8th April 2011

Written by: Julian Hought
Published in: The Chemical Engineer

And the Results Are....

Dr Julian Hought, Managing Director of HFL Risk Services, reveals the results of the chemical industry’s first ever PSM benchmarking programme.

In October 2010, risk management specialists, HFL Risk Services, together with the Chemical Industries Association (CIA) and the National Skills Academy for the Process Industries (NSAPI) embarked on what is considered to be an industry first: a Process Safety Management benchmarking programme for the chemical industry.

The exercise had the support of the HSE and brought together representatives from 12 complex manufacturing sites, from multinational Plcs to specialist SMEs. All companies were regulated under COMAH and all bar one were designated top-tier sites. This gave a broad range in terms of organisation and complexity – in our opinion a fair representation of the chemical industry as a whole.

The programme commenced with a series of seminars, held at the Catalyst Museum in Wigan, where speakers included Phil Scott of the CIA, Ian Travers of the HSE and representatives from NSAPI and HFL Risk Services. This was then followed by auditing exercises undertaken at each of the sites by HFL Risk Services between November 2010 and February of this year. The PSM benchmarking centred on Asset Integrity Management, this being a critical aspect – that of keeping chemicals contained at their primary source.

Information form 206 data points at each site was collated and analysed, giving almost 2500 data points in total on which to base the results of the audit. At each site a cross-functional team of managers, supervisors and operatives were involved and the information generated was supported by observations and documentations as appropriate.

The auditing process was based around current US guidance (CCPS) and prepared independently of, but mapped to, COMAH guidelines. Scorings were allocated to the HSG POPMAR model i.e. Policy, Organisation, Planning, Monitoring, Audit and Review and took into consideration the four P’s of process safety – Process, Plant, Procedures and People.

So.... to the results. Encouragingly what we found was some truly world class performance in terms of PSM in many instances. It was clear from the research that across the board it was the technicians who scored most highly – well above the 60% mark. This indicates that the actual process of operation i.e. the Organisation, Planning and Monitoring aspect of POPMAR is fairly strong. In essence operators are doing what needs to be done very well.

By comparison, the Policy, Review and Monitoring aspect relating to Leadership and Administration skills were not so strong. So whilst technicians know their role regarding safe operation, there is no driving force or leadership behind these actions.

Interestingly, but perhaps not surprisingly, the scores across all departments and all companies were strong for those areas where legislation exists, such as compliance with the Pressure System Safety Regulations (PSSR), Safety Integrity Systems (SIS) , passive devices and non-codal high risk pressure systems, but tailed off as we moved away from classic containment systems.

For example, it transpired that greater focus is required in the inspection and testing of secondary and tertiary systems, medium and lower risk process systems, and the control of maintenance and spares in relation to critical items. Another area was the inspection of structures. Attendees were advised that objects such as railings, handrails, hangers, drains and flooring should be evaluated as part of a structural survey. Redundant structures should also form part of the same survey, since the likelihood is that they will still have power and may be put to a different use in the future. Their proximity to other functional buildings also needs to be taken into consideration and any potential for accidents assessed.

As far as actual procedures were concerned, companies scored highly on Management of Change, Failure reporting, Design and Mechanical and C&I Maintenance – again much of this due to excellent technical staff within the companies audited. There was room for improvement in Asset Integrity Policy, Identification, Monitoring KPIs and inspection frequency, frequency of audits and planning and implementation for parts and supplies/degradation and corrective action.

The overarching themes that emerged as a result of the benchmarking process is that there is generally a lack of any high level policy covering Asset Integrity. The issues around PSSR and SIS are well understood and, in the main, well managed. However chemical companies allow themselves to be regulated into rather than setting out their own programmes of testing and inspection.

The high scores were consistent with HSE hot topics and those issues being championed by the Process Safety Leadership Group (PSLG). But the impetus to improve performance in non-codal areas must come through leadership in individual companies. Self-regulation, led from the top, gives sites a clear understanding of what needs to be done, where and when, in accordance with budgets.

Feedback from the companies involved has shown that all involved felt this first PSM benchmarking programme to be highly beneficial. It has given different chemical companies the opportunity to learn from experts, share experiences and work together for a common cause – improved process safety within their industry. Their enthusiasm has inspired future benchmarking activity to continue the programme of work and build on its findings.