Transcript Major Hazard Facilities - Preparing and Managing a Safety

Major Hazard Facilities
Preparing and Managing a Safety Report
Overview
The seminar has been developed to provide:
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Context with the MHF Regulations
An overview of what is required by an employer who needs to
prepare and maintain a safety report.
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Some Abbreviations and Terms
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AFAP - So far as practicable
ER or ERP - Emergency response or Emergency response plan
HAZID – Hazard Identification
HSR - Health and safety representative
MHF - Major hazard facility – as defined in the Regulations
MA - Major accident
OHS -Occupational health & safety
Employer - Employer who has management control of the
facility
SMS - Safety management system
SRO – Safety report outline
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Topics Covered In This Presentation
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Introduction
Preparing a safety report
What makes a good safety report
Safety report outline - Core components
Potential pitfalls
Key success factors
Managing and maintaining a safety report
Review and revision
Safety report for a new project
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Preparing a Safety Report
Understand
Requirement
s
Planning
Consultation & Communication
Project Management
Management
Commitment
and Support
So this is what’s
required
Resources, Tools
and Systems
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Management Commitment and Support
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The safety report should feature in, and be consistent with,
business goals and objectives
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The process is resource and time intensive so commitment for
significant funding and employee time is required
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Consistency with company policy, philosophy and objectives is
necessary to maintain and sustain a compliant safety report
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Essential that upper management show strong commitment,
drive the process and provide the environment for the facility to
develop, implement and maintain the safety report
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Know The Regulatory Requirements
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Read the Regulations !!!
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Be sure to interpret the Regulations in the context of your facility
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Define the relationships between the safety report / MHF
requirements and other OH&S management activities
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Clarify any points of the Regulations that are not understood. Do
this early as several matters require compliant practice from the
very beginning of the activity (eg consultation)
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The MHF Regulations are relatively simple to grasp albeit difficult
to comply with
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Safety Report Planning
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Proper planning is an
essential element in preparing
a safety report
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An effective plan will cover all
aspects of safety report
development (or review and
revision) including important
aspects such as consultation
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Safety Report Planning
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Definition of tasks to be completed
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Definition of constraints in place
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What resources do you have access to, funding available, regulatory
timeframes etc
Definition of task inter-relationships
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What do you need to do ?
What has to come first, which tasks rely on information from
another task, what are the constraints on availability of resources?
etc
Identification and allocation of resources to each task
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Who is needed to complete each task?
What other projects/tasks are competing for the same resource?
What tools, equipment or systems will you require?
What data will you generate and how will you store, use and
manipulate this data?
What resources will you use to monitor progress?
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Safety Report Planning
Other elements in the safety report plan:
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Estimation of task completion times and definition of task
milestones in overall project schedule
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Consultation and reporting plan for the project –
who needs to be involved, who needs to be informed?
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A clear project organisation structure detailing roles,
responsibilities & reporting lines for project activities
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Safety Report Planning
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Safety report outline for new safety reports
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Review/revision plan for update of an existing safety report
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Employees and HSRs should be briefed on the proposed plan to
achieve a common understanding and agreement of what is
required
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Acceptance by upper management of the resource requirements,
process, and commitment is essential
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Resources, Tools and Systems
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Safety report development is a resource intensive process
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Expect that high levels of employee participation are needed
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Plant operators, maintenance personnel, plant managers,
engineers, OH&S personnel, consultants, support personnel,
administrative personnel, HSRs, contractors and corporate
managers are all likely to be involved to a significant extent
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Often spin-off projects are identified to address deficiencies in
related support systems (e.g. training systems, document
management systems, IT systems)
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Core safety report development roles are not always best served
by part time roles
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Resources, Tools and Systems
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Attempt to identify early any important tools which may be
required. For example, are CAD drafting facilities required to
update drawings? Will access to certain database information be
required? What reference materials must be sourced?
