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Major Hazard Facilities

Major Hazard Facilities. Safety Management Systems. 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. Some Abbreviations & Terms. AFAP - As far as (reasonably) practicable

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Major Hazard Facilities

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  1. Major Hazard Facilities Safety Management Systems

  2. 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

  3. 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

  4. 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

  5. Regulations Occupational Health and Safety (Safety Standards) Regulations 1994

  6. 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

  7. 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

  8. 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

  9. 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

  10. Examples of SMS OH&S 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

  11. Environmental Policy Planning Implementation & Operation Checking & Corrective Actions Management Review Examples of SMS ISO 14001 Environmental Management Systems

  12. Policy Planning Implementing Assessing ManagementReview Key Elements of the SMS From the previous examples, there are common elements

  13. Policy Planning Implementing Assessing ManagementReview Key Elements of the SMS Effective health and safety policies set a clear direction for the organisation to follow

  14. Policy Planning Implementing Assessing ManagementReview 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

  15. Policy Planning Assessing ManagementReview 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

  16. Policy Planning Implementing ManagementReview Key Elements of the SMS Performance is measured against agreed standards to reveal when and where improvement is needed. Assessing

  17. Policy Planning Implementing Assessing Key Elements of the SMS The organisation learns from all relevant experience and applies the lessons. ManagementReview

  18. 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

  19. The Importance of SMS The following information provides broad details on some US incidents and contributing causes

  20. The Importance of SMS Breakdown of management system categories identified as contributing causes in incident investigations

  21. 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

  22. 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

  23. 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

  24. 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

  25. 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?

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

  27. 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?

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

  29. 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

  30. 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

  31. 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

  32. 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

  33. 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

  34. 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

  35. 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

  36. Corporate Safety Management System 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

  37. 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

  38. 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

  39. 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?

  40. 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?

  41. 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

  42. 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.

  43. 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:

  44. Examples of SMS Performance Indicators

  45. 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

  46. 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?

  47. 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

  48. 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

  49. 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

  50. 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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