At the 2012 edition of the UK Institute of Mechanical Engineers’ Process Safety event in London this month, Eddie Moreland spoke with authority on two counts. As CEO of the UK’s Health and Safety Lab (HSL), Moreland is tasked with ‘crime scene investigation’ of process and industrial accidents. The HSL’s own plant contains hazardous materials used in its investigations and so is a (regulated) duty holder in its own right. The bad news for process safety in the UK is that things have gone wrong and they still are going wrong—HSL averages one site visit per day. The good news is that ‘goal-based regulation offers guidance, encourages thinking and an ongoing search for learning and improvement.’ Moreland stressed that process safety should not be confused with conventional HSE, focusing on stuff like folks holding hand rails.
The HSL’s remodeled Control of major accident hazards (Comah) rules presuppose competency from both the regulator and regulated. These derived from HSL’s investigation of the UK Buncefield oil tank farm fire. This was a puzzler initially as computations failed to explain the size of the explosion. HSL conducted an experiment by spilling hexane to re-calibrate the code and found the big bang was caused by a very still day, allowing a huge vapor cloud to build-up.
HSL’s ‘Safety climate tool’ powered by Snap has been made available to industry and exposes an eight point plan for assuring safety culture across the organization. The tool helps measure the ‘safety gap’ between management, where things may appear OK, and the shop floor, where they may not! All the same, the UK has made ‘tremendous progress in stopping people getting killed at work.’ With some 5,000 per year in 1900 to a current 170 per year today (all industries).
Colin Dennis of the UK Rail Safety and Standards Board described some of the perverse effects of safety performance indicators (SPI). In 2004 Network Rail’s attempt to drive down reportable incidents ‘worked’ in that reporting was greatly reduced—but this did not result in a comparable reduction in accidents. What was happening was that the new regime had caused significant under-reporting of injuries with some 34% of accidents not reported. Such ‘unintended consequences’ resulted from ‘real and perceived pressure’ from management. UK operator Network Rail has introduced a safety leadership program and is researching the optimal use of leading and lagging indicators. A guidance/good practice document ‘should be applicable to other industries.’ SPIs, properly handled, ‘appear to genuinely help manage risk’ and can complement existing safety management systems and processes. The reporting conundrum can be solved with anonymous reporting of ‘close calls’ without fear of being disciplined.
Ann Metherall (Burges Salmon) observed that only one in six accidents are due to a breach of regulations. The legal basis for process safety revolves around ‘reasonable practicability.’ Operators must take ‘proportionate’ safety measures—but what is ‘proportionate?’ Legal precedent suggests that industry good practice sets the standard. Buncefield was a wake-up call re manning levels, employee competency and leadership. Lessons were also learned by the legal profession in terms of where, in a joint venture, compliance responsibility actually lies. Corporate manslaughter legislation can expose the parent company to higher fine than a smaller sub.
Amec’s Howard Thompson returned to the Texas City incident observing that plant performance and occupational safety were target areas but that at the time, process and design safety metrics were relatively new. Even today, refinery damages paid are trending up and there is concomitant increasing public risk aversion. Thompson argues plants would benefit from inherently safer design (ISD) to ‘eliminate or reduce hazards completely.’ The Bombay High field fire involved a complex chain of events that began with a self inflicted injury to a cook. The subsequent medevac went badly wrong when a supply ship ran into the platform causing a fire and 22 deaths. Thompson thinks that better design would have avoided this—for instance putting the risers deeper inside the structure. Amec now has an ISD workshop process that augments ‘imperfect’ traditional hazard and risk management. More from Amec and Imeche.
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