This was a keynote conference for Chemicals Northwest that concentrated on the topical aspects of process safety, those of which the regulator has made specific reference to following the re-modelling of the COMAH regulations.
How is the use of process safety performance indicators (PSPIs) demonstrating improvement in safety since the UK process leadership initiative five years ago and the guidance document HSG 254 from 2005? Additional feedback has also been given to the industry’s performance across ageing plant, which appears now to be an area that improvement is required. There was a fresh view on employee involvement and how companies should take a closer look at the important role played by their people in delivering successful process safety practices.
Mr Ian Travers, Head of Chemicals Strategy Unit within the Hazardous Installations Directorate at the Health & Safety Executive, chaired the day. The opportunity was taken to remind delegates of the PSPI journey from the launch of the HSG 254 guidance through the added impetus on leadership and how such leading indicators became an established strategic theme within the COMAH intervention scope. Evidence has shown that not all sites are the same and a universal set of PSPIs can’t be achieved. The role of people across our businesses is essential so that all the major features of process safety actually work. Ian suggested that a review of the above guidance is likely to be produced in the near future.
ABB Ltd’s Lee Allen explained the need to revisit criteria for selecting PSPIs and not focus just on the areas that sites may be good at i.e. areas where we are also weak. It is also expected that indicators may be changed or removed. What happens when you remove a ‘good’ performing indicator from site communications? If it stays at a ‘good’ level, then this could be seen as a measure of a good safety culture. Leadership involvement in developing PSPIs and on-going monitoring, is key if the approach is to be successful.
Marie Connor of Innospec Ellesmere Port explained how PSIPIs have become an established part of the site’s performance, monitoring and planning. The indicators are reviewed in a six monthly best practice meetings for sharing and learning across the group. It is important that the board sees these KPIs and support the progress based on review of overall site scores and getting the right information. Innospec quickly found that different sites cannot be compared with the same indicators and there is high importance placed on site managers in their understanding of the PSPIs and the provision of resource to maintain them.
Phil Scott, CIA Safety & Risk Manager bridged the PSPI theme with that of ageing plant, in terms of best practice sharing amongst process safety specialists. The CIA process safety issue team is growing and has over the past two years generated much discussion and best practice examples for the benefit of its members. There is a need to keep reviewing PSPIs and it is important that our boards see updated indicators. CIA is also working on a global process safety indicator and is involved in cross-sector experience sharing. The issue team also looks at asset integrity and observes that care is needed when choosing third party inspection partners. The following aspects of managing ageing plant were highlighted: good plant surveillance and reporting by operational staff, don’t forget pipework, bunding, tanks supports, etc and inspection and maintenance should be clearly linked through corporate policies.
Ageing plant has been seen to be the chemical industry’s low scoring feature following the HSE’s COMAH interventions. Paul Stanworth, specialist inspector on mechanical engineering, described the inspection approach to this important subject. The key topics of HSE’s delivery guidance cover: leadership awareness and support, asset registration, safety critical mechanical equipment, primary containment boundary (PCB) management systems and inspection processes and overall resources available. The issue of third party maintenance providers is seen by the regulator too as a key issue and that sites should become intelligent customers, insisting on the right to overview the work being carried out. A new Chemical & Downstream Oil Industry Forum (CDOIF) working group is to be set up to look at this aspect.
Dr Andrew Fowler of HFL Risk Services reminded the audience of ensuring the best standards within the “4 Ps” of process safety: initial process design, maintenance personnel, operational procedures and process hazards and risks. There is also the fear that as the workforce is changing, new engineers and plant managers may not be up to speed with process situations and previous learnings. HFL have launched an assessment tool to help companies go about process safety analysis and the findings from a recent benchmarking exercise showed that higher scoring items correlated with the regulators strategic topics, but also that more could be done in terms of policy provisions from our boards.
David Raymond of GSK Ulverston spoke about the GSK Ulverston site commenced on an innovative risk based inspection programme in 2007. Following a need to see closely how the plant areas are looked after, site pipework and tank inspections plans were based on a “5 x 5” risk matrix. Site tours and desk top assessments were carried out up to a point where 6600 inspection points were identified. This resulted in a highly integrated and innovative approach to maintenance using in-house testing equipment and mechanical expertise. The company is now turning its attention to plastic tanks and associated equipment.
Neil Smith of the National Skills Academy for the Process Industries (NSAPI) explained how new training standards and course material for process safety management had been developed over recent years. The units now in place include process safety leadership (chiefly aimed at senior managers and directors) and the broader process safety management foundation, aimed at wider site management. A new standard that focuses on raising process safety awareness of staff at operations level has just been completed and the academy can now offer a full framework of training standards for raising awareness of PSM at all levels within industry.
Rob Vondy Head of Workforce and Leadership at HSE reminded all to reinforce the promotion of workers involvement and consultation in health & safety matters. The benefits of good worker involvement are for everyone in the organisation and businesses should realise that it is a long term investment in time, bringing about changes to attitudes and behaviours.
At Syngenta in Huddersfield lots of steps have been taken in developing a constructive and open partnership in EHS cooperation. After some difficult years a new SHE steering group was set-up with the workforce and management agreeing that a partnership approach would be essential in dealing with the newer higher pressures of the business environment. Company safety representatives, Sean McGuin and Kevin Clarke made this very interesting presentation.
Dr Jackie Coates, Health Safety & Environment manager at CIA, outlined an additional leading indicator tool that follows on the success of the 2012 CIA health metric tool which really has drawn the attention of many health industrialists. The simple self check has already been cumulating group data in relation to the key stages of implementation of several sustainable safety systems. Views on this idea were welcomed from the delegates with a view to refining the data already secured from over 40 % of CIA membership so far.
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