Transcript Slide 1
“Introducing A Major Hazards Regime ”
By: Mr. Adam Radojkovic HSE Regulations & Enforcement Directorate (DG) Qatar Petroleum 19 June 2012
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Objectives of MHR
The main objectives of this Major Hazards Regime (MHR) are: a) Prevention of the harm or losses due to a major incident in a facility, plant or equipment while processing and handling hazardous substances, and b) Implementation of management strategies intended to prevent the occurrence and to minimize the consequences from realising fires, explosions or toxic gas clouds due to loss of containment of hazardous substances
Statement of Intent of MHR
a) Demonstrate Directorate (DG) approach in implementing the Minister's requirements for the control of MAH’s.
b) MHR will support the Licensing Schemes proposed in the “Technical HSE Framework”, which represents a value added to the business c) Fair, consistent and transparent approach by Directorate (DG) in dealing with the stakeholders d) Directorate (DG) will be issuing Regulations/guidelines to support the requirement of this regime, as appropriate. e) Directorate (DG) will stimulate research and development for the prevention of major accident hazards, as part of the ALARP principles and continual improvement.
Application of MHR
The scope of this framework includes the following: A.
Oil and gas operations (upstream and downstream) within concession areas (onshore & offshore) B.
C.
Chemical and Petrochemical industry Major storage and processing sites for hydrocarbon, petrochemicals/chemicals or other dangerous/toxic products D.
E.
F.
G.
H.
Pipelines Transportation Systems containing hydrocarbons, chemicals or other hazardous substances and/or handling high pressure Construction of hydrocarbon and chemical facilities and processes (onshore & offshore) Power Generation, but not distribution Refining of metals (Steel and Aluminum) Marine – Oil tankers, LNG Carriers, MODU/Jack-up rigs, production and storage vessels (FSO/FPSO), supply and boats & vessels
Application of MHR (Con’t)
When to develop a Major Hazards Regime?
Design, Construction and Commissioning Start up and Operation Decommissioning/Abandonment 5
Regulatory Approach
Prescriptive • “WHAT TO DO AND HOW TO DO IT” • The regulatory function focuses on ensuring conformity with specified requirements. Prescriptive regulation may be more appropriate where specific direction on procedures or technical standards is needed. The weaknesses of prescriptive regulation are that its inflexibility can impede the introduction of innovative practices.
Goal Oriented • “MIX OR HYBRID” • Many regulatory regimes include elements of both styles, based on the available resources and maturity of industry and regulator. provide prescription where deemed necessary and provide for latitude in the achievement of certain targets or results where appropriate Goal based • “WHAT RESULT IS REQUIRED” • The regulatory role here involves defining the high level safety standards which companies must meet, while legislation sets the broad safety goals to be attained and the operator of the facility develops the most appropriate methods of achieving those goals. The "Duty of Care" clearly rests with the operators in these cases 6
Safety Regulatory Approach
• Widely accepted trends indicate efforts in minimizing risks to ALARP and inclusion of continuous improvement practices.
• Different scenarios for control of major hazards envisaged: o OSHA-PSM, Seveso II (COMAH) or Safety Case, o o Some facilities have no system for control of major hazards in place, or Some have no HSE Management System.
• To be aligned with other guidelines drafted by DG, such as: CHEMICAL DISASTER PREPAREDNESS AND RESPONSE GUIDELINES (IHR 2005 based*) “ and “CHEMICAL SAFETY IN PORT AREAS GUIDELINES” (Guidelines for the Establishment of Programmes and Policies Related to Prevention of, Preparedness for, and Response to Accidents Involving Hazardous Substances).
* International Health Regulations
Key Elements of a MHR
Executive Summary Surrounding Environment Safety Management System (SMS) Major Accident Prevention Policy (MAPP) Organisation Processes / Operating & Maintenance Performance Process Description Major hazard identification (i.e. hazards register) Systematic Major hazards risk assessment Permit to Work System Management of Change (MoC), Equipment Criticality, etc Emergency Response Planning Performance measurement Audit & review Demonstration of Prevention, Control & Mitigation (ALARP) Self-Declaration of Compliance 8
Safety Management System
• • • • • • • • • • • • • The essential elements of a Safety Management System (SMS) are: Policy and objectives The organisation of personnel involved in major hazard management with defined roles and responsibilities in ensuring safe operation and provision of training Identification of major hazards, likelihood and severity Permit to work system Operational control, including maintenance of plant, processes and equipment; Contractors safety management Incident management and control Management of change, including design of new installations and processes; Emergencies management system Hazards communication and employee involvement Monitoring, audit and review performance of the SMS Continuous improvement Documents and records maintenance, control and reviews 9
ALARP Demonstration
• DL No. 4 (1977), Articles 3 and 4, requires that Operators manage HSE risk in an adequate manner by applying the best practices in their operations • All reasonably practicable measures are adopted to reduce risks and that the residual risks are acceptable • Demonstration of ALARP should be commensurate with the size and complexity of the facility and the level of the risk that is being considered • Risk Management process typically uses a combination of: a) Codes and Standards; b) Engineering judgment; c) Quantified Risk Assessment (QRA) and; d) Cost-Benefit Analysis 10
Self-Declaration of Compliance
Submitting entity shall include a signed statement by which the Operator commit to: (a) Operate in compliance with all relevant legal requirements, including: – management of risks to people health and safety and surrounding environment; – certification of equipment, processes, facilities, etc; – Implementation of best available practices.
