Considering industry costs and benefits for Safety Management, can we do better?

Similar documents
Are you in control of process safety? Basis of safety assurance can provide the answer

Superior Solutions for the Process Industry

Process Safety Leading Indicator

Health and Safety Management Profile (HASMAP)

APCChE 2012 PSM Seminar Feb 2012 Critical role of leadership in preventing Major Accidents in the Chemical Process Industry

شركة التقنية الصناعية للخدمات النفطية INDUSTRIAL TECHNOLOGY OIL SERVICES

Process Safety Management and Functional Safety Management. Spot the difference

Session Nine: Functional Safety Gap Analysis and Filling the Gaps

POST LICENSING OVERSIGHT AND INSPECTION OF MAJOR HAZARD FACILITIES AN AUSTRALIAN REGULATOR S EXPERIENCE

Leading indicators workshop: Breaking the barrier to zero injuries. [Risk Engineering]

Table of Contents. 2 Introduction: Planning an Audit? Start Here. 4 Starting From Scratch. 6 COSO s 2013 Internal Control Integrated Framework

SAFETY CULTURE IN ITALY: THE LEGISLATION, INSPECTIONS, THE PERSPECTIVE OF AN INSPECTOR

Lessons Learned from PSM Audits

An Garda Síochána. Global Energy Management System Implementation: Case Study. Republic of Ireland

T. Sathyapriya, PG Scholar

Cheddar or Swiss? How Strong are Your Barriers? Bayan Saab, Process Safety Consultant, FVC International Symposium October 2009

SPHERA CUSTOMER CASE STUDIES. ADVANCING OPERATIONAL EXCELLENCE A focus on Incident Management

EA-7/04 Legal Compliance as a part of accredited ISO 14001: 2004 certification

SAFETY INTEGRITY LEVELS CONSIDERATIONS FOR NEW AND EXISTING ASSESSMENTS

INTRODUCTION TO QUALITY ASSURANCE

2012 ISA Safety and Security Division Symposium

CAPITAL INVESTMENT SYSTEMS MAKING THE RIGHT INVESTMENT DECISIONS

MAKING PROCESS SAFETY A TOPIC FOR THE BOARD ROOM

Morasey Capability Statement. Capability Statement IENVIRONMENT ISAFETY IPROPERTY RISK MORASEY MORASEY MORASEY. Page 1

VisiumKMS Industrial. VisiumKMS Operational Risk Management Solution

SYMPOSIUM SERIES NO. 155 Hazards XXI # 2009 IChemE

Integrity Program Evaluation Using Meaningful Performance Metrics

Health and Safety Audit Procedure

IET Code of Practice: Competence for Safety Related Systems Practitioners. Ron Bell Engineering Safety Consultants Ltd

Expected and Unintended Effects of Instrumented Safety Protections

EHS Management Systems

GUIDANCE ON THE MANAGEMENT OF THIRD PARTY COMPETENCE FOR SAFETY CRITICAL POSITIONS OFFSHORE

Safety and Health Recognition Programme 2012

Safety and Risk Management Aspects for Major Accident Industry in Poland Adam S. Markowski

2018 RESPONSIBLE CARE OBJECTIVES & TARGETS

Benefits and Application of OSHA s Voluntary Protection Program

Environmental, Health and Safety Management

PG&E Gas Operations. Gas Safety Excellence API 1173

Operational Safety Integrity Closing the Safety Loop

Contractor Safety Performance -

SAFETY MANAGEMENT SYSTEMS IMPLEMENTATION EVALUATION GUIDE

Workplace HSE & Process Safety Consultancy

EHS Specialist, SW Hub Manager, EHS VP & General Manager REVISION HISTORY

European Medicines Agency Inspections

HSES-SP Management in Contracts. HSE Prequal Questionnaire for Bidders.

HS309 Corrective Action Procedure

WM2012 Conference, February 26 March 1, 2012, Phoenix, Arizona, USA. The Sellafield Plan

Effective Process Safety Management: Introduction. Process Safety Framework. Keep it in the pipe!

