Major Hazard Facilities

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Major Hazard Facilities

• Safety Management Systems

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Overview

• The seminar has been developed to provide
• Context with MHF Regulations
• An overview of what is required
• An understanding of the SMS and why it is
  important

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Some Abbreviations Terms

• AFAP - As far as (reasonably) practicable
• Employer - Employer who has management control of
  the facility
• ER or ERP - Emergency response or Emergency
  response plan
• Facility - any building or structure at which
  Schedule 9 materials are present or likely to be
  present for any purpose
• HAZID - Hazard identification
• HSR - Health and safety representative
• LOC - Loss of containment
• LOPA Layers of protection analysis
• MA - Major accident
• MHF - Major hazard facility
• MOC Management of change
• OHS - Occupational health safety
• SR - Safety report
• SMS - Safety management system

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Topics covered in This Presentation

• Introduction
• Regulations
• What is a safety management system?
• SMS models and standards
• Key elements of the SMS
• The importance of SMS
• What should the SMS do?
• Measurement of performance
• Examples of SMS performance standards
• Emergency planning
• SMS testing
• Items to note
• Critical success factors
• Sources of additional information

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Regulations
Occupational Health and Safety (Safety Standards)
Regulations 1994
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What is a Safety Management System?

• An SMS is a comprehensive and integrated system
  that ensures that all work at the facility is
  conducted safely
• It should be fully documented, accessible and
  comprehensible to those that need to use it
• It recognises the potential for errors and
  establishes robust defences (control measures)
  which are fully implemented, to ensure that
  errors do not result in accidents or near misses
• It is comprises a set of work practices and
  procedures for monitoring and improving the
  safety and health of all aspects of the operation
  

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Key Terms Used in Describing the SMS

• Comprehensive
• Describes the way that all safety issues
  including control measures are managed
• Clear link between controls management and the
  SMS
• Integrated
• The structure is logical, systematic
• Logically ties in to other management systems
• Corporate systems do not contradict onsite
  systems
• Comprehensible
• Abbreviations and terms used mean something to
  employees
• Consideration of language issues

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Key Terms Used in Describing the SMS

• Implemented
• Procedures are approved and in circulation
• Evidence is available completed forms and/or
  checklists
• Employees are trained and knowledgeable
• Accessible
• Employees are aware of how to obtain the most up
  to date or relevant procedures
• Employees can obtain the SMS information needed
  to support control measures

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SMS Models Standards

• Sound management systems are all similar in
  fundamental terms
• Compliance with the MHF Regulations does not
  require any particular standard to be used, nor
  will compliance with an existing management
  standard ensure compliance with the SMS
  requirements of the MHF Regulations
• There are a variety of ways in which the SMS can
  be structured. Most large organisations will
  have their own structure already
• However, adoption of a proven standard may assist
  an MHF employer

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Examples of SMS
OHS Management Systems 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

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Examples of SMS
ISO 14001 Environmental Management Systems
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Key Elements of the SMS

• From the previous examples, there are common
  elements

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Key Elements of the SMS
Effective health and safety policies set a clear
direction for the organisation to follow
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Key Elements of the SMS
An effective management structure and
arrangements are in place for delivering the
policy. There is a planned and systematic
approach to implementing the health and safety
policy
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Key Elements of the SMS
The policies and procedures are put in place to
manage all aspects of the control measures that
ensure safe operation of the facility
Implementing
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Key Elements of the SMS
Performance is measured against agreed standards
to reveal when and where improvement is needed.
Assessing
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Key Elements of the SMS
The organisation learns from all relevant
experience and applies the lessons.
Management Review
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The Importance of SMS

• In reviews of accidents, a common thread
  throughout is the inadequacy of management
  systems that might have prevented the accident
  from occurring
• Examples of some issues identified are
• Lack of hazard review and risk assessment to
  predict and prevent incidents
• Insufficient investigation and follow up after
  previous incidents
• Inadequate training of staff
• Failure to implement effective mechanical
  integrity programs

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The Importance of SMS
The following information provides broad details
on some US incidents and contributing causes
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The Importance of SMS
Breakdown of management system categories
identified as contributing causes in incident
investigations
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The Importance of SMS

• Flixborough 1974
• Management of modification failure
• Inadequate experience
• Overstretched resources
• Piper Alpha 1988
• Failures in shift handover
• Permit to work
• Training
• Communications
• Auditing

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The Importance of SMS

• Pasadena 1989
• Maintenance
• Permit to work errors
• Failure to follow-up on audits
• Longford 1998
• Inadequate knowledge of hazards
• Absent personnel
• Poor procedures

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The Importance of SMS
BP America Refinery Explosion Texas City, 23
March 2005

• Corporate safety oversight, including the safe
  management of sites obtained through mergers and
  acquisitions
• Corporate safety culture
• Corporate and site SMS
• Near miss reporting and investigation programs
• Mechanical integrity programs
• Hazard analysis programs
• Change management

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The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005

• In the early hours on Sunday 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

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The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005

• What control measures
• Were in place?
• Could have been in place?
• Were they effective?

