Process Safety Performance Indicators: The UK Experience in Major Hazard Industries Seveso Conference 2010 Stockholm 19 May 2010 Peter Dawson Principal Process Safety Specialist Inspector Hazardous Installations Directorate UK Health and Safety Executive peter.hid.dawson@hse.gsi.gov.uk
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 amplifying existing 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 Initiating event Possible lagging indicators Upset Operating Procedures Safeguard defects Major Accident Pressure relief High pressure alarm/trip Possible leading indicators Plant integrity inspection 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 2 nd 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 doesn t tell you what the problem is! Set leading indicators for the critical must do activities/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 Principles http://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 Risk control systems Challenges to integrity Overfilling Accidental leakage Over-pressure Corrosion Wear Physical damage Subsidence Control and instrumentation Operational procedures Competence Inspection and maintenance Design PTW Plant change Control of contractors
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?