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Early consideration on how to record, store, manipulate and use
the vast quantity of data generated from the safety report
development process is recommended
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Where existing systems, tools etc are to be used for the safety
report tasks, it is prudent to verify early that those systems and
tools will provide compliant outcomes
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If the systems and tools of third parties (e.g. consultants) are to
be utilised, the employer should include tasks to test and verify
the adequacy of these for achieving a compliant safety report
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Availability of Resources
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The significant effort and time commitment required to complete
activities such as hazard identification and risk assessment can
be wasted if all relevant facts and knowledge are not available
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Early consideration and coordination with many people is
generally required
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An objective evaluation of available skills is necessary to ensure
additional expertise can be sourced where necessary
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A low tolerance approach to workshop non-attendance is often
required from senior management level. Workshops may be
arduous, time consuming and often repetitive. Management and
HSR support is required to overcome this
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Plant and corporate managers need to agree and commit to the
safety report program, and manage conflicting
demands on resources accordingly
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Project Management
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The safety report plan needs to not only be defined, but also
tracked and monitored to ensure successful completion by the
due date and within all constraints
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Good project management is required to ensure tasks are
completed on schedule, over-runs are identified early and
rectified, barriers to achieving compliance are identified and
overcome
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Consider the need for dedicated project resources (e.g. Safety
Report Manager) to ensure process is not derailed by conflicting
responsibilities
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Quality Assurance
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A great deal of effort and resource is expended by facilities in
developing and documenting safety report components. It is
important that this effort is accurately reflected in the final
documentation
Facilities should be careful to ensure data presented in their
submitted safety report is:
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Accurate
Consistent
Unambiguous
Complete
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Safety Report Outline (SRO) – Core Components
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Safety report philosophy
Scope of work to be undertaken
Resources, timetable, milestones
Key definitions and criteria (risk, property damage)
Methodology statements (HAZID, risk assessment etc.)
Details of the scope of consultation that will be undertaken
The emergency plan
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SRO Core Components - Safety Report Philosophy
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Inherent risks within the facility
Chief methods of ensuring safe operation at the facility
Description of safety management system
Safety culture within the organisation
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SRO Core Components – Description of Methods
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The methods chosen for hazard identification and risk
assessment are likely to have a major impact on resource
requirements and timeline
Identify these early in the safety report planning
The methods used should align with the approach to safety
adopted at the facility
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SRO Core Components - Consultation
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The MHF Regulations require you to consult with employees
and external stakeholders during the development of the
safety report
The safety report outline should describe:
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Who will be consulted
How the consultation will occur
How the information from the consultation will be included in
the safety report
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SRO Core Components - Consultation
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Who do you have to consult?
7 main groups of people
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HSRs
Employees
Emergency Services
Municipal Council(s)
Non-employees who enter the facility (e.g. contractors)
Local Community
Other persons who may reasonably
suspect risk to their health and safety
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SRO Core Components - Emergency Plan
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Emergency Plans exist because things can go wrong and
preparation is needed for such an event
Emergency Plans are more than response procedures; they also
include the supporting framework of training, resources,
performance measures and drills etc
Consultation with all emergency services is necessary (because
they have a role to play in combating incidents and provision of
resources)
Emergency Plan must be adopted as a control measure and as
such the development of meaningful performance measures and
indicators is required
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What Makes a Good Safety Report?
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All parts of the Regulations are systematically addressed
Early momentum is established
High levels of employee involvement
Wide and varied expertise has been made available
Thinking outside the established norms
Challenging the status quo
The safety report process is integrated into facility improvement
plans and business processes
Safety report is owned, understood and managed by the MHF
The safety report process provides clear benefits to stakeholders
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What Makes a Good Safety Report cont…
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Clear and consistent links between MAs, Hazards, Risk,
Controls, Emergency Plan, SMS and Performance Monitoring
Regimes
Implemented control measures, SMS, performance
monitoring regimes etc are sustainable given the size and
complexity of the facility
Documentation captures corporate memory
The process is logical and simple – don’t over complicate
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What Makes a Good Safety Report cont…
The safety report demonstrates that:
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The employer fully understands the facility’s processes/systems
The employer understands the facility’s risks
Appropriate control measures have been selected and
implemented to reduce risks AFAP at the facility
Systems are in place to manage each MA to ensure risks
continue to be reduced AFAP
The employer has systems to keep the control measures working
to their stated performance level
The employer has in place processes for reviewing and revising,
as needed
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Some Potential Pitfalls and Mistakes
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Not taking time to understand the Regulations properly
Inadequate planning
Wasting time and resources redoing work unnecessarily
Over committing to controls and systems which cannot be
reasonably sustained
Do things to “look impressive” but which don’t add real value
to the business
Not using valuable information already available (e.g.
