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Major Hazard Facilities - Safety Management Systems _presentation_

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									Major Hazard Facilities

Safety Management Systems
Overview


  The seminar has been developed to provide:

  •   Context with MHF Regulations
  •   An overview of what is required
  •   An understanding of the SMS and why it is important




                                                            2
Some Abbreviations & Terms
   •   AFAP - As far as (reasonably) practicable
   •   Employer - Employer who has management control of the facility
   •   ER or ERP - Emergency response or Emergency response plan
   •   Facility - any building or structure at which Schedule 9 materials are
       present or likely to be present for any purpose
   •   HAZID - Hazard identification
   •   HSR - Health and safety representative
   •   LOC - Loss of containment
   •   LOPA – Layers of protection analysis
   •   MA - Major accident
   •   MHF - Major hazard facility
   •   MOC – Management of change
   •   OHS - Occupational health & safety
   •   SR - Safety report
   •   SMS - Safety management system




                                                                                3
Topics covered in This Presentation


   •   Introduction
   •   Regulations
   •   What is a safety management system?
   •   SMS models and standards
   •   Key elements of the SMS
   •   The importance of SMS
   •   What should the SMS do?
   •   Measurement of performance
   •   Examples of SMS performance standards
   •   Emergency planning
   •   SMS testing
   •   Items to note
   •   Critical success factors
   •   Sources of additional information


                                               4
Regulations
Occupational Health and Safety (Safety Standards) Regulations 1994




                                                                     5
What is a Safety Management System?


   •   An SMS is a comprehensive and integrated system that
       ensures that all work at the facility is conducted safely
   •   It should be fully documented, accessible and
       comprehensible to those that need to use it
   •   It recognises the potential for errors and establishes robust
       defences (control measures) which are fully implemented, to
       ensure that errors do not result in accidents or near misses
   •   It is comprises a set of work practices and procedures for
       monitoring and improving the safety and health of all aspects
       of the operation




                                                                       6
Key Terms Used in Describing the SMS


   Comprehensive
   • Describes the way that all safety issues including control
     measures are managed
   • Clear link between controls management and the SMS

   Integrated
   • The structure is logical, systematic
   • Logically ties in to other management systems
   • Corporate systems do not contradict onsite systems

   Comprehensible
   • Abbreviations and terms used mean something to employees
   • Consideration of language issues



                                                                  7
Key Terms Used in Describing the SMS


   Implemented
   • Procedures are approved and in circulation
   • Evidence is available – completed forms and/or checklists
   • Employees are trained and knowledgeable

   Accessible
   • Employees are aware of how to obtain the most up to date or
      relevant procedures
   • Employees can obtain the SMS information needed to support
      control measures




                                                                   8
SMS Models & Standards


   •   Sound management systems are all similar in fundamental
       terms
   •   Compliance with the MHF Regulations does not require any
       particular standard to be used, nor will compliance with an
       existing management standard ensure compliance with the SMS
       requirements of the MHF Regulations
   •   There are a variety of ways in which the SMS can be structured.
       Most large organisations will have their own structure already
   •   However, adoption of a proven standard may assist an MHF
       employer




                                                                         9
   Examples of SMS
   OH&S Management Systems Model – AS 4801




                                            Overall
                                         vision, goals
                                              and
                                         commitment
                                          to improve


                                                        • Legal compliance
       Suitable, adequate,                             • Objectives and targets
        effective                                       • Implementation plans
       Changes needed?
       Opportunities to
        improve?

                                             • Resources
                                             • Leadership responsibility
• Monitoring and                             • Training and competency
  measurement                                • Consultation and communication
• Incident investigation                     • Documentation
• Records management                         • Hazard identif ication, risk assessment
• Audits                                       and controls
                                             • Emergency response




                                                                                         10
Examples of SMS
ISO 14001 Environmental Management Systems



                     Environmental
                        Policy


                        Planning


                     Implementation
                       & Operation


                       Checking &
                    Corrective Actions


                      Management
                        Review



                                             11
Key Elements of the SMS

                             Policy


                            Planning
   From the previous
   examples, there are
   common elements
                          Implementing


                           Assessing



                          Management
                            Review




                                         12
Key Elements of the SMS

         Policy
                          Effective health and
        Planning          safety policies set a
                          clear direction for the
                          organisation to follow
      Implementing


        Assessing



      Management
        Review




                                                    13
Key Elements of the SMS

         Policy


        Planning          An effective management
                          structure and arrangements
                          are in place for delivering
      Implementing        the policy.