(b) Effective implementation of procedures for periodical evaluation of compliance with applicable legal requirements; (c) Information provided in the MHR is accurate; (d) Operators demonstrates a detailed understanding of all aspects of HSE risks; (c) Manage the associated HSE risks and reduce them to a level that is ALARP through the effective implementation of such management systems (i.e. SMS, IMS, HSEMS); (d) Organisation has the necessary knowledge, skills and experience to undertake the tasks in the implementation of the SMS; (e) Operate with valid licenses, and permits as applicable for all their operations.
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Requirements of MHR
• A consolidated, integrated and comprehensive document (REPORT) can be used to justify/demonstrate why something is safe • Overall demonstration that the installation is operated safely justifying continuous operation • Description of the processes and procedures that are adopted for ensuring that all identified hazards and risks are reduced to a level that is ALARP • Implementation of SMS and MAPP • Clear guidelines in the way to implement 12
Acceptable MH Report
An acceptable Report will: Have an adequate safety management system (SMS) Operator has systems to keep the control measures working to the stated performance standards Identifies and evaluates the risks from Major Hazards Describes how an appropriate approach to risk assessment has been adopted Identifies and considers a range of potential measures for further risk reduction Presents systematic analysis of each identified measures and views formed on the safety benefit associated with each (ALARP demonstration) 13
Acceptable MH Report (Con’t)
An acceptable Report will: The Operator fully understand the facilities, process/systems and risks Explains the implementation (or planned implementation) of the identified reasonably practicable measures (What, when, who) Clear and consistent links between MI’s, hazards, risk controls, emergency plans, SMS and performance monitoring Justify continued safe operation confirming that risk to people is acceptable against industry criteria Describes the site emergency response plan and mutual aid programs 14
Acceptable MH Report (Con’t)
An acceptable Report will: Describes how the employee representatives were consulted on the preparation, review or revision of the report The documentation captures the corporate memory Establish arrangements for monitoring, audit, compliance and safety performance reporting The process in logical and simple – don’t over complicate. The documentation in the Major Hazards Report needs to be clear and detailed to be understood by others 15
Operators Responsibilities
1) 2) 3) 4) 5) 6) Carry out all activities within their control in such a manner that the risks are ALARP Prepare and submit MH Report Outline to DG for review Develop the MH Report for the facility with the involvement of the workforce Plan, develop, establish and implement compliance to all the requirements of MH Report at the facility Submit the MH Report to DG for assessment To operate the facility in accordance with its MH Report , and review and revise as necessary 7) 8) 9) Provide necessary support to DG and provide information for clarification & verification of the MH Report Build and operate the facilities as per MoEI licenses Report Process Safety Performance (leading and lagging) indicators in annual base to DG 10) Report Major Accidents to DG 16
Roles of DG under MHR
1) 2) 3) 4) 5) 6) Assess the MH Report against regulatory requirements and verify its implementation status at the facility Issue reports to H.E. Minister of Energy and Industry and notices to the Operators for compliance Oversee the organisation and facility’s operation for compliance monitoring with the MHR Assess the operator’s proposal for introducing new materials or major changes in process, facilities, organisation to assure that the risk remains ALARP Investigate serious (major) industrial incidents Facilitate shared learning in managing major hazards and to provide guidance material to promote best practice 17
Implementation Process
1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) 12) 13) Operator - MHR Outline submission DG -review and feed back on MHR Outline DG - attend and observe Operator MHR workshops Operator – MHR Submission (Draft) DG – Draft MHR review and feed back Operator - MHR Re -Submission (Draft 2) if required Operator - Submission of Major Hazard report DG – Review , assessment and verification of the MHR DG – Acceptance of MHR DG - Issue of compliance memo MoEI - License Approval decision DG - Supervision compliance visits DG - Relicensing of MHR (at later phase)
Issue of compliance memo MHR Outline submission Review & feed back on MHR Outline
Relicensing of MHR ( AT later Phase)
Attend & observe Operator MHR workshops License Approval decision Supervision compliance visits MHR Submission (Draft) Acceptance of MHR Review , assessment and verification of the MHR Submission of Major Hazard Report Draft MHR review and feed back MHR Re–Submission (Draft 2) if required
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