Major Hazard Facilities

1
Major Hazard Facilities

• Introduction to Safety Report

2
Some Abbreviations and Terms

• AFAP - As far as practicable
• BPCS Basic process control system
• Employer - Employer who has management control of
  the facility
• FTA Fault tree analysis
• HAZOP Hazard and operability study
• HSR - Health and safety representative
• LOPA Layer of protection analysis
• MHF - Major hazard facility as defined in the
  regulations
• MA - Major accident
• OHS -Occupational health safety
• QRA Quantitative Risk Assessment
• SMS - Safety management system

3
Topics Covered in This Presentation

• Introduction
• Key principles and objectives of the MHF
  regulations
• Why is a Safety Report needed?
• What is the Safety Report?
• What must the Safety Report do?
• Main components of the Safety Report
• Hazard identification
• Safety assessment
• Risk controls
• Emergency response plans

4
Topics Covered in This Presentation

• Demonstration (of adequacy)
• What else is in the safety report?
• MHF regulations versus process
• Sources of additional information
• Review and revise
• Conclusion
• Examples of major accidents

5
Introduction

• This seminar is a basic introduction to the
  Safety Report that is required under the MHF
  Regulations.
• It has been developed for the following purposes
• To provide a simple overview
• To be suitable for new MHF Employers
• Outline the reason for a safety report
• Overview of all parts of a safety report
• Show examples of major accidents

6
Key Principles of MHF Regulations

• Focus on major hazards (catastrophic events i.e.
  typically high consequence and low frequency)
• Requires a proactive risk based approach
• Places the responsibility on the Employer
• Employer has to actively demonstrate safe
  operation

7
Key Principles of MHF Regulations

• Consultation with different parties required at
  all critical stages
• Facilitate culture change at major hazard
  facilities
• Regulator peer review, tied to a licence
• Addresses both on-site and off-site safety

8
Focus of MHF Regulations
Increasing risk
Minor risks
Very high risks should already be eliminated
after risk assessment
Relative Frequency of Occurrence
OHS risks already regulated





Consequence Severity
9
Objective of the MHF Regulations

• The objective of the MHF Regulations is to
  provide for the safe operation of major hazard
  facilities to
• Reduce the likelihood of an MA occurring
• Reduce the consequences to health and safety and
  damage to property in the event of an MA
  occurring

10
MHF Regulations

• Specific parts of the MHF Regulations relevant
  for this seminar are
• Hazard identification (9.43)
• Risk assessment (9.44)
• Risk control measures (9.45)
• Safety management system (9.46)
• Emergency planning (9.53)
• Provision of information to the community (9.50)

11
Why is a Safety Report Needed?

• There is a need for specific control of major
  hazards due to
• Changing scale and complexity of specific
  facilities
• Advances/changes in technology - unforeseen
  hazards
• Changing community perceptions
• Range of major accidents that have occurred
• Prescriptive approach has proven inappropriate

12
Why is a Safety Report Needed?

• Some major accidents that have occurred
• Coode Island, Australia storage terminal fire,
  August 1991, 0 dead, 0 injured
• Longford, Australia explosion and fire,
  September 1998, 2 dead, led to the development of
  Victorian MHF legislation
• Entschede, Holland fireworks factory explosion,
  May 2000, 21 dead, 1,000 injured
• Texas City, USA fire and explosion, March 2005,
  15 dead, over 170 injured

13
Why is a Safety Report Needed?

• Port Kembla Ethanol Tank Fire, NSW, Australia,
  28th January 2004

Quote from the Coronernot a lack of adequate
safety procedures but rather the failure to
adhere to them. (Welding was carried out in an
unsuitable area without a hot work permit)
14
Why is a Safety Report Needed?

• This has led to Regulations where
• The Employer knows what technical and human
  activities occur
• The Employer decides on the appropriate means of
  major hazard control for the facility, and
  prepares a Safety Report explaining this
• The Regulator assesses and audits performance
  adequacy against the safety report

15
Why is a Safety Report Needed?

• The introduction of regulations were fast
  tracked in Victoria primarily as a result of the
  Royal Commission into the incident at Longford in
  1998.
• The Victorian MHF regime is now mature and is
  working well.

16
What is the Safety Report?

• The safety report must address all hazardous
  events that could result in MAs that pose serious
  danger or harm to
• Persons
• The community
• Property
• The environment

17
What is the Safety Report?

• A safety report is a detailed document that
  outlines
• The identification and control mechanisms in
  place to prevent and mitigate all MAs for the
  facility
• The types of safety studies undertaken
• The results obtained for such studies
• The management arrangements in place
• to ensure the continued safety of the facility
  and its people and the surrounding community.
• The safety report must be prepared in
  consultation with employees and be a true
  reflection of the state of the safety
  arrangements for the facility.

18
What is the Safety Report?

• The Role of the Safety Report
• Regulatory role The primary document used by an
  approved assessor to verify that the facility is
  operated safely to support the Employers licence
  application.
• Information Repository Contains all information
  about the safe operation of the facility which
  contributes to continuous improvement of safety
  at the facility.

