Fire and Explosion Hazard Management UK Offshore model Presentation to the Dutch Seveso Inspectorate by Graham Dalzell (TBS)3

Risk Management Model :ISO 18001 Policy Review Planning Leadership Understanding Communication Monitor Implement (TBS)3

Leadership = Attitude Careful, courageous or reckless Investing or cost cutting Short term profit or long term stability and security Keeping going or prepared to stop No room for error Managing rules and compliance or managing hazards. Appeasing the regulator or matching their requirements to your own aims Understanding or ignorance Owning hazards and risks – or employing consultants Reactive audit culture or proactive hazard management

Is it Safe? Society demands the answer: Yes Is this what the managers of your major hazard sites ask?

We do risk assessments and we make recommendations, and we implement them, so the risk has gone away, hasn’t it? Should we just deliver recommendations or Should we deliver risk and hazard knowledge

The Good News Culture LESSONS FROM LONGFORD The Esso Gas Plant Explosion Professor Andrew Hopkins Australian National University ISBN 1-86468-422-4

Hazard Understanding How can we manage if we don’t understand? We will all know what is dangerous, why it is dangerous and what each of us must do to keep us all safe. How can we manage if we don’t understand? (TBS)3

Most common comments during accident investigations No-one told me that could happen I didn’t know that was important I didn’t know it would be like that

So what’s this and what caused it?

Who are WE? Everyone who manages a company, operation, design department or contract. Everyone who operates, maintains, inspects or audits a plant Everyone who designs a facility, process, assembly or component Everyone who supports design and operation. (TBS)3

Director Manager Supervisor Individual Operations Maintenance Engineering Contracts Design SLIDE 7 STRUCTURED DIAGONAL SLICE: The earlier referenced work in the ISM gave clear responsibilities at each level of an organisation. This is crucial for this process. It argues that there are at least four distinct levels within an organisation, The role and responsibilities at each level are different. It is argued that they manage the following aspects of hazard and risk: Corporate, - setting the overall corporate risk levels and managing the total exposure - corporate risk management Divisional, - managing their business within the allocated fraction of the corporate risk target – business and facility risk management – ensuring that there is sufficient resource to support hazard management in the facility and setting the clear operational limits of intolerability. Plant/Facility –managing hazards; i.e. ensuring that sufficient critical elements are in place and effective to manage the hazards at the time Individual/Element or Task. – managing the individual elements; people, plant or processes so that they are available and effective. The diagonal slice would probe how the performance and effectiveness of specific attributes at each level, bearing in mind the different roles that they play in the hazards and risk management process. The diagonal slice would not only examine the parts of the organisation with direct responsibility but would look across other critical support functions such as engineering, contracts, procurement which have an indirect but important role.

Communication :We have a finite capacity for information in our memory in an aide memoir accessible as a detailed reference But do our risk analyses look like this?

Distilling the information: Who needs to know what Senior management Corporate risk levels; patterns of risk by business type and location; future risks; the underlying risk drivers Business and regional managers Facility risk levels; patterns of risk by facility hazard and personnel; demands on business processes and others Plant and project managers Facility hazards, their relative risks and characteristics; hazard strategy; critical measures; operating limits Operators, technicians and designers Hazard characteristics, why measures critical are critical, performance standards and limitations

Operators, technicians Assigning the responsibilities: Who carries the can – and who says stop? Senior management Setting the tolerable risk levels and deciding how close to operate; providing the resources to reduce risk Business and regional managers Operating within corporate risk levels; providing the supporting infrastructure; Deciding how risks should be managed Plant and project managers Operating the plant within its limits; managing the hazards and activities; ensuring critical measures are suitable Operators, technicians and designers Comply with procedures; maintain their competence and the plant to the performance standards

Developing the knowledge Corporate Risk Level Regional/business Risk profile Regional/business Risk profile Regional/business Risk profile Facilities Analysis Hazard Registers Hazard Registers Hazard Registers Facilities Analysis Facilities Analysis Critical Measures Critical Measures Performance stds Performance stds

Policies must be structured and integrated: Policy: - What do we want?: Policies must be structured and integrated: Level 1 – Leadership, accountability and tolerable risk levels Level 2 – Risk management, resourcing, and relationships Level 3 – Processes; design, operations, maintenance, contracts Level 4 – Competencies, procedures, operating limits and plant (TBS)3

Typical Corporate HSE management system Design and Construction Leadership and Accountability Community and Stakeholder Awareness Operations and Maintenance Risk Assessment And Management Crisis and Emergency Management Management Of Change People Behaviours and Competence Incident Analysis and Prevention Information and Documentation Working with Contractors and others Assessment Assurance and Improvement Customers and Products

HSEMS Default set of rules? Discrete and unrelated elements? Audit and compliance culture? Different owners? No coordination? Generic requirements rather than matching hazards No risk based investment and infrastructure? Importance based on perception not risk Cyclical emphasis on elements and hazards?