independent audits etc)
Overlooking mitigative controls and the need to maintain them
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Some Potential Pitfalls and Mistakes
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Failing to carry forward changes into all relevant parts of the
safety report (e.g. Emergency Plan)
Inconsistencies between different parts of safety report or
between different sources of information
Losing sight of the big picture – unbalanced focus on certain
aspects
Losing sight of the overall objective of the regime
Failing to make safety report compliment overall
business objectives
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In Conclusion - Keys to a Successful Outcome
Adequate Planning and Education
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Understand the requirements in the Regulations and know what
compliance looks like
Don’t over complicate at the start
Test processes and methods of documentation before starting
Identify resource needs early and consider how on-going
maintenance of the safety report will be managed
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In Conclusion - Keys to a Successful Outcome
Involve the right people
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Commitment from senior management
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Appropriate depth & range of experience
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Suitably qualified people
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Operations staff, those who;
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are exposed to the hazard
are the ones most likely to be impacted by, or contribute to an
incident
understand the true variance in operating conditions and
environments
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In Conclusion - Keys to a Successful Outcome
Clarity and Consultation
People understand what they are doing and why.
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It is essential to included ongoing consultation with
employees
Everyone exposed to hazards or involved in management of
the risk needs to understand;
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The
The
The
The
hazards
risk
controls
relationship between them
The safety report should form the basis of training and
operating procedures
Key documents are updated and available
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In Conclusion - Keys to a Successful Outcome
Cultural Match
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It is important that the process and methods used will work
successfully within the organisation and the way it functions
E.g.
• Don’t use highly technical approaches if that is not what you
usually do
• Ensure that controls are appropriate to the capability of the
facility to manage them
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In Conclusion - Keys to a Successful Outcome
Sustainability
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Need to remain focused on the facilities ability to sustain both:
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Ongoing resource requirements need to be considered before
starting
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The processes introduced
The outcomes from the process (new controls)
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In Conclusion - Keys to a Successful Outcome
Belief in the Outcomes
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Focus on improving safety, not simply compliance (regulatory or
internal)
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Effective real consultation & stakeholder ownership
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Preparedness to challenge established “norms”
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Process and procedure for resolving issues and agreeing
assumptions
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Transparency of the process
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In Conclusion - Keys to a Successful Outcome
Continuous Improvement
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Focussed effort for continuous improvement in all aspects of the
safety report and its supporting systems
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Managing A Safety Report
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Managing a Safety Report
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The facility has been given a licence for 5 years
Management congratulates all
Everyone breathes a sigh of relief
Onto the next project
Let the safety report sit in the draw until the next
investigators visit or licence renewal period
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Managing a Safety Report
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After all, the licence confirms:
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Risks are in control
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There are management systems in place to deal with all of the
required issues covered by the Regulations
Tempting – yes
But WRONG!
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Managing a Safety Report
What are the key
things
to be
addressed
on an
ongoing
basis
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Managing a Safety Report
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The safety report should become integrated into the daily
management activities of an MHF
The safety report process will have identified all of the
performance parameters required for managing the risk from
each MA
How to use the information to keep the risk from each MA
as low as practicable?
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Managing a Safety Report
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How to validate that controls identified in the safety report
are:
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Implemented?
Functional?