19
What Must the Safety Report Do?

• Document the state of safety arrangements for the
  facility
• Demonstrate to the satisfaction of the
  Commission, through content and supporting
  material, that
• The employer knows what technical and human
  activities occur
• How activities are managed
• How safety will be managed in the event of an
  emergency

20
What Must the Safety Report Do?

• Identify methods to be used for monitoring and
  reviewing all activities for continual
  improvement of the safety arrangements of the
  facility over its lifetime.

Review
Monitor
Safer Facility
Improve
21
The Safety Report Should

• Reflect the facility safety culture
• Contain information about the facility and
  interaction with its surroundings
• Describe the systems used to achieve safety
• Identify, assess and show controls for potential
  major accidents
• Demonstrate ongoing consultation between the
  employer and workforce
• Be integrated into the Employers management
  systems rather than a collection of separate
  individual safety studies

22
Safety Report Timeline
Refer Guidance Booklet 4 for this timeline
23
Main Components of a Safety Report

• The main components of the safety report are
• Facility description
• Risk assessment
• Hazard and MA identification
• Risk control measures
• Safety management system description
• Emergency response plan
• Demonstration of adequacy
• Control measures
• Safety Management System

24
Facility Description

• History
• Daily operations
• Schedule 9 materials and their characteristics
• Demographic description
• Facility topography meteorological data
• Simplified process flow diagrams
• Site layout drawings
• Location plans, surrounding facilities and
  sensitive neighbours
• Proposed changes

25
Risk Assessment Requirements

• Hazard identification for determining MAs
• Risk assessment studies for determining
  controls
• Risk evaluation - for determining risk
  acceptability
• Recommendations and review for continuous
  improvement

26
Hazard and MA Identification

• Hazards that can lead to major accidents are
  identified. From these, MA scenarios can be
  developed for further analysis.

Process Hazard Studies (HAZOP/What If)
Past Risk Assessments
Unit Technical Review Input (Specialist Review)
Incident History (internal / external)
Dangerous Goods Present and Material Properties
Major Accident Event Grouping
27
Risk Assessment

• The information for assessment can be presented
  as a bow-tie diagram

28
Example Layer of Protection Analysis
Risk Assessment

• Analysing the safety measures and controls that
  are between an uncontrolled event and the worst
  potential consequence - risk reduction study

29
Risk Assessment

• Example Risk Matrix

30
Description of the Safety Management System

• A comprehensive and integrated management system
  for all aspects of control measures adopted
• Documented and describes how compliance is to be
  achieved
• Site safety philosophy and how it is reflected in
  the SMS
• Safety policy and safety objectives
• Organisation and personnel responsible for the
  implementation and compliance with the SMS
• Major features/elements of the SMS
• SMS performance monitoring processes
• Consultative processes used to develop and
  implement the SMS

31
OHS Management System Model AS 4801
Overall vision, goals and commitment to improve

• Suitable, adequate, effective
• Changes needed?
• Opportunities to improve?

• Legal compliance
• Objectives and targets
• Implementation plans

• Resources
• Leadership responsibility
• Training and competency
• Consultation and communication
• Documentation
• Hazard identification, risk assessment and
  controls
• Emergency response

• Monitoring and measurement
• Incident investigation
• Records management
• Audits

32
Emergency Response Plans

• Promote preparation
• Ensure necessary equipment is available
• Ensure personnel are trained and prepared to
  respond
• Identify communication methods
• Identify community resources
• Consultation with emergency services, local
  council community

33
Emergency Incident Scenario Plans

• Analysis of the consequences of specific MAs to
  determine fire fighting access and to identify
  affected areas
• Determination of firewater and foam requirements
  for extinguishing the fire and/or protecting
  affected equipment
• Available as a resource for training

34
Demonstration of Adequacy

• The safety report must demonstrate that the
  Employer is achieving safe operation of the
  facility by
• Use of adequate control measures
• Satisfactory management systems

35
Demonstration of Adequacy of Control Measures

• Controls linked to hazards and proportionate to
  risk
• Depth and breadth of control measures
• Performance indicators defined and performance
  monitored
• Risk has been reduced AFAP
• Standards, industry practices
• Decisions are documented and justifiable
• Improvement programs past and future

• More information is available in the Comcare
  guidance Booklet 3 (control measures).