                          There is a planned and
        Assessing         systematic approach to
                          implementing the health
                          and safety policy

      Management
        Review




                                                        14
Key Elements of the SMS

         Policy
                          The policies and
        Planning          procedures are put in
                          place to manage all
                          aspects of the control
      Implementing        measures that ensure safe
                          operation of the facility

        Assessing



      Management
        Review




                                                      15
Key Elements of the SMS

         Policy


        Planning
                               Performance is
                              measured against
      Implementing           agreed standards to
                           reveal when and where
                          improvement is needed.
        Assessing



      Management
        Review




                                                   16
Key Elements of the SMS

         Policy


        Planning

                          The organisation learns
      Implementing        from all relevant
                          experience and applies
                          the lessons.
        Assessing



      Management
        Review




                                                    17
The Importance of SMS


  •   In reviews of accidents, a common thread throughout is the
      inadequacy of management systems that might have
      prevented the accident from occurring
  •   Examples of some issues identified are
       –   Lack of hazard review and risk assessment to predict and
           prevent incidents
       –   Insufficient investigation and follow up after previous incidents
       –   Inadequate training of staff
       –   Failure to implement effective mechanical integrity programs




                                                                               18
The Importance of SMS


   The following information provides broad details on some US
   incidents and contributing causes




                                                                 19
The Importance of SMS

   Breakdown of management system categories identified as
   contributing causes in incident investigations




                                                             20
The Importance of SMS
  •   Flixborough 1974
       –   Management of
           modification failure
       –   Inadequate experience
       –   Overstretched resources




  •   Piper Alpha 1988
       –   Failures in shift handover
       –   Permit to work
       –   Training
       –   Communications
       –   Auditing




                                        21
The Importance of SMS

  •   Pasadena 1989
       –   Maintenance
       –   Permit to work errors
       –   Failure to follow-up on
           audits



  •   Longford 1998
       –   Inadequate knowledge of
           hazards
       –   Absent personnel
       –   Poor procedures




                                     22
The Importance of SMS
  BP America Refinery Explosion Texas City, 23 March 2005

  •   Corporate safety oversight,
      including the safe
      management of sites obtained
      through mergers and
      acquisitions
  •   Corporate safety culture
  •   Corporate and site SMS
  •   Near miss reporting and
      investigation programs
  •   Mechanical integrity programs
  •   Hazard analysis programs
  •   Change management




                                                            23
The Importance of SMS - Exercise
  Buncefield Explosion, UK, 11 December 2005

  •   In the early hours on
      Sunday a number of
      explosions occurred at
      Buncefield Oil Storage
      Depot, Hemel Hempstead,
      Hertfordshire
  •   At least one of the initial
      explosions was of massive
      proportions and there was a
      large fire, which engulfed a
      high proportion of the site
  •   Over 40 people were
      injured; fortunately there
      were no fatalities




                                               24
The Importance of SMS - Exercise
  Buncefield Explosion, UK, 11 December 2005


  What control measures
  • Were in place?
  • Could have been in place?
  • Were they effective?




                                               25
The Importance of SMS - Exercise
  Buncefield Explosion, UK, 11 December 2005




  Common theme – failure to manage the control measures



                                                          26
The Importance of SMS - Exercise
  Buncefield Explosion, UK, 11 December 2005



  •   What SMS elements were needed to ensure that the control
      measures worked when required?




                                                                 27
The Importance of SMS - Exercise
  Buncefield Explosion, UK, 11 December 2005




                                               28
The Importance of SMS – Australian Experience


  •   Feedback from regulator site visits to Australian MHFs,
      together with examination of incident data has revealed the
      following issues are likely to be the weakest links within an
      SMS
       –   Management of 3rd parties
       –   Maintenance procedures and systems
       –   Hazard identification and analysis
       –   Engineering design and review
       –   Operating procedures
       –   Management of change




                                                                      29
The Importance of SMS – Australian Experience


  Other issues to note:
  • There are always fundamental failings in the “system”
  • Complacency and safety versus production conflicts
  • Deficiencies in practice with adherence to application of the
    SMS rather than system standards
  • Failure to accept and prepare for emergencies




                                                                    30
What Should the SMS Do?


  •   The SMS is the tool with which the Employer meets the overall goal
      of the Regulations
  •   The SMS should cover the following
       –   Define safety roles and responsibilities
       –   Ensure adequate skills, information, tools and decision-making are
           present in day to day and abnormal operations
       –   Maintain awareness of hazards and risks
       –   Plan, implement, measure and evaluate MA controls and the SMS
       –   Develop performance requirements
       –   Set targets for improvement of safety at the facility
       –   Manage change




