Post on 07-Jan-2017
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 Executivepeter.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
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
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 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
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 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?