Process Safety Performance IndicatorsNeil Macnaughton

Process Safety SpecialistIneos Manufacturing Scotland Ltd

Personal Background• Graduated in Chemical Engineering in 1983• Worked with ICI, BP and now Ineos• Full time process safety role since 1998

– Ongoing role in promoting process safety on refining andpetrochemical complex at Grangemouth

– Member of Scottish CIA pilot on process safety performanceindicators (2003-2004)

– Contributor to development of HSG 254– Member of OECD Expert Working Group on process safety

performance indicators– Member of UKPIA working groups on Process Safety and

Process Safety Performance Indicators

Content of presentation

• What do I mean by a PSPI?

• Why the interest in PSPIs?

• How do they fit in with other monitoringactivities?

• Possible approaches to PSPIs

• What might PSPIs look like?

• Why are they important?

What do I mean by PSPIs?

• A subset of the metrics gathered by anorganisation– Monitored periodically to give a indication of how the

organisation is managing its major hazards

– Need to include a combination of input and outputmeasures (leading and lagging)

Longford gas plant explosion (1998)Andrew Hopkins “Lessons from Longford”

• “Esso regarded itself as a safetyconscious company. Following standardindustry practice, it used lost-time injuryfrequency rate as its principal measure ofsafety performance, and in terms of thismeasure Esso's level of safety wasenviable. “

• “Measuring safety in terms of lost-timeinjuries or total recordable injuries isinherently problematic in hazardousindustries.”

• “An airline would not make the mistake ofmeasuring air safety by looking at thenumber of routine injuries occurring to itsstaff. Baggage handling is a majorsource of injury for airline staff, but thenumber of injuries experienced bybaggage handlers tells us nothing aboutflight safety.”

BP Grangemouth (2000)BP Grangemouth Competent Authority

Report (2003)

• “Major accident hazards should beactively managed to allow control andreduction of risks. Control of majoraccident hazards requires a specificfocus on process safety managementover and above conventional safetymanagement.”

• “Companies should develop keyperformance indicators (KPI’s) for majorhazards and ensure process safetyperformance is monitored and reportedagainst these parameters.”

BP Texas City (2005)• Baker Report (2007)• “BP primarily used injury rates to measure

process safety performance at its U.S.refineries before the Texas City accident.

• “Although BP was not alone in thispractice, BP’s reliance on injury ratessignificantly hindered its perception ofprocess risk.

• “BP tracked some metrics relevant toprocess safety at its U.S. refineries.Apparently, however, BP did notunderstand or accept what this dataindicated about the risk of a majoraccident or the overall performance of itsprocess safety management systems.

• “As a result, BP’s corporate safetymanagement system for its U.S. refineriesdoes not effectively measure and monitorprocess safety performance.”

Other incidents

What price knowing…….?

The goal of PSPI’s

• To support the prevention of a loss of primarycontainment by focusing attention on criticalareas of the management system.

PSPIs – the new “in thing”?• Muted response until Baker report

– Not much happened in immediate aftermath of Longford (onlypermeated BP in late 2000)

– Limited response to Grangemouth incidents – probably confinedto UK and UK trade associations

• CIA and HSE produce HSG 254

• UKPIA produce report for refining industry

– OECD produced guidance (2003)• Guidance on Developing Safety Performance Indicators related to

Chemical Accident Prevention, Preparedness and Response

– Main US focus comes on the back of Texas City• API, AIChE/CCPS, NAS, etc., etc.

Limitations of PSPIs• Collecting PSPIs is a waste of time unless the

right people:– Understand the question the PSPI is asking;– Understand the limitations of the data;– Have the will and the authority to act on the data;– Have a critical attitude to the relevance of the PSPIs;– Know that PSPIs cannot answer everything.

• The effectiveness of PSPIs cannot be separatedfrom organisational / cultural factors and fromother feedback mechanisms

Benefits of PSPIs• A good set of measures can help organisations

– “How close are we to catastrophe?”– Promote awareness of the possibility of disaster

• But….– It has been hard to know how to develop measures

for process safety– Many issues can’t be reduced to a number, so

• What are the right questions to ask?• What measures help to provide the answer?• What is the equivalent to the lost time injury?

Where do PSPIs fit in?• PSPIs are one feedback mechanism

– They provide a means of gathering information;

– They provide a means for challenging performance;

– They can drive behaviour (good and bad);

• But….– Organisations can only respond to a few measures;

– Which are the right ones to pick?

• PSPIs must be complemented by audits

• PSPIs and audits aren’t a substitute for goodengineering

Selecting output PSPIs

• Simpler than input PSPIs

• Should primarily focus on losses of primarycontainment– Can align to input measures and/or common causes

– Could include some “near miss” type performance

Selecting input PSPIs

• Two principle approaches– Management system process based

• Broadly the approach adopted by OECD

– Hazard and risk based• Broadly the approach adopted by HSG254 and UKPIA report

– What is the rationale for choosing?• Both approaches ask entirely valid questions, but…

– What level of the organisation are the PSPIs aimed at?

– How often are they to be measured?

“Management system” PSPIs• Based on monitoring of key management system

elements– What % overdue inspections?

– How many of the planned Hazops carried out?

– What % of Hazop actions have been closed?

– How many investigations have root causes developed?

– How many investigation actions closed out?

– What % of changes have formal MoC?

– How many OIs are overdue review?

– What % of emergency exercises carried out?

– Compliance with improvement objectives

Hazard and Risk based• Based on key factors in preventing a dangerous loss of

containment– How often did a unit exceed operating limits?

• High temperature, low temperature, level, pressure, pH, velocity, etc

– How many times was equipment not properly depressuredbefore maintenance?

– How many demands were placed on trip and relief systems?

– How many equipment items are overdue inspection or testing?

– What % of required hose tests were carried out?

– What % of permits had field visits carried out?

What’s the difference?

• Management system PSPIs tend to be high level– Relationship to preventing loss of containment is

generally indirect

– May be more to do with contributing factors?

• Hazard / risk based PSPIs tend to be low level– Direct relationship to loss of containment

– More connection with immediate causes

– Directly related to plant issues

What might good PSPIs look like?

• Ideally a combination of both “managementsystem” and Hazard/risk based– Must relate to how primary containment can be lost

and the principle controls to prevent this• Active and Passive measures

– May include improvement measures

– Output measures should measure loss of containment

• Use audits for “high level” view of managementsystem

Example• Monthly measures

– Output measures• Reportable releases• Minor releases (by category)

– Input measures• Inspection and testing compliance (by category)• No of demands on protective systems (by category)• No of protective systems found failed on test (by category)• Operating envelope breaches (by category)• Permit to work system compliance (site visits, safe depressuring)

– Improvement objectives• Overdue plant modifications

Complement with audits• Focus of audits could be (for example)

– Effectiveness of leadership– Effectiveness of training– Compliance with key systems

• maintenance,• management of change,• inspection process,• risk assessment,• operating instructions• override management

– Effectiveness of emergency response– Safety culture

Do PSPIs matter?

• Yes, if done properly– Give a window on how hazards are being managed

– Can help support process safety at a local level

– Can promote learning

• But,– Need to see PSPIs as part of an integrated whole

– Need to look beyond the simple numbers

– Need to be alert to issues that aren’t being measured

• How would an imminent TXC be detected?