; Understand the limitations of the data; Have the will and the authority to act on the data; Have a critical attitude to the relevance of the PSPIs; Know that PSPIs cannot answer everything. The effectiveness of PSPIs cannot be separated from organisational / cultural factors and from other feedback mechanisms

12 Benefits of PSPIs A good set of measures can help organisations How close are we to catastrophe? Promote awareness of the possibility of disaster But. It has been hard to know how to develop measures for process safety Many issues can t be reduced to a number, so What are the right questions to ask? What measures help to provide the answer? What is the equivalent to the lost time injury?

13 Where do PSPIs fit in? PSPIs are one feedback mechanism They provide a means of gathering information; They provide a means for challenging performance; They can drive behaviour (good and bad); But. Organisations can only respond to a few measures; Which are the right ones to pick? PSPIs must be complemented by audits PSPIs and audits aren t a substitute for good engineering

14 Selecting output PSPIs Simpler than input PSPIs Should primarily focus on losses of primary containment Can align to input measures and/or common causes Could include some near miss type performance

15 Selecting input PSPIs Two principle approaches Management system process based Broadly the approach adopted by OECD Hazard and risk based Broadly the approach adopted by HSG254 and UKPIA report What is the rationale for choosing? Both approaches ask entirely valid questions, but What level of the organisation are the PSPIs aimed at? How often are they to be measured?

16 Management system PSPIs Based on monitoring of key management system elements What % overdue inspections? How many of the planned Hazops carried out? What % of Hazop actions have been closed? How many investigations have root causes developed? How many investigation actions closed out? What % of changes have formal MoC? How many OIs are overdue review? What % of emergency exercises carried out? Compliance with improvement objectives

17 Hazard and Risk based Based on key factors in preventing a dangerous loss of containment How often did a unit exceed operating limits? High temperature, low temperature, level, pressure, ph, velocity, etc How many times was equipment not properly depressured before maintenance? How many demands were placed on trip and relief systems? How many equipment items are overdue inspection or testing? What % of required hose tests were carried out? What % of permits had field visits carried out?

18 What s the difference? Management system PSPIs tend to be high level Relationship to preventing loss of containment is generally indirect May be more to do with contributing factors? Hazard / risk based PSPIs tend to be low level Direct relationship to loss of containment More connection with immediate causes Directly related to plant issues

19 What might good PSPIs look like? Ideally a combination of both management system and Hazard/risk based Must relate to how primary containment can be lost and the principle controls to prevent this Active and Passive measures May include improvement measures Output measures should measure loss of containment Use audits for high level view of management system

20 Example Monthly measures Output measures Reportable releases Minor releases (by category) Input measures Inspection and testing compliance (by category) No of demands on protective systems (by category) No of protective systems found failed on test (by category) Operating envelope breaches (by category) Permit to work system compliance (site visits, safe depressuring) Improvement objectives Overdue plant modifications

21 Complement with audits Focus of audits could be (for example) Effectiveness of leadership Effectiveness of training Compliance with key systems maintenance, management of change, inspection process, risk assessment, operating instructions override management Effectiveness of emergency response Safety culture

22 Do PSPIs matter? Yes, if done properly Give a window on how hazards are being managed Can help support process safety at a local level Can promote learning But, Need to see PSPIs as part of an integrated whole Need to look beyond the simple numbers Need to be alert to issues that aren t being measured How would an imminent TXC be detected?

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