                                                                                31
What Should the SMS Do?


  •   Manage and maintain knowledge
  •   Instigate HAZID and risk assessments
  •   Manage adequate human resources
  •   Provide performance information to all levels of
      organisation
  •   Review and improve the SMS itself




                                                         32
What Should the SMS Do?


  •   Manage safe operation at the facility, including MAs,
      specifically focusing on:
       –   Prevention
       –   Reduction
       –   Mitigation
  •   It is not just documentation - it is the actual implementation
      of processes, procedures and practices at the facility
  •   Include and reflect the safety culture at the workplace




                                                                       33
What Should the SMS Do?


  •   Some companies, in particular employers of multiple sites, may
      apply corporate standards for an SMS
  •   These may prescribe the entire SMS, or only common high-level
      components such as the overall policies and procedures
  •   In other cases corporate SMS requirements may be very
      limited, and the site will then need to develop its own systems




                                                                        34
What Should the SMS Do?


  •   Many corporate systems specify that local regulations override
      corporate requirements if they are more stringent
  •   Other companies may employ integrated management
      systems for the business as a whole
  •   It is entirely up to the Employer to choose how the SMS is
      structured and developed
  •   However, in all cases the SMS must provide a management
      focus on the specific control measures required for safe
      operation of the particular facility




                                                                       35
What Should the SMS Do?



Level 1                 Corporate Safety Management System


Level 2     Local procedures and practices (design, maintenance & operation)




                                                                               Consequences
                         Hazards



                                                Accidents
               Causes




Level 3



                                   Prevention               Mitigation
                                                                         MA Potential
                                   Controls                 Controls


                                                                                              36
What Should the SMS Do?


  •   The SMS should not just be seen as satisfying MHF
      requirements
  •   It should be used as a performance management tool to assist
      in managing the entire operation, including other performance
      based regulatory requirements
  •   Most modern management system “standards” or "models"
      feature a set of generic elements, forming a continual
      improvement cycle




                                                                      37
Measurement of Performance


  •   Performance standards/indicators must be developed and
      implemented as part of the SMS (e.g. measure the
      effectiveness of SMS) to support the MHF safety objectives
  •   The following principles apply in defining performance
      standards: Make them SMART
            •   Specific
            •   Measurable
            •   Achievable
            •   Realistic
            •   Targeted
  •   The purpose of performance standards/indicators for the SMS
      is to enable the objective measurement of its target and
      (subsequently) effective maintenance and improvement of
      performance




                                                                    38
Measurement of Performance


 •   Standards and systems need to be practical
 •   Should not place an unworkable burden on employees
 •   Ensure open, comprehensive and accurate reporting of errors or
     problems

     Is an absence of evidence of problems really indicating
     high performance?




                                                                      39
Measurement of Performance


  •   Performance indicators need to be meaningful and contribute to
      the overall evaluation of the SMS effectiveness
  •   If a control is stated to be in place for prevention of an MA,
      then:
       –   Is it implemented?
       –   Is it effective?
       –   Is it audited?
       –   Are the results used for improving the effectiveness of controls
           management?




                                                                              40
Measurement of Performance


  •   Performance indicators should be established covering (as a
      minimum):
       –   How often audits are to be undertaken
       –   Scope of the audits
       –   Are the controls implemented?
       –   Are the controls functional?
       –   % compliance, partial compliance and non compliance
  •   Performance indicators should be sufficiently detailed and
      transparent to enable the effectiveness of the SMS to be
      apparent from the documentation




                                                                    41
Measurement of Performance


  •   The audits need to be evaluated against criteria developed by
      the MHF
  •   They should include steps to continually improve the SMS, so
      there needs to be processes and measures designed to
      identify and implement improvements to the system itself
  •   Three main types of audits
       –   First audit: Self audit
       –   Second party: audit of suppliers
       –   3rd party: external agencies e.g. regulator, certification bodies.




                                                                                42
Measurement of Performance

  •    Likewise, 100% compliance is a desirable objective - but realistically
       not practical
  •    Setting a tiered acceptability criteria could be an option

      Example only:
      Item               Compliance      Partial          Non-
                                         Compliance       compliance



      Audit frequency    90%             10%              0%
      for controls met
      Audit time frame   90%             10%              0%
      achieved
      Controls           100%            0%               0%
      implemented
      Controls           95%             5%               0%
      functional



                                                                                43
Examples of SMS Performance Indicators


Permit to work         Number of accidents or near misses caused by a
                       failure of this system
                       % permits audited compliant with procedure