Sr Dr. Mohd Saidin Misnan UNIVERSITI TEKNOLOGI MALAYSIA UTM Skudai, Johor, Malaysia

Occupational Health and Safety Management Manual v2.2

SFSSCN4 Oversee the implementation of security measures

Diversified Services. Our Diversified Services include:

Understanding Internal Controls. Federal Highway Administration New Mexico Division

REGULATORY COMPLIANCE SAVING TIME, MONEY, AND LIVES

Labour Evaluating Occupational Health and Safety Systems Follow-up

R-1 Risk Management. Policy. Organising. Planning and Implementing. Measuring Performance. Reviewing Performance

Health and and Safety Executive. Safety and Health. Paul Billinger HSE Manufacturing Sector

Process Safety Competency: Trends and Challenges. Hervé VAUDREY - DEKRA

Supplier Partnership. BPF 2123 Quality Management System

The Hard Target and Target Zero

9 1.0 Step 1 Overview of what should be considered Step 2 ISO 9001:2015 Context of an organisation

Workplace Safety Management Software Suite

INDUSTRIAL FIRMS MUST EMBED RISK BASED THINKING INTO THEIR OPERATIONS

SMS. Sƒfety Mƒnƒgement Services. Explosives Safety Training

Process Safety Management (PSM)

Process Safety Management (PSM) Program. General Company Policy

ABIOSH INT L CERTIFICATE IN HAZARD AND OPERABILITY -HAZOP- AND HAZARD IDENTIFICATION (HAZID) STUDIES - HAZOP/HAZIDCert

Further excellence. Freedom of association. How can you enhance social responsibility within your supply chain? Social responsibility Audit solutions

Risk-based oversight: who has control?

Project Remedies Solution Set s Ability to Transform your IT Organization. A Selection of Use Cases from Project Remedies Inc.

A BARBOUR GUIDE. Benefits Gained from Implementation of OHSAS18001

Safe Management of Electrical Switchgear

Assessment Tool Committed Culture

A Guide To ISO 45001:2018. The new international standard for Occupational Health & Safety. Version 1.1 Page 1 of 7

PMP Practice Questions

10 minute read. Key Takeaways. How technology supports more proactive and efficient safety management

Benefits of Implementing an Integrated Process Safety & HSE Information Management System

CORROSION UNDER INSULATION WHY CUI IS NOT THE PROBLEM A TOPICAL DISCUSSION ON THE CHALLENGES THAT DRIVE THE PROBLEM OF CORROSION UNDER INSULATION

GxP Auditing, Remediation, and Staff Augmentation

AN INTRODUCTION TO RISK BASED PROCESS SAFETY. Bob Wasileski January 6 th, REEF MEETING-

2017 Archaeology Audit Program Procedure Manual. April 2017

TABLE OF CONTENTS 1.0 INTRODUCTION...

RISK MANAGEMENT COMMITTEE TERMS OF REFERENCE

ELEMENTS OF A HIGH PERFORMING SAFETY PROGRAM

Digital Analytics as An Enabler for Operations Risk Management

AUDITING CONCEPTS. July 2008 Page 1 of 7

EOSMS Date: 05/21/2014 Page 1 of 5

The Needs of Process Safety Management in Palm Oil Industry

ISO IOSH East Midlands Branch Nottingham Forest Football Club 17 January Evolution of OHSMSs

Engagement Performance 49% Independence and Ethical Requirements 40% Human Resources 31% Monitoring 28%

A Trade Union Perspective on The New View of Health and Safety

Five Star Process Safety Audit Specification October 2017

All About OSHA. Marianne McGee. Compliance Assistance Specialist Corpus Christi Area Office

Challenge H: For an even safer and more secure railway

ESTATES DEPARTMENT Health & Safety Manager

THE IMPORTANCE OF IMPLEMENTING SUSTAINABLE OPERATIONS MANAGEMENT SOFTWARE

Transcription:

Considering industry costs and benefits for Safety Management, can we do better? www.epsc.org Richard Gowland Technical Director EPSC

EPSC EPSC is an Industry funded association of approximately 40 chemical companies EPSC has cooperative groups on IEC 61511 LOPA Buncefield Learning Experience Safety Critical Systems Ageing Facilities Competence Atypical scenarios Cooperates with Competent Authorities in Technical Work Groups And was asked to chair the Buncefield PSLG Sub group 3 on Layer of Protection Analysis (June 2008-Dec 2009) to produce guidance on best practice.