Meeting the performance standards nominated
Changes to circumstances are handled in accordance with the
safety report process requirements
A system must be in place to verify all of these issues in an
explicit and transparent manner
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Managing a Safety Report
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The control measures need to be managed through an audit
system by the employer and documented in such a manner that
allows the performance of every control to be verified
The overall performance of every control managing an MA
should therefore be audited
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Managing a Safety Report
Hazard Identification
Non-MAs (ie OH&S)
Major Accidents
Define Control Activities
Performance Requirements
Demonstration of
Adequacy
Safety Management System
Risk Analysis
Implementation
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Managing a Safety Report
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The SMS becomes the primary means of managing safety
As with the concept of management systems, if it is stated to
do something, then it should be verified
Performance indicators should be developed to measure the
success or otherwise
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Reviewing and Revising
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The effectiveness of the SMS can be measured through a
specifically developed auditing process
Safety
management
system
Audit and
verification
process
Control activities
performance
standard
Demonstration of
adequacy
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Reviewing and Revising
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The auditing process is considered essential to demonstrate
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Continuing compliance with the safety report
Effectiveness of all the processes and systems
For the facility
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The employer can develop a schedule for auditing the SMS
elements and each of the MA controls identified in the safety
report throughout the year
Undertake the audit and report on outcomes
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Reviewing and Revising
Example
Pressure Safety Valve (PSV)
Performance
indicator
• Passes test within acceptable +/- kPa limits
In Place
• PSV confirmed, correct location, correct set
pressure and relief path open to correct location
Effective
• PSV test records indicate that it is within test
interval
• PSV passed ‘pop’ test before last recalibration i.e. it
was ‘effective’ when removed for overhaul
Corrective
Actions
• If failure was noted, what reporting of control
failure was done
• What corrective action was identified
• Have corrective actions been completed
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Reviewing and Revising
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It is natural that with any system there will be opportunities
for improvements to be made to the safety report process
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Such improvements could relate to:
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Feedback from employees regarding training
Performance of controls (positive or negative)
Management of change
Emergency response exercises
Training
Incidents that occur
Communications with Regulator
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Reviewing and Revising
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Feedback from various sources will enable the safety report to
be continually used as a key management business platform
for the MHF
It will provide demonstration to all stakeholders of how the
process is working
It will aid transparency and continued demonstration of
adequacy that the safety report is fit for purpose
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New Projects
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New Project
How do we achieve the right outcome?
New Project!
Safety Report
Requirements
Project
Lifecycle
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New Project
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MHF issues need to be considered as early as possible during
a project lifecycle
Decisions taken at early stages of a project will have an
impact on the MA profile of the facility – good and bad
The employer needs to focus on short, medium and long term
issues required for the safety report during project
development
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New Project
Concept
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Major hazard issues should be
considered during each step in the
project life cycle
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Important decisions at the concept
phase can impact upon the overall risk
profile of the facility throughout its life
Design
Construction
Commission
Production
Decommission
Disposal
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New Project
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It is cheaper to fix an issue at the design phase than the
operational phase
Retrofitting control measures or fundamental design changes
during the operational phase:
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Is always more expensive
Places a very large burden financially on operational budgets
Delays the facility from reaching the designed throughput targets
If the process is well structured, the reasons for specific
controls adopted and rejected can be documented – corporate
memory
The corporate memory approach is extremely valuable
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New Project – Potential Issues
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For example, XYZ company engages a contractor for developing
a project on a lump sum basis and the project requires MHF
licensing
In many cases the contractor will engage a resource to deal with
MHF requirements
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New Project – Potential Issues
Possible Project Organisation
XYZ Company
EPC Contractor
Sub contractor 1
Sub contractor 2
MHF Resource
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New Project – Potential Issues
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The question for all concerned is “how can the objectivity of a
safety report development be achieved without competing
elements of the project being compromised”?
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The key to a successful outcome is how the contract is set up
between XYZ company and the contractor
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New Project – Potential Issues
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Conflicts of interest can easily occur – there are many examples
of this and the end result would be costly for both XYZ company
and the contractor
MHF issues that arise which are outside the basis on which the
contractor’s lump sum price was developed will need to be
addressed – as opposed to being ignored
This may lead to protracted delays between employer (XYZ
company), contractor and regulator
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New Project – Potential Issues
Start the safety
report early -at the
concept phase
Clearly defined responsibilities,
accountabilities and authorities
Establishment
of milestones
Contractual
arrangements
Establishment of
key criteria and
methods
Resources
(internal versus
external)
Clearly defined
deliverables
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New Project – Potential Issues
The contractual arrangement should address:
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Commitment of client
Contractual and planning arrangements
Resources (internal versus external)
Clearly defined deliverables
Establishment of milestones
Establishment of key criteria and methods
Clearly defined responsibilities, accountabilities and
authorities
Start the safety report early (at the concept phase)
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Questions?
