07Process Safety Performance Indicators Health and Safety Executive

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


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


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/


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?


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.


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


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?

Documents

07Process Safety Performance Indicators Health and Safety Executive