Safety Management at the establishment Creating a system tailored for the establishment: Corporate requirements Technology Risk Location International Standards e.g. ISO, IEC,OECD. Industry Standards API, NFPA,,. Local Legal requirements Eu Directives as determined by national bodies Seveso 2, ATEX, CAD,.

General Principles The best performing companies systems have a history of managing safety and environment to a high standard The cost of this is not seen as a cost to conform with Seveso 2 Seveso 2 Directive is a good framework for Safety management For the best performing companies the added cost of Seveso 2 is: Preparation of the Safety Report Enforcement/Inspection (cost difference between now and pre Seveso 2) Charges (where applied) For the regulators, the cost of Seveso 2 Is it the overall cost of the regime? or The cost difference between now and pre Seveso 2?

Steps Interpreting the different requirements of each Member State Competent Authority Local law enhancements Gap analysis comparing these detailed requirements with: establishment practices the documented system in the establishment (c.w. the Safety Report format) Closing the gaps Demonstration of conformance

Looking at the Safety Report In E. Versluis work Enforcement Matters 2003), she found that for top tier sites in 4 member states, the effort required to create the Safety Report varied widely: Highest 50 man months Lowest 7.5 man months

Looking at the Safety Report This range translates into: Highest 200M Lowest 30M This seems to be a large variation Not always explained by complexity, risk or other establishment factors. Inspector Visits during report preparation 10 man days (industry personnel cost 12000) Report Assessment costs 46000 (average). Repeats every 5 years.

For the best performers Looking at the Safety Report investment was: primarily in documentation (more recording of activity, organising in a format required) having little direct effect on the establishment s actual practices Looking at enforcement and demonstration Investment was: Increased company specialist time spent on inspection Explaining what is done Demonstrating/Proving its actual status Not directly related to risk and performance

Looking at - Demonstration Results of Inspection and auditing versus detailed requirements Performance Both relevant, but there seems to be more emphasis on the first

Demonstration COST ESTIMATE Inspection effort 20 man days per year (Source of data E. Versluis Enforcement Matters )

Actual Demonstration COST ESTIMATE from received info. Typical top tier small/medium site main hazards exothermic reactions, toxic pesticides, flammable solvents: Preparation of Safety Report Ongoing demonstration and enforcement. Seveso 2 C.A.s spend 10 man days on enforcement. Establishment staff time absorbed 20 man days Periodic Safety Report review (5 years) Seveso 2 C.A.s spend 25 man days Establishment staff time absorbed 40 man days Annualised cost: approx 40,000

Using this data for a cost benefit analysis often a part of ALARP requirement Assumption1) Individual Risk of a single fatality 1E-03 (unacceptable) Value of fatality avoided 3.00MM Future life of establishment 25 years Risk Reduction as a result of Seveso 2 demonstration = 1E-01 Cost is 15 x benefit

Using this data for a cost benefit analysis often a part of ALARP requirement Assumption 2) Individual Risk of a single fatality 1E-04 (ALARP range) Value of fatality avoided 3.00MM Future life of establishment 25 years Risk Reduction as a result of Seveso 2 demonstration = 1E-01 Cost is 140 x benefit

If the cost can be reduced by 50% Assumption 1 goes to Cost is 7 x benefit Assumption 2) goes to: Cost is 70 x benefit

Demonstration - What companies have found with their own systems Audit standards and requirements not clear (i.e. what are the standards which must be in place) Repetitive topics covered by more than 1 audit Same generic topics visited by Occupational Safety, Process Safety, Environment, Security Audit schedule does not allow significant deep drill on key subjects or observations - demonstration Too much time looking at paper and not on observation and interview - demonstration Auditor training issues Inadequate follow up/resolution of findings One size fits all No discrimination based on risk or performance Opportunities to adjust to regulator needs were missed Sometimes through inertia Sometimes because regulator needs were not expressed or were published late It was clear that we could do better