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The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
Common theme failure to manage the control
measures
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The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005

• What SMS elements were needed to ensure that the
  control measures worked when required?

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The Importance of SMS - Exercise
Buncefield Explosion, UK, 11 December 2005
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The Importance of SMS Australian Experience

• Feedback from regulator site visits to Australian
  MHFs, together with examination of incident data
  has revealed the following issues are likely to
  be the weakest links within an SMS
• Management of 3rd parties
• Maintenance procedures and systems
• Hazard identification and analysis
• Engineering design and review
• Operating procedures
• Management of change

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The Importance of SMS Australian Experience

• Other issues to note
• There are always fundamental failings in the
  system
• Complacency and safety versus production
  conflicts
• Deficiencies in practice with adherence to
  application of the SMS rather than system
  standards
• Failure to accept and prepare for emergencies

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What Should the SMS Do?

• The SMS is the tool with which the Employer meets
  the overall goal of the Regulations
• The SMS should cover the following
• Define safety roles and responsibilities
• Ensure adequate skills, information, tools and
  decision-making are present in day to day and
  abnormal operations
• Maintain awareness of hazards and risks
• Plan, implement, measure and evaluate MA controls
  and the SMS
• Develop performance requirements
• Set targets for improvement of safety at the
  facility
• Manage change

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What Should the SMS Do?

• Manage and maintain knowledge
• Instigate HAZID and risk assessments
• Manage adequate human resources
• Provide performance information to all levels of
  organisation
• Review and improve the SMS itself

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What Should the SMS Do?

• Manage safe operation at the facility, including
  MAs, specifically focusing on
• Prevention
• Reduction
• Mitigation
• It is not just documentation - it is the actual
  implementation of processes, procedures and
  practices at the facility
• Include and reflect the safety culture at the
  workplace

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What Should the SMS Do?

• Some companies, in particular employers of
  multiple sites, may apply corporate standards for
  an SMS
• These may prescribe the entire SMS, or only
  common high-level components such as the overall
  policies and procedures
• In other cases corporate SMS requirements may be
  very limited, and the site will then need to
  develop its own systems

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What Should the SMS Do?

• Many corporate systems specify that local
  regulations override corporate requirements if
  they are more stringent
• Other companies may employ integrated management
  systems for the business as a whole
• It is entirely up to the Employer to choose how
  the SMS is structured and developed
• However, in all cases the SMS must provide a
  management focus on the specific control measures
  required for safe operation of the particular
  facility

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What Should the SMS Do?
Level 1
Local procedures and practices (design,
maintenance operation)
Level 2
Accidents
Level 3
Hazards
Consequences
Causes
Mitigation Controls
Prevention Controls
MA Potential
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What Should the SMS Do?

• The SMS should not just be seen as satisfying MHF
  requirements
• It should be used as a performance management
  tool to assist in managing the entire operation,
  including other performance based regulatory
  requirements
• Most modern management system standards or
  "models" feature a set of generic elements,
  forming a continual improvement cycle

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Measurement of Performance

• Performance standards/indicators must be
  developed and implemented as part of the SMS
  (e.g. measure the effectiveness of SMS) to
  support the MHF safety objectives
• The following principles apply in defining
  performance standards Make them SMART
• Specific
• Measurable
• Achievable
• Realistic
• Targeted
• The purpose of performance standards/indicators
  for the SMS is to enable the objective
  measurement of its target and (subsequently)
  effective maintenance and improvement of
  performance

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Measurement of Performance

• Standards and systems need to be practical
• Should not place an unworkable burden on
  employees
• Ensure open, comprehensive and accurate reporting
  of errors or problems
• Is an absence of evidence of problems really
  indicating high performance?

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Measurement of Performance

• Performance indicators need to be meaningful and
  contribute to the overall evaluation of the SMS
  effectiveness
• If a control is stated to be in place for
  prevention of an MA, then
• Is it implemented?
• Is it effective?
• Is it audited?
• Are the results used for improving the
  effectiveness of controls management?

