-
Process Safety Performance Indicators:The UK Experience in Major
Hazard Industries
Seveso Conference 2010Stockholm19 May 2010
Peter Dawson
Principal Process Safety Specialist Inspector
Hazardous Installations Directorate
UK Health and Safety
[email protected]
-
Presentation outline
Terminology and definitions Where we started and why, in the UK.
Wider perspective - world incident learnings. How PSPIs can help
prevent major incidents. How PSPIs can be developed and used. UK
approach to PSPI implementation. PSPI example
-
Terminology & definitions
Process Safety (PS) prevention, control and mitigation of
incidents and events with potential to cause death, major injuries
and/or significant damage. Clear distinction from personal
safety.
Key Performance Indicator (KPI) includes wide range of metrics
used to measure business, operational and safety performance.
Process Safety Performance Indicator (PSPI) -HSE uses PSPI to
mean a small number of selected site specific indicators for
monitoring the performance of key risk controls. Specific type of
safety KPI.
-
Where we started and why in the UK
BP Refinery, Grangemouth, Scotland 2000: A series of loss of
containment incidents prosecution and a record
fine.http://www.hse.gov.uk/comah/bpgrange/
A good safety record when viewed by lost time incident rate but
BP did not know how well it was managing major hazard risks
Management system discouraged reporting of bad news senior
managers assumption no news is good news
-
Where we started and why in the UK
Subsequent enquiries showed that senior managers of similar
sites had:
An overwhelming belief in system design and integrity and in the
regulatory controls CoMAH/Seveso
No means of discovering deterioration in the risk controls in
place, short of catastrophic failure
Little or no use of KPIs for major hazard risk and where process
safety KPIs were used they were exclusively lagging.
An over reliance on auditing that focused on compliance not
safety and environmental outcomes.
-
World incident learnings
Investigation of chemical and process industry major incidents
worldwide continue to reveal similar failings.
Despite widespread communication of the lessons incidents keep
occurring in the same ways.
Andrew Hopkins book Failure to learn, about the BP Texas City
disaster provides a detailed analysis of why the company had failed
to learn the lessons from earlier incidents, including BP
Grangemouth and Exxon Longford.
Concludes that a major factor was catastrophic risk
blindness
-
World incident learnings
Catastrophic risk blindness can arise from;
focusing too much on personal safety using lost-time accident
rates to measure safety
poor understanding of causes of major incidents different from
personal safety
failure to identify and learn from process upsets &
deviations no data collected.
inadequate Process Safety leadership by senior management
-
How PSPIs can help
A well designed system of PSPIs can;
provide specific information on how well process safety risks
are being controlled amplifyingexisting weak signals before a major
incident.
challenge no news is good news attitude to process safety
allow improvements in process safety controls to be
demonstrated
provide both leading and lagging data for maximum benefit
-
How PSPIs can help
Lagging indicators designed to identify failures of
safeguards& controls that can cause upsets or near misses
Operating Procedures
High pressure alarm/trip
Pressure relief
Plant integrity inspection
Safeguarddefects
Possible lagging indicators
Possible leading indicators
Initiating event
Major Accident
Upset
Leading indicators designed to identify weaknesses in key
elements of safeguards & controls that could lead to
failure
-
How PSPIs can be developed
HSE Guidance HSG 254 Developed jointly with CIA
and individual companies
Originally started with post BP Grangemouth pilot in Scotland
2003/04
Step by step guide developed and trialled
HSG 254 published 2006 Clear methodology for
developing PSPIs linked to MA events for a site.
Available on HSE
website.http://www.hse.gov.uk/pubns/books/hsg254.
htm
-
How PSPIs can be developed
OECD Guidance on Developing Safety Performance Indicators
related to Chemical Accident Prevention, Preparedness and
Response.
Produced by working group on chemical accidents
Recently revised 2nd edition, based on pilot programme with
expert review
Uses HSG 254 methodology Sets out 7-step process with 3
examples, more practical detail and explanation than HSG 254
Freely available on-line at
http://www.oecd.org/dataoecd/60/39/21568440.pdf
-
How PSPIs can be developed
New guidance from American Petroleum Institute
API RP 754 PSPIs for refining and petrochemical industries
Defines four tiers of indicators to provide both leading and
lagging data
Tiers 1 & 2 are loss of containment events against defined
threshold levels
Tiers 3 & 4 provide information on the performance of safety
and management systems.
http://www.api.org/standards/psstandards/
-
How PSPIs can be developed
Key starting questions for every organisation:
How will the information be used? By whom and when?
