Neil Smith, Head of Workforce Development at Cogent Skills Training Ltd
This isn’t a new topic. The Process Safety Leadership Group set out the Principles of Process Safety Leadership addressing this very subject several years ago, and over the last few years the Health and Safety Executive has been encouraging industry to demonstrate how it is improving its performance in competence management and human factors, which really underpin the effective management of major accident hazards.
Chemical and petrochemical manufacturers have been looking at how they improve their business and safety performance and deal with major accident hazards on their sites through investing in process safety leadership for years. However, the Health & Safety Executive has now developed an inspection tool to assess whether boards or senior leaders of duty holders can demonstrate effective leadership arrangements when benchmarked against legislative requirements, including COMAH, and established industry standards for major hazard control.
Why the focus in 2019?
I think it’s important to note that this isn’t just a 2019 initiative. Since we introduced the Process Safety Leadership training standard in 2011 the Process Safety Management Competence Programme has been targeting both COMAH and non-COMAH businesses to encourage them to develop a top-down approach; raising awareness of the principles of process safety leadership, and how everyone can contribute at all levels within a business.
Over that time we’ve seen an increased level of engagement from other major hazard industries, but there are some sectors, particularly those where the major hazard is the potential risk to the environment, that are still some way behind the curve, and recent events have highlighted how the Competent Authority will come down hard on those businesses that are not achieving the necessary performance in preventing pollution incidents.
It’s timely that we are seeing this renewed focus, not only because it seeks to address concerns over the potential for major accident hazards to compromise businesses and the performance of the industry in the UK, but also because there are currently many competing priorities for industry leaders. There are any number of short and long-term pressures on businesses at any one time; but maintaining a healthy and robust approach to managing major accident hazards must stay at the top of the agenda.
Where are the main areas of concern?
Colleagues in the HSE have highlighted several issues that raise concerns; including
- Transfer of ownership and acquisitions
- Ownership of major hazard assets by non-chemical or non-technical companies
- The loss of specialist knowledge
The transfer of business between different asset owners that can lead to issues with or changes to their management systems or processes which could compromise the understanding or control of their major accident hazards. Many businesses are now owned by global corporations or institutional investors that may not have a background in the chemicals industry, and simply don’t understand those major accident hazards. There’s also been a loss of specialist knowledge over recent years, stemming from pressures to reduce staff numbers, restructuring, sub-contracting, and turnover resulting from redundancies or people retiring from the industry.
What should leaders be doing?
Against all that background, all senior executives really need to understand exactly how their organisation is managing their major accident hazards and what their role as leaders within the industry needs to be. They need to:
- Understand their major accident hazards and the risks their businesses face
- Understand that their system design does not completely mitigate all these risks
- Understand the impact their decisions make on the control of their major accident hazards
- Know how to and be confident in challenging what they are being told
- Beware of the performance indicator watermelons (all green on the outside but masking the red on the inside)
- Make sure that they are as robust in managing the risks to the environment as they are to people
- Leaders can gain the knowledge by undertaking recognised training such as the Cogent Process Safety Management training.