A SAFETY CASE IS NOT A HAZARD AND RISK MANAGEMENT SYSTEM But many companies think that it is

Typical Corporate HSE management system Leadership and Accountability People Behaviours and Competence Operations and Maintenance Design and Construction Information and Documentation Crisis and Emergency Management Risk Assessment And Management Community and Stakeholder Awareness Incident Analysis and Prevention Working with Contractors and others Assessment Assurance and Improvement Customers And Products Management of Change

Bringing all the parts of hazard management together Inputs WHAT WE CAN EXPECT FROM THE COMPANY Minimum default standards for people and plant Actual condition and provision History and knowledge Outputs WHAT THE RISK ASSESSMENT SHOULD DELIVER Hazard an risk knowledge Extra requirements above the default provision Critical plant, processes and procedures What have we got, what do we need, what can we provide, how do we live with it?

Planning:- What do we need to do? Understand the hazards Reduce risks at source Decide how, what and who we need to manage the hazards Set performance standards and operating limits Evaluate the risks Identify the improvements Determine the resources needed to implement hazard management (TBS)3

Cause Severity Consequence Escalation HAZID HAZARD UNDERSTANDING Cause Severity Consequence Escalation RISK ELIMINATE MINIMISE at SOURCE STRATEGY PREVENT CONTROL MITIGATE EVACUATE SYSTEM PASSIVE ACTIVE OPERATIONS EXTERNAL STANDARDS ROLE and SUCCESS RATE IS IT GOOD ENOUGH? NO: - IMPROVE or CHANGE YES: PROCEED COMMUNICATE

Design out people – the make mistakes and they die. ELIMINATE Inherently safer design and operation Designing out hazards – simpler plant Eliminating or minimising causes Reducing the severity pressure, inventory, hole size) Reducing consequence – fewer people, better layout, lower overpressures Design out people – the make mistakes and they die.

STRATEGY What is the “design case” Is it practical to contain the effects? Rigorous source, consequence and escalation analysis – effective control and mitigation Is it practical to make sure that extreme events do not occur Rigorous causation analysis and effective prevention

SYSTEMS Passive – no moving parts –highly reliable Active –breaks down and requires maintenance and intervention – predictable reliability Operational – needs competent people and judgement – subject to error External – relying on others outside your control – needs clear definition of expectations

Performance standards Active Functionality, Availability, Reliability, Survivability Passive Functionality, Inspection Frequency, Survivability Operational Numbers, Role, Competence , Availability External Duty, Availability, Resource

the judgement of adequacy? Risk Assessment: Is it good enough? How do we manage the judgement of adequacy?

UKOOA Risk based decision making framework Extreme consequence uncertain hazards Societal Values Company Values Well understood risk specific major accident hazards QRA Qualitative Risk Assessment Engineering Judgement Well understood lower risk hazards Good Practice Codes and Standards

“As Low as Reasonably Practical”

Implementation:- Making it work Share the hazard and risk knowledge Establish the business processes Assign the responsibilities Provide the resources Embed or confirm the requirements: - procedures, competencies, performance standards Implement the improvements (TBS)3

The Reality – Badly Maintained? SLIDE 15: THE REALITY – BADLY MAINTAINED (Poor Implementation) This shows the condition and effectiveness of pressure monitoring on a HP gas line and severe metal loss on the main piping.

The Reality – Badly Operated? SLIDE 16 THE REALITY – BADLY OPERATED: ( Poor implementation) This slide shows open sampling of a highly gaseous oil stream into a plastic bottle. It is indicative of long established bad practices.

Monitoring:- Is it working? Advanced safety auditing (ASA) - Confirm hazard understanding - Is the process complete and is it working? Competence assurance Adequacy and compliance with procedures Plant integrity verification Adequacy of resources (TBS)3

Review:- How and where do we improve? 4 levels of improvement (TBS)3 Strategic corporate risk reduction - business rationalisation/closure Infrastructure and resource enhancement, facility improvement Hazard management improvement; - strategy, system selection Performance improvement - people, plant, procedures (TBS)3

Proactive Hazard Management not Retrospective Risk Assessment (TBS)3