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Measurement of Performance

• Performance indicators should be established
  covering (as a minimum)
• How often audits are to be undertaken
• Scope of the audits
• Are the controls implemented?
• Are the controls functional?
• compliance, partial compliance and non
  compliance
• Performance indicators should be sufficiently
  detailed and transparent to enable the
  effectiveness of the SMS to be apparent from the
  documentation

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Measurement of Performance

• The audits need to be evaluated against criteria
  developed by the MHF
• They should include steps to continually improve
  the SMS, so there needs to be processes and
  measures designed to identify and implement
  improvements to the system itself
• Three main types of audits
• First audit Self audit
• Second party audit of suppliers
• 3rd party external agencies e.g. regulator,
  certification bodies.

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Measurement of Performance

• Likewise, 100 compliance is a desirable
  objective - but realistically not practical
• Setting a tiered acceptability criteria could be
  an option

Example only
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Examples of SMS Performance Indicators
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Items to Note - Emergency Planning

• The MHF must prepare an emergency plan addressing
  the on-site/off-site consequences
• Must consult with employees and emergency
  services
• Plan should consider
• Accident type (e.g. major/minor, environmental,
  personal safety, on-site, off-site, property
  damage)
• Command hierarchy and contact information
• Equipment required
• Contingency plans
• Plan should be tested, reviewed, updated

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Items to Note - Management of Change

• Management of change needs to be considered very
  carefully within the safety report
• An issue often discussed is
• When is a change really a change?
• When is a change not a change?

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Items to Note - When is a change really a change?

• Any change to an MHF needs to be evaluated in the
  context of the safety report
• Examples of this include but are not limited to
• Organisational change
• Addition of a new unit
• Closure of a unit
• Any modification to a potential MA
• Desired Outcome Demonstrate that at least the
  same level of risk or lower is achieved after the
  change and that all the processes within the
  safety report are followed and transparent

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Items to Note - When is a change not a change?

• Any change to an MHF that involves swapping like
  for like is not considered to be a change
• This assumes the equipment or systems being
  changed are fit for purpose

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Items to Note - Incident Investigations

• Incidents that occur or could have occurred at an
  MHF are a valuable source of information
• As with good practice, all incidents at a
  facility should be reviewed for lessons learned
  and their findings implemented for prevention in
  the future
• For an MHF, investigation of MAs is of particular
  importance as it will provide insight into the
  mechanism of occurrence

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SMS - Critical Success Factors

• Adequate resources for both development and
  improvement
• Personnel are aware of their responsibility and
  accountability
• Personnel are trained/competent
• Consistent with the understanding of risk gained
  from the risk assessment
• There should be sufficient focus on MAs, from
  planning through to operations
• The Employer must document the basis for the
  facility's SMS, and the SMS itself

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SMS Critical Success Factors
Comprehensive and Integrated

• Adequate resources for both development and
  improvement
• Responsibilities accountabilities defined
• Adequate education and training is provided for
  employees
• Covers the whole facility as defined in the
  safety report
• Employees know how to access it and understand it
• Performance indicators standards for the
  control measures and the SMS as a whole are
  defined
• Planning, implementation and monitoring processes
  are provided for control measures and the system
  as a whole and failures are addressed
• Processes are provided for review and revision of
  control measures and the SMS
• More information is available in Booklet 3 on the
  SMS

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Review and Revision

• The SMS needs to be reviewed on a regular basis
  to ensure it is fit for purpose for management of
  an MHF
• Over a period of time the lessons learned
  together with results of performance reviews
  should enable improvements to be documented

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Sources of Additional Information

• Safety Management, Hazardous Industry Planning
  Advisory Paper No. 9, Guidelines for the
  Development of Safety Management Systems,
  Department of Urban Affairs and Planning, 1995
• AS/NZS 48012001, Occupational Health and Safety
  Management Systems
• Specification with Guidance for Use, Standards
  Australia,15 November 2001
• General Guidelines on Principles, Systems and
  Supporting Techniques, Standards Australia,15
  November 2000

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Sources of Additional Information

• AS/NZ ISO 90012000, Quality Management Systems
• AS/NZ ISO 140012004, Environmental Management
  Systems
• API Recommended Practice 750, Management of
  Process Hazards
• API Publication 9100, Model Environmental Health
  and Safety Management System and Guidance

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Sources of Additional Information

• UK Health and Safety Executive HSG65, Successful
  Health and Safety Management
• US Department of Labour. OSHA Standard CFR 29
  1910.119, Process Safety Management
• AIChE, CCPS, Guidelines for Implementing Process
  Safety Management Systems
• Management System Failures Identified in
  Incidents Investigated by the U.S. Chemical
  Safety and Hazard Investigation Board, Angela S
  Blair PE Chemical Incident Investigator, Process
  Safety Progress, December 2004, Volume 23, No.4

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Questions?