Evolving Does this help? - Self Assessment and Audit Pyramid 3 year Cycle for normal Operations. May vary by risk or performance External Review Audit to validate Self Assessment Deep drill key items. By Third party or regulator By Audit Team independent of the facility Rolling programme To achieve annual Self Assessment Self Assessment of conformance Assurance that baseline activities Are being carried out By trained Operations Self Assessors in facility Daily or weekly checks of key items by Operations, Permit to Work, Management of Change, Job Safety Analysis, Task Observation programme, critical equipment Inspection and testing, training. By Operations In many cases, it offers improvements in effectiveness and efficiency

Can this model be modified to take account of Seveso 2 Demonstration? 3 year Cycle for normal Operations. May vary by risk or performance External Review Audit to validate Self Assessment Deep drill key items. By Third party or regulator By Audit Team independent of the facility Rolling programme To achieve annual Self Assessment Self Assessment of conformance Assurance that baseline activities Are being carried out By trained Operations Self Assessors in facility Daily or weekly checks of key items by Operations, Permit to Work, Management of Change, Job Safety Analysis, Task Observation programme, critical equipment Inspection and testing, training. By Operations

Company Audit and Inspection practices - remarks It is not efficient to expect an audit to discover deficiencies which the operating staff could have found (and fixed) themselves Waiting for an audit to find a deficiency is dangerous practice Audits can be stressful experiences if they discover things you should have known about and fixed Engaging the facility staff at all levels in Self Assessment encourages: Timely remedial action Universal knowledge of requirements Improved knowledge of process hazards Process Safety Culture The use of Key Performance Indicators Self Assessment offers advantages in effectiveness and efficiency but does not replace top level of pyramid

Returning to risk and performance (avoiding one size fits all ) Self assessment: can be a rolling programme driven by subject matter experts and based on corporate requirements. Risk is understood and is a driver on methods. Audit: Risk and performance can be used to determine the frequency of audit. e.g. low risk cycle = 5 years high risk cycle = 2-3 years (primary basis scale of consequence) Performance vs API 754 or CEFIC Responsible Care metrics Poor performance merits frequent inspections Competent Authority enforcement programme may be able to advise on assist and take account of self assessment practices and adjust their own programmes based on risk and performance.

If self assessment partnerships can be created: Competent Authority specifies standards and methods Companies adjust their self assessment and audit practices Companies need to maintain or improve performance before confidence can be established Read What happened at Buncefield (HSE publications) to see how big this challenge might be.

It seems logical that: Companies need to adapt audit protocols and requirements to meet regulator expectations Establishments adapt self assessment to include regulator detail Establishments need to publish performance metrics for all aspects of safety (not just occupational safety) Process Safety performance metrics systems need to become the norm and establish confidence. Regulators publish their requirements and expectations and take account of risk and performance

.and the Benefits A plant manager said to me in 1990. Until you sent me the audit format and the pre-audit questionnaire, I did not know enough detail of the company s requirements it made me go and look and check myself! In the Seveso regime we have seen the same evolution over time. The preparation of the safety report and demonstration of conformance has improved documentation and organisation of EH&S Benefits can be quantified and compared with costs in an organised way. Risk Reduction - Benefits of incidents avoided (injury and asset) versus Costs over the lifetime of of the establishment

Can we do better? We still face the challenges of atypical scenarios. (Events we never imagined unknown unknowns) e.g. Buncefield Vapour Cloud Explosion. Making the situation described in the safety report actually happen as a way of life a challenge e.g. Buncefield reveals a huge gap between policy and practice. (Read What happened at Buncefield) Establishing credibility and trust We need a common performance metrics approach CEFIC launches Process Safety Performance metrics Can we consider a performance and risk lever in the enforcement regime Reward the good performers We can look at schemes such as the OSHA Strategic Partnership Agreements. http://www.osha.gov/dcsp/partnerships/index.html

Can we do better? Clear requirements Operator self assessment against requirements Compliance can influence self assessment Philosophy of compliance by the operator A hierarchy of self assessment through to C.A. inspection can enhance compliance and educate operator at all staff levels Cost and resource commitment for demonstration and enforcement can be reduced 50% reduction should be possible if operator meets commitments Seveso 2 art 19 para 4 amendments need to allow CAs freedom to do their jobs (see amendment 228) Dramatic effect on Cost versus Benefit.