Management of change   Number of accidents or near misses caused by a
                       failure of this system
                       % of MoC forms completed in compliance with
                       procedures
                       % temporary changes beyond their time limit

Operating procedures   % of new procedures completed
                       % of procedures reviewed

Auditing               % audits completed to schedule
                       Number of non conformances closed out/month




                                                                        44
Items to Note - Emergency Planning


  •   The MHF must prepare an emergency plan addressing the on-
      site/off-site consequences
  •   Must consult with employees and emergency services
  •   Plan should consider
       –   Accident type (e.g. major/minor, environmental, personal safety,
           on-site, off-site, property damage)
       –   Command hierarchy and contact information
       –   Equipment required
       –   Contingency plans
  •   Plan should be tested, reviewed, updated




                                                                              45
Items to Note - Management of Change


  •   Management of change needs to be considered very carefully
      within the safety report

  •   An issue often discussed is:
       –   When is a change really a change?
       –   When is a change not a change?




                                                                   46
Items to Note - When is a change really a change?


  •   Any change to an MHF needs to be evaluated in the context of
      the safety report
  •   Examples of this include but are not limited to:
       –   Organisational change
       –   Addition of a new unit
       –   Closure of a unit
       –   Any modification to a potential MA


  •   Desired Outcome: Demonstrate that at least the same level of
      risk or lower is achieved after the change and that all the
      processes within the safety report are followed and transparent




                                                                        47
Items to Note - When is a change not a change?


  •   Any change to an MHF that involves swapping like for like is
      not considered to be a change
  •   This assumes the equipment or systems being changed are fit
      for purpose




                                                                     48
Items to Note - Incident Investigations


  •   Incidents that occur or could have occurred at an MHF are a
      valuable source of information
  •   As with good practice, all incidents at a facility should be
      reviewed for lessons learned and their findings implemented
      for prevention in the future
  •   For an MHF, investigation of MAs is of particular importance as
      it will provide insight into the mechanism of occurrence




                                                                        49
SMS - Critical Success Factors


  •   Adequate resources for both development and improvement
  •   Personnel are aware of their responsibility and accountability
  •   Personnel are trained/competent
  •   Consistent with the understanding of risk gained from the risk
      assessment
  •   There should be sufficient focus on MAs, from planning
      through to operations
  •   The Employer must document the basis for the facility's SMS,
      and the SMS itself




                                                                       50
SMS – Critical Success Factors

 Comprehensive and Integrated
  •   Adequate resources for both development and improvement
  •   Responsibilities & accountabilities defined
  •   Adequate education and training is provided for employees
  •   Covers the whole facility as defined in the safety report
  •   Employees know how to access it and understand it
  •   Performance indicators & standards for the control measures and
      the SMS as a whole are defined
  •   Planning, implementation and monitoring processes are provided
      for control measures and the system as a whole and failures are
      addressed
  •   Processes are provided for review and revision of control
      measures and the SMS

     More information is available in Booklet 3 on the SMS




                                                                        51
Review and Revision


  •   The SMS needs to be reviewed on a regular basis to ensure it
      is fit for purpose for management of an MHF
  •   Over a period of time the lessons learned together with results
      of performance reviews should enable improvements to be
      documented




                                                                        52
Sources of Additional Information


  •   Safety Management, Hazardous Industry Planning Advisory
      Paper No. 9, Guidelines for the Development of Safety
      Management Systems, Department of Urban Affairs and
      Planning, 1995
  •   AS/NZS 4801:2001, Occupational Health and Safety
      Management Systems
       –   Specification with Guidance for Use, Standards Australia,15
           November 2001
       –   General Guidelines on Principles, Systems and Supporting
           Techniques, Standards Australia,15 November 2000




                                                                         53
Sources of Additional Information


  •   AS/NZ ISO 9001:2000, Quality Management Systems
  •   AS/NZ ISO 14001:2004, Environmental Management
      Systems
  •   API Recommended Practice 750, Management of Process
      Hazards
  •   API Publication 9100, Model Environmental Health and Safety
      Management System and Guidance




                                                                    54
Sources of Additional Information


  •   UK Health and Safety Executive HSG65, Successful Health and
      Safety Management
  •   US Department of Labour. OSHA Standard CFR 29 1910.119,
      Process Safety Management
  •   AIChE, CCPS, Guidelines for Implementing Process Safety
      Management Systems
  •   Management System Failures Identified in Incidents
      Investigated by the U.S. Chemical Safety and Hazard
      Investigation Board, Angela S Blair PE Chemical Incident
      Investigator, Process Safety Progress, December 2004,
      Volume 23, No.4




                                                                    55
Questions?




             56

								
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