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Supporting Slides
Emergency Plan
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SRO Core Components - Emergency Plan
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An emergency response plan is a mitigative control that may
prevent an incident from escalating to a more severe outcome
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SRO Core Components - Emergency Plan
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Develop your EP/ERP based on your credible Major Accident
Scenarios
Involve all emergency services in the consultative process
Ensure involvement of council and community
Simplify procedures
Develop and implement performance standards that will
value-add to the emergency plan
Conduct exercises based on the plan
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SRO Core Components - Emergency Plan
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When an emergency occurs, the first steps taken will have an
impact on the outcome (consequences)
The outcome can be minimised by having control measures and
systems in place to mitigate the consequences of an emergency
situation
This takes:
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Planning
Evaluation
Adequacy of systems in place
Training
It is an ongoing process over the lifetime of the MHF
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SRO Core Components - Emergency Plan
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Emergency planning is a cyclical process
The plan should be:
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Dynamic and interactive
Ensuring ongoing relevance to the needs of the facility and all
stakeholders by continual:
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◦
Monitoring
Review
Consultation
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SRO Core Components - Emergency Plan
Mitigative
Control Measures
Outcomes
Causes
Preventative
Control Measures
MA
Elimination
measures
Hazards
Prevention
measures
Controls
Reduction
measures
Mitigation
measures
Controls
Land-use
planning
Emergency
response
Consequences
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SRO Core Components - Emergency Plan
Aim of the Plan
• Provide a system and resources to protect people, property
and the environment
• To minimise adverse impact on people, property and the
environment
Objectives of the Plan
• Comprehensive, yet concise, simple and flexible
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Emergency Plan Contents - Example
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Emergency Plan – Site and Hazard Detail
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Links the risk assessment outcomes to the emergency plan
Identifies personnel resourcing issues
Details assumptions
Details the combating resources available on site
Details Emergency Response Plans
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Emergency Plan – Site and Hazard Detail
Assumptions affecting the emergency plan:
• Assumptions on the availability of resources and services and
the execution of responses within an estimated time frame
• Assumptions should be evaluated and contingency plans
developed when assumptions fail or cannot be justified
Typical assumptions include:
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Availability of external resources
Response time of emergency services
Correct operability of equipment
Key personnel will be available on site at time of incident
Personnel will be competent to undertake duties as detailed in
the plan
Fire water containment capability
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Emergency Plan – Site and Hazard Detail
Estimation of Consequences:
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The effects/impacts can be estimated from information
available on material released, operating conditions, facility
layout, nature of the surroundings and environmental
conditions:
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Nature and rate of material released
Radiated heat generated by a fire
Blast generated by an explosion
Toxic concentration in the atmosphere
Escalation potential
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Emergency Plan – Site and Hazard Detail
Estimation of Consequences:
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Once the analysis of the scenario has occurred, the
emergency response scenario information can be presented in
a consistent format
Format is site specific but must meet the needs of those
expected to use the information including site and emergency
services personnel.
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Example Emergency Response Plan
Emergency Response Plan
Ref Number: ERP-1
Unit Name: Plant A: Crude Unit
Equipment No. P-XYZ-001
Incident Title: Pump Pool Fire
Product
CHEMICAL DETAILS
Kerosene
Typical Product
Flash Point
o
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UN Number
C
1223
Typical Inventory
50
m3
POTENTIAL CONSEQUENCES
POOL FIRE
Hole Size
25
Spill Diameter
7
JET FIRE
mm
Hole Diameter
m
Product State
EQUIPMENT PROTECTION PRIORITY
D-456
T-789
NA
mm
Fire
Consequences
NA
EQUIPMENT PROTECTION PRIORITY
NA NA
Butane Storage Drum
Kerosene Storage Tank
FIXED FIRE FIGHTING EQUIPMENT IN VICINITY
Fire Hydrants
3
Deluge Systems (Total)
1
Fire Monitors
3
Deluge Systems (Detail)
D-456 Butane Storage Drum
Foam / Water Monitors
0
Foam
Fire Fighting
Equipment
ADDITIONAL FIRE EQUIPMENT/RESOURCES REQUIRED
Portable Monitors
2
2“ Hose Lengths
6
Foam Cannons
1
Pumpers
0
Foam
POOL FIRE FOAM/WATER REQUIREMENT
FOAM REQUIREMENT
Concentrate
Application Time
Foam Sol’n Flow Rate
Full Foam Supply
WATER REQUIREMENT
1,200
15
580
20,000
L (3%)
Water For Foam
1,200
L/min
min
Water For Cooling
5,600
L/min
L/min
Supplementary
2,400
L/min
L
Total Water Flow Required
9,200
L/min
Foam and Water
Requirements
JET FIRE WATER REQUIREMENT
Water For Cooling
0
L/min
*Supplementary
0
L/min
Water For Jet Impingement
0
L/min
Total Water Flow Required
0
L/min
