Process Safety (updated April 2018)

On the morning of the last day of two weeks of intensive training in the Middle East (last year) on the subject of Process Safety I happen to read the following article from IOSH:

Process safety neglected in board discussions

The two weeks have included a lot of interesting process safety discussions on technical topics such as:

• Risk Assessment
• HAZOP
• Bow Tie Diagrams
• Root Cause Analysis

Importantly, we have also talked at length about the importance of other factors, such as:

• Communication and Consultation
• Commitment from Senior Management
• Active Monitoring
• Process Safety Audits
• Health and Safety Culture

In the UK, in April 2018, the HSE challenged Oil and Gas Companies to “do more” to tackle the problem of hydrocarbon releases (see below). This challenge came as we get close to the thirtieth anniversary of the Piper Alpha disaster.

With serious Process Safety failures leading to major catastrophes, it is vital that Process Safety is discussed at board level and that it the effects of poor process safety are understood by at board level. Safety is a dynamic non-event; that means that we have to work hard to have nothing to show. Safety professionals, managers, supervisors, operatives, and even the board of directors need to be working hard to ensure that nothing happens (no more Texas City explosions, no more Chernobyls, no more Bhopals, no more Piper Alphas).

Process safety neglected in board discussions

• Process Safety is a less common topic on board agendas in high-hazard organisations than general safety performance, according to a survey by consultancy DuPont Sustainable Solutions (DSS).
• DSS surveyed 82 senior managers from the oil and gas, mining, chemical manufacturing and construction sectors.
• Only just over two respondents in five (40%) said they discussed process safety and asset integrity at board meetings. But more than half reviewed general safety, health and environment metrics and regulatory compliance.
• If boards do not focus on operational risk, they can fall prey to the “illusion of understanding”, warned DSS, in which “performance indicators may show positive trends, but risks remain hidden, waiting to strike [at] any time.”
• Eight respondents in ten believed the senior managers in their organisations were aligned in their understanding of major operational risks, but less than half were confident that frontline employees were clear about these risks.
• DSS said the finding was an “indication there is an engagement gap between leaders and frontline personnel”, suggesting CEOs are not communicating adequately. “But this is a two-way street”.
• Not only does the CEO need to be clear about their vision, but frontline staff also need to be able to communicate the operational risks they see to their management and leadership.”
• Though nine senior managers in ten said that risk governance was an important factor in safety management, fewer than three in ten (30%) were confident that their organisations managed it well. Similar gaps between priority and performance were reported for risk identification and assessment and leadership commitment.

Letter from the HSE

In a letter to coincide with the approaching 30th anniversary of Piper Alpha, Health and Safety Executive (HSE) boss Chris Flint today took oil and gas operators to task over continued loss of containment (hydrocarbon releases), saying that the industry needs to “do more” to tackle the problem.

Mr Flint, director of HSE’s energy division, said that although strides are being made, the continued hydrocarbon leaks represent failure “across the board”.

Mr Flint said:

Every HCR [hydrocarbon release] is a safety threat, as it represents a failure in an operator’s management of its risks. I recognise the steps the industry has taken to reduce the overall number of HCRs, however HCRs remain a concern, particularly major HCRs because of their greater potential to lead to fires, explosions and multiple losses of life. There have been several such releases in recent years that have come perilously close to disaster.

Mr Flint went on to ask operators to take a new approach and “look critically ” at their operations and learn from incidents both onshore and offshore.

Proposing that operators carry out a safety review, Mr Flint also suggested a comprehensive audit of oil and gas producers safety management standards as a road to improvement.

He said (emphasis added):

Experience from our investigations is that HCRs typically happen because there have been failings across the board. Poor plant condition, and breaches of procedures are often immediate causes, but beneath that we often find a lack of leadership, a poor safety culture, and evidence that weaknesses have existed for some time, but haven’t been picked up through audit, assurance and review and then dealt with.

If you get the safety culture right, staff will be much more likely to spot hazards, challenge when standards aren’t right, and be engaged in improvement

And if you have an effective system of monitoring and audit in place, leadership will know which systems need fixing, and can target their efforts to prevent the incidents occurring in the first place.

The letter requires operators to respond to HSE by 20 July 2018 with a summary of their improvement activities and plan arising from their self-assessment.

A simple example of a recent process safety failure in the UK – Tank Explosion

Look for information on Process Safety Indicators? Then follow this link to HSE document