20th October 2010
Written by: Dr Julian Hought
Published in: Process Industry Informer, Tank Storage, Storage Terminals
The Problem with Kneejerk Compliance
Dr Julian Hought of risk management specialists, HFL Risk Services, questions whether concentrating on the latest COMAH hot topic is the best use of budgets and resources.
The COMAH Competent Authority regularly reviews compliance with regulations and best practice at hazardous installations throughout the UK. The findings from these intervention visits and worldwide incidents have led to the development of special emphasis programmes designed to promote better understanding and performance against good practice in a number of key areas relating to process safety.
Commonly referred to as ‘hot topics’ these have included such subjects as Human Factors, Containment Policy, Process Safety Performance Indicators (PSPIs), Emergency Response and Process Safety Management. Whilst each topic is valid and should be given due consideration in its own right, companies should remain wary of rushing headlong into detail to be compliant with the latest recommendation, if it’s at the expense of other areas.
So how do you decide what to focus on and where to target resources?
As in all walks of life ‘putting all your eggs into one basket’ is not necessarily the most sensible course of action. Implementing any type of change consumes time and resources and so it’s important to understand what benefits are to be gained. To avoid kneejerk reactions to recommendations on specific issues, companies should first of all be asking themselves “what will implementing this latest change cost?” and “is it the most cost-effective way of reducing the overall risk to people and the environment?”
Quite often the answers to these questions are (1)“most, if not all, of my available budget” and (2) “probably not”. COMAH itself is risk-based goal setting legislation designed to ensure that risks to people and the environment are as low as is reasonably practicable. So special emphasis programmes or not, operators need to concentrate first and foremost on recognising where their own particular weaknesses lie.
Let’s look at some of the most recent COMAH hot topics. Firstly Emergency Response plans. No one would doubt they are an essential part of any safety programme; they form the rule set by which people need to work should the worst happen and there is a loss of process materials or energy. They are designed to mitigate the consequences of an event by saving lives and protecting the environment and assets when all else has failed. They are in effect the last resort. Concentrating all of one’s budget and efforts on developing an appropriate Emergency Response Plan may therefore be less than ideal, if it is at the expense of much needed improvements to other safeguards.
Similarly, where problems with safety critical instruments have been identified through inspection, it’s not uncommon for companies to go into overdrive, setting safety integrity levels and re-engineering many of the systems in place. By all means do this but not at the expense of all other matters of concern. Fix the problem, but do so within the context of overall site safety.
The subject of Human Factors is another topic high on the Competent Authorities agenda. It is a commonly accepted statistic that human failure plays a role in around 80 per cent of all accidents. In fact failures in operation have been found to have contributed to catastrophic disasters such as those at Bhopal, Three Mile Island, Piper Alpha and Texas City. Ignoring design, construction and maintenance, the HSE has identified a number of major pitfalls on major hazard sites relating to human failure in operation. They include assumptions that people will always: follow procedures; be present; and take appropriate action immediately. However, experience shows that these assumptions can be flawed when those involved do not fully understand the consequences of there actions or inaction. They need to know just why a particular set of actions is necessary – it is not sufficient to know what to do but also why those particular procedures or steps are in place to prevent a major accident.
Tackling Human Factors is, again, an important aspect of overall site safety. It’s a theme that runs through everything we do, from conceptual design, through to beneficial operation and eventual decommissioning, and should not be treated as a subject in isolation. If the design intent is to be maintained, human factors should be integrated into the Process Safety Management strategy giving greatest attention to those aspects necessary to maintain the integrity of the critical risk control systems. Site operators should concentrate on the criticality of processes and plant with respect to human performance, identify those activities deemed critical and put measures in place to minimise the likelihood of failure. But once again the resources deployed should be appropriate, proportionate and specific to the particular business needs.
Given the current economic climate and increasing competition from abroad, many companies are continuing to use plant and equipment beyond its planned life expectancy. This has given rise to yet another subject on which the Competent Authority is placing increased emphasis – the issue of Ageing Plant. The term applies not to the physical age of plant and equipment, but to the accumulation of damage and the increasing likelihood of failure over time.
Corrosion Fatigue is a recent safety alert issued by the HSE - caused by a combination of a corrosive mechanism and fatigue generated by mechanical or thermal stresses. Most excursions are likely to be related to tubes or pipework, so vigilance in respect of a component or piece of equipment’s mechanical integrity is essential. After all, a system containing toxic material which fails could kill, injure or cause significant damage to the environment. Again, companies need to balance budgets with driving down risk. An effective Mechanical Integrity Programme will ensure that appropriate standards, processes and procedures are put in place to maintain the original design intent and ensure continued safe operation without targeting valuable resources on assets for which failure can be tolerated.
Achieving the balance means understanding just how major accidents could occur and putting in place an appropriate mix of physical and procedural measures to control those risks. It’s the maintaining of this balance that is often lost in kneejerk reactions aimed at trying to comply with the latest initiatives.
So, how do we please the Competent Authority, but at the same time make the most appropriate choices according to our budget?
The starting point is compliance with the law and accepted good practice. Consider the ‘hot topic’ issues within the overall assessment process, dovetailing them in where necessary to develop a cohesive strategy for overall management of risk. This will lead to a more holistic approach and avoid the creation of a seemingly disparate collection of project initiatives.
The problem for many companies is that the ‘hot topic’ issues are often pushed at the middle management level where different functional heads will have responsibility for resolution of each of the issues raised. This means that situations can arise where different groups campaign on single issues, effectively competing for limited resources without the big picture in mind. What is needed is someone in a position of authority to champion the cause and act as arbitrator. This must be someone with a clear understanding of the issues in hand and the benefits to be gained for any given spend. This view is supported by the Process Safety Leadership Group*, which has emphasised the need for board level competence and involvement, and sharing of best practice across industry sectors, in its recently published Process Safety Management Principles.
In simple terms, organisations need leadership and clarity from the board down in relation to: compliance; understanding of risks; management of risks; and measurement of performance and improvement.
A number of specialist risk assessment consultancies offer tools and techniques to help pinpoint areas for improvement and my own is no different. It has been very active in this field and has developed a unique programme called INSIGHT Lifecycle®, designed specifically to help organisations make the necessary decisions. It uses a matrix of structured question sets to help tease out weaknesses in the management systems in place and generate specific and detailed action plans for improvement. It allows operators to carry out a systematic and thorough examination of the risk control systems in place for managing the Process, Plant, Procedures and People to determine what more can or need be done.
But whatever your approach, it is important to keep the big picture in mind. Concentrate on the basket and the route home, not just the eggs inside, and all should go well.
* The PSLG is a collaboration of regulators and industry bodies; it includes the HSE, EA, SEPA,