36
Demonstration of Adequacy of SMS

• Comprehensive and Integrated
• Performance standards for the control measures
  are defined
• Control measures are monitored and failures are
  addressed
• Adequate education and training is provided for
  employees
• Processes are provided for review and revision of
  control measures
• Sufficient resources are provided,
  responsibilities, accountabilities defined
• Planning, implementation and monitoring processes
  are provided for control measures and the system
  as a whole
• More information is available in Booklet 3 (SMS)

37
What Else is in a Safety Report?

• Detailed Risk Assessment Records
• Risk analysis of the hazards on site. E.g.
• LOPA
• FTA
• Risk matrix
• QRA
• Provides a more detailed analysis of
  causes/frequency/consequences/controls for each
  identified MA
• Assessment of off-site risk
• Comparison of risk reduction options

38
What Else is in a Safety Report?

• Occupied Buildings Risk Assessment
• Analysis of the impact of MAs on occupied
  buildings
• Mainly risks (due to flame impingement,
  explosions, toxic gas) from other
  buildings/operations

39
What Else is in a Safety Report?

• Risk Assessment Procedures
• Details of all the hazard and risk assessment
  work documented in procedures and referenced
• Procedures provide step by step guidance on how
  the assessments were undertaken enables
  corporate memory retention
• Consistency of approach for all assessments
• Justification for selection of risk assessment
  processes
• Resources/guidance for the conduct of future
  assessments

40
What Else is in a Safety Report?

• Community Consultation
• Community consultation philosophy
• Summary of Safety Report information for
  community
• Community bulletins

41
What Else is in a Safety Report?

• Recommendations and Improvements
• Identification of opportunities to reduce risk
  via risk assessments
• Recommendations are assessed and prioritised

42
MHF Regulation vs. Suggested Process
43
MHF Regulation vs. Suggested Process
44
Review Revision

• Employers must review (and revise) the safety
  report for an MHF to ensure risks remain reduced
  AFAP
• Prior to modification
• When new information becomes available regarding
  possible MA hazards previously unknown
• Upon licence renewal conditions or at least every
  5 years
• At the direction of the Commission
• After a major accident

45
Conclusion

• The safety report must demonstrate adequacy of
  all Safety Duties required by the MHF regulations
• Safety Duties are ongoing requirements
• An Employer at a MHF who fails to comply with the
  MHF regulations may be subject to civil
  proceedings or criminal prosecution under the OHS
  Act.

46
Sources of Additional Information

• Part 9 of the Occupational Health and Safety
  (Safety Standards) Regulations 1994
• Major Hazard Facility Guidance Material Comcare
  website www.comcare.gov.au
• WorkSafe Victoria www.workcover.vic.gov.au
• NSW Major Industry Hazard Advisory Papers 1 to 9
• Centre for Chemical Process Safety
• UK Health and Safety Executive, www.hse.gov/comah

47
Questions?
48
Publicly Available Data/Incidents

• Several examples of incidents are available.
  These include
• Tosco Avon refinery fire incident, Martinez
  California, 23rd February 1999 (source U.S.
  Chemical Safety and Hazard Investigation Board,
  Report No. 99-014-1-CA, issue date March 200)
• Buncefield fire, December 2005 (source UK HSE)
• Dubai Dry Dock Incident (source Web site, US
  Naval Sea Systems Command)

49
Buncefield Incident (UK) December 2005.

• In the early hours of Sunday 11 December 2005, a
  number of explosions occurred at Buncefield Oil
  Storage Depot, Hemel Hempstead, Hertfordshire
• At least one of the initial explosions was of
  massive proportions and there was a large fire,
  which engulfed a high proportion of the site
• Over 40 people were injured fortunately there
  were no fatalities

50
Buncefield Incident

• Off-Site Consequences
• Significant damage to commercial and
  residential neighbours
• ?2000 people evacuated
• Sections of M1 Motorway closed
• Very large smoke plume over Southern England ?
  Air pollution
• Large quantities of foam and water ?
  contaminated water courses and ground water

51
Buncefield Incident

• HSE/EA investigation determined the direct cause
  (initiating event) as follows
• Tank 912 . overflowed at around 05.30 hours
  .. while being filled at a high rate
• Large vapour cloud formed and flowed off-site
• First explosion at 06.01 hours
• There were multiple root causes (failures)
  identified
• Many related to management system failures
• Still some unanswered questions
• Why was there so much explosive force?

52
Buncefield Fuel Storage before incident
53
Buncefield during the incident
54
Buncefield after the incident
55
Dubai Dry Dock Incident

• On 27 March, 2002 in Dubai there was a breach and
  failure in one of the dock gates that caused
  uncontrolled flooding in the dry dock.
• Several vessels were set on blocks inside the dry
  dock at the time of the failure. The vessels
  included the large vessel "Key Burmuda," a cargo
  barge and the accommodation barge "SEP 350.

56
Dubai Dry Dock Incident

• The dry dock gates failed at 09.30 during a
  working day.
• The dock is 500 metres long by 100 metres wide
  and 11 metres deep.

57
Dubai Dry Dock Incident

• Everything looks normal!!

58
Dubai Dry Dock Incident
Moments after the first breach at 0930 on 27.3.02
59
Dubai Dry Dock Incident

• Larger vessels coming off the blocks

60
Dubai Dry Dock Incident

• Cargo barge getting ready to roll. Many trapped
  inside, a few on deck getting ready to jump

61
Dubai Dry Dock Incident
KEY BERMUDA coming off blocks. INDRA-1
swinging towards rig
62
Dubai Dry Dock Incident
Accommodation barge SEP 350 sinking
63
Dubai Dry Dock Incident
SEP 350 touching bottom
64
Dubai Dry Dock Incident
The aftermath. Official reports account for 26
persons killed.