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Example Emergency Response Plan
Site Plan
Pool Fire
Heat Flux with Wind
(4.7 kW/m2 for personnel accessibility)
Heat Curve irrespective
of wind direction
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Emergency Response – Command Structure & Personnel
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Identifies roles for individuals within the emergency plan
Identifies:
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Who is in charge
What personnel should do
Why they do it
When they do it
Who is communicating with whom
How to contact persons, organisations or additional resources
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Emergency Response – Command Structure & Personnel
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Roles and responsibilities needs to clearly detailed and should
to be consistent with the Command Structure
Role statements need to be available for all positions and
persons need to be familiar with their role and also their
contingency role (if any)
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Emergency Plan – Notifications
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On site personnel
Off site facilities
Emergency services
Applicable authorities
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Emergency Plan – Notifications
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Information required by fire services when responding to a
notification should be “fit for purpose”
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i.e. for Chemical Spill
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Type and scale of the spill (eg within bund or uncontained)
Name of the substance involved
UN Number
Estimated quantity
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Emergency Plan – Resources
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The plan must identify all resources available on site that are
available for use during an emergency
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Where the equipment/material (foams, neutralisers, etc) are
located or how they are to be obtained
Fixed fire fighting systems should be explained, in particular
their design intent (eg. Deluge systems -cooling or mitigation) &
method of activation
Flow rates and water supply duration should also be detailed
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Emergency Plan – Evacuation Procedures
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These procedures must enable any person on site to
understand what is expected of them and what actions they
are required to undertake
The procedures must explain who is responsible for accounting
for personnel and how it is to be achieved (links to Command
Structure)
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Emergency Plan – Isolation Procedures
Control Isolation Points:
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Provides details for the isolation of:
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Utilities (gas, water and electricity)
Road Traffic
Isolation points need to be identifiable, accessable and
maintained
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The Emergency Plan as a Control Measure
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The emergency plan must be included among the control
measures adopted under Regulation 9.45.
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Need to identify appropriate Performance Indicators and
Standards that will ensure the on-going effectiveness for each
individual control, to enable ongoing assurance.
Indicators of failure need to be identified
Actions to be taken in reporting any such failure
Other corrective actions to be taken in the event of any such
failure.
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Emergency Plan – Example Performance Standards
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Emergency response personnel are nominated and manned on
all shifts
Response plans are in place for all emergency scenarios
Emergency response personnel training is current
Emergency response resources are available, capable and
tested
Drill/exercises are conducted according to the schedule
83
Emergency Plan – Example Performance Indicators
•
•
•
•
•
% of fire equipment inspected and tested as per schedule
Evacuation of non essential personnel to assembly point within
7 minutes
Notification to Emergency Services within 2 minutes of
potential major accident being identified
Emergency Response Team to assemble within 3 minutes of
alarm
Emergency response plan exercises are completed within one
month of scheduled date
84
Emergency Plan - Testing
What is the desired outcome of conducting an emergency exercise?
•
To be able to demonstrate so far as is reasonably practicable
that in the event of emergency (eg MA), the mitigation control
measures will work as expected to reduce the likelihood of injury
to all persons and restrict damage to plant, equipment and local
community to a minimum.
85
Emergency Plan - Testing
What else is tested in an emergency exercise?
•
•
•
•
Alarm and communications systems
Call-out of internal/external emergency personnel
Critical emergency equipment availability
Evacuation procedures
 Ensure participation of appropriate emergency services.
86
Emergency Plan Testing – Desktop Exercise
•
•
•
•
Useful training for familiarisation with procedures and site
emergency issues
Can identify resource limitations, issues and knowledge
amongst personnel
May not adequately test communication, site evacuations
processes or equipment accessibility.
Desktop exercise should not be used as the means of
compliance with Regulation 9.53(4)
87
Emergency Plan Testing – Simulated MA Scenario
•
•
•
•
•
Will test effectiveness of evacuation procedures
Coordination between onsite procedures and emergency
services
Extended test of onsite/offsite communication systems
Tests capability of emergency services to response
Identify limitation/restrictions in equipment access
88