Who is involved in setting the indicators? What will change in
the organisation as a result? Do the indicators match the risk
profile of the business?
Have they been prioritised based on vulnerability to
deterioration and the relative risk that the control measure
protects against?
Do you measure at a sufficient frequency to detect rapid
change?
-
How PSPIs can be developed
Lagging & Leading
Causes confusion - the most important issue is to obtain the
right information
Set lagging indicators to show critical deviations from the
desired outcomes failures in risk controls and safeguards leading
to upset or near miss.
All adverse findings must be followed up indicator doesnt tell
you what the problem is!
Set leading indicators for the critical must
doactivities/elements of controls/safeguards show defects or
weaknesses in advance of a failure.
-
How PSPIs can be developed
Site specific v corporate indicators
Site based indicators more closely match the risks specific to
the processes and activities on site.
It is easier to involve the workforce in setting site indicators
compared to corporate more relevant.
Great amount of benefit comes from the analysis required to set
indicators a lot is learnt about the importance of the various
control measures.
Corporate indicators are more suited to benchmark performance
across a number of businesses
Corporate indicators are more relevant where the same risks and
systems for controlling them exist across businesses
-
How PSPIs can be developed
PS Leadership is vitally important to ensure:
Process safety is given the right degree of attention and
focus;
Process safety considerations feature in key business decisions,
and
Understanding of major hazard risk and the importance of
critical control measures is communicated and championed.
Recent UK PSLG Guidance on PS Leadership
Principleshttp://www.hse.gov.uk/comah/buncefield/pslgprinciples.pdf
-
UK approach to PSPI implementation
Senior management and employees should be involved in setting
indicators
Indicators should be set following an analysis of the
vulnerability of control measures
The indicators adopted should match the risk profile of the
enterprise
A balance of leading and lagging indicators should be used A
small number of focused indicators should be used to
avoid overload.
CEOs and senior managers should make business decisions taking
account of information from indicators
Information from indicators should be used to improve
performance,
Indicators should be reviewed regularly and changed with
experience
-
UK approach to PSPI implementation
HSE expectation for all CoMAH/Seveso sites to have suitable
PSPIs in place.
Implementation requires staged approach to identify, trial and
fully implement indicators.
Top tier sites should have PSPIs by 2011 Lower tier sites 1-2
years later. Series of workshops held for operators and trade
associations.
Progress monitored at site inspections.
-
PSPI example
PSPIs for a fuel storage depot with pipeline and jetty
filling;
Buncefield, UK, incident 2005 large vapour cloud explosion
arising from overfilling of petrol storage tank.
Led to establishment of Process Safety Leadership Group
(PSLG)
Final report Safety and environmental standards for fuel storage
sites includes worked example of PSPIs in Annex 1
http://www.hse.gov.uk/comah/buncefield/fuel-storage-sites.pdf
-
PSPI example identify major accident causes and risk
controls
Control of contractors
Plant change
PTW
Design
Inspection and maintenance
Competence
Operational procedures
Control andinstrumentation
SubsidencePhysical damageWearCorrosionOver-pressureAccidental
leakageOverfilling
Challenges to integrityRisk control systems
-
PSPI example lagging indicators
For each risk control define purpose, or what success looks
like.
Identify a measurable successful outcome to provide a lagging
indicator
For example; To prevent overpressure of transfer pipeline
number
of times pressure >10bar during transfer
To prevent overfilling of tank number of times tank filled above
defined safe fill level
-
PSPI example leading indicators
Identify critical elements or activities of risk controls, need
to consider which
Must work correctly every time
Are more likely to deteriorate over time
Are undertaken most frequently
For example; To prevent overpressure number of times ship
unloaded without ship to shore checks correctly completed
To prevent overfilling - % completion of inspections and test of
tank gauging system
-
Thank you for listening
Any questions?