major hazard facilities preparing and managing a safety report

Major Hazard Facilities

Preparing and Managing a Safety Report

2

Overview

The seminar has been developed to provide:

• Context with the MHF Regulations• An overview of what is required by an employer who needs to

prepare and maintain a safety report.

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Some Abbreviations and Terms

• AFAP - So far as practicable• ER or ERP - Emergency response or Emergency response plan• HAZID – Hazard Identification • HSR - Health and safety representative • MHF - Major hazard facility – as defined in the Regulations• MA - Major accident• OHS -Occupational health & safety• Employer - Employer who has management control of the

facility• SMS - Safety management system• SRO – Safety report outline

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Topics Covered In This Presentation

• Introduction• Preparing a safety report• What makes a good safety report• Safety report outline - Core components• Potential pitfalls• Key success factors • Managing and maintaining a safety report• Review and revision• Safety report for a new project

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Understand Understand RequirementRequirement

ss

Planning

Resources, Tools and Systems

Project M

anagement

Project M

anagement

Consultation &

Com

munication

Consultation &

Com

munication

Preparing a Safety Report

Management Management Commitment Commitment and Supportand Support

So this is what’s So this is what’s requiredrequired

So this is what’s So this is what’s requiredrequired

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• The safety report should feature in, and be consistent with, business goals and objectives

• The process is resource and time intensive so commitment for significant funding and employee time is required

• Consistency with company policy, philosophy and objectives is necessary to maintain and sustain a compliant safety report

• Essential that upper management show strong commitment, drive the process and provide the environment for the facility to develop, implement and maintain the safety report

Management Commitment and Support

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• Read the Regulations !!!

• Be sure to interpret the Regulations in the context of your facility

• Define the relationships between the safety report / MHF requirements and other OH&S management activities

• Clarify any points of the Regulations that are not understood. Do this early as several matters require compliant practice from the very beginning of the activity (eg consultation)

• The MHF Regulations are relatively simple to grasp albeit difficult to comply with

Know The Regulatory Requirements

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Safety Report Planning

• Proper planning is an essential element in preparing a safety report

• An effective plan will cover all aspects of safety report development (or review and revision) including important aspects such as consultation

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• Definition of tasks to be completed – What do you need to do ?

• Definition of constraints in place– What resources do you have access to, funding available, regulatory

timeframes etc

• Definition of task inter-relationships– What has to come first, which tasks rely on information from another

task, what are the constraints on availability of resources? etc

• Identification and allocation of resources to each task– Who is needed to complete each task? – What other projects/tasks are competing for the same resource? – What tools, equipment or systems will you require? – What data will you generate and how will you store, use and

manipulate this data? – What resources will you use to monitor progress?


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Other elements in the safety report plan:

• Estimation of task completion times and definition of task milestones in overall project schedule

• Consultation and reporting plan for the project – who needs to be involved, who needs to be informed?

• A clear project organisation structure detailing roles, responsibilities & reporting lines for project activities


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• Safety report outline for new safety reports

• Review/revision plan for update of an existing safety report

• Employees and HSRs should be briefed on the proposed plan to achieve a common understanding and agreement of what is required

• Acceptance by upper management of the resource requirements, process, and commitment is essential


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• Safety report development is a resource intensive process

• Expect that high levels of employee participation are needed

• Plant operators, maintenance personnel, plant managers, engineers, OH&S personnel, consultants, support personnel, administrative personnel, HSRs, contractors and corporate managers are all likely to be involved to a significant extent

• Often spin-off projects are identified to address deficiencies in related support systems (e.g. training systems, document management systems, IT systems)

• Core safety report development roles are not always best served by part time roles


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• Attempt to identify early any important tools which may be required. For example, are CAD drafting facilities required to update drawings? Will access to certain database information be required? What reference materials must be sourced?

• Early consideration on how to record, store, manipulate and use the vast quantity of data generated from the safety report development process is recommended

• Where existing systems, tools etc are to be used for the safety report tasks, it is prudent to verify early that those systems and tools will provide compliant outcomes

• If the systems and tools of third parties (e.g. consultants) are to be utilised, the employer should include tasks to test and verify the adequacy of these for achieving a compliant safety report


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• The significant effort and time commitment required to complete activities such as hazard identification and risk assessment can be wasted if all relevant facts and knowledge are not available

• Early consideration and coordination with many people is generally required

• An objective evaluation of available skills is necessary to ensure additional expertise can be sourced where necessary

• A low tolerance approach to workshop non-attendance is often required from senior management level. Workshops may be arduous, time consuming and often repetitive. Management and HSR support is required to overcome this

• Plant and corporate managers need to agree and commit to the safety report program, and manage conflicting demands on resources accordingly

Availability of Resources

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• The safety report plan needs to not only be defined, but also tracked and monitored to ensure successful completion by the due date and within all constraints

• Good project management is required to ensure tasks are completed on schedule, over-runs are identified early and rectified, barriers to achieving compliance are identified and overcome

• Consider the need for dedicated project resources (e.g. Safety Report Manager) to ensure process is not derailed by conflicting responsibilities

Project Management

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• A great deal of effort and resource is expended by facilities in developing and documenting safety report components. It is important that this effort is accurately reflected in the final documentation

• Facilities should be careful to ensure data presented in their submitted safety report is:

– Accurate – Consistent– Unambiguous– Complete

Quality Assurance

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• Safety report philosophy• Scope of work to be undertaken• Resources, timetable, milestones• Key definitions and criteria (risk, property damage)• Methodology statements (HAZID, risk assessment etc.)• Details of the scope of consultation that will be undertaken• The emergency plan

Safety Report Outline (SRO) – Core Components

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• Inherent risks within the facility• Chief methods of ensuring safe operation at the facility• Description of safety management system• Safety culture within the organisation

SRO Core Components - Safety Report Philosophy

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SRO Core Components – Description of Methods

• The methods chosen for hazard identification and risk assessment are likely to have a major impact on resource requirements and timeline

• Identify these early in the safety report planning• The methods used should align with the approach to safety

adopted at the facility

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SRO Core Components - Consultation

• The MHF Regulations require you to consult with employees and external stakeholders during the development of the safety report

• The safety report outline should describe:– Who will be consulted– How the consultation will occur– How the information from the consultation will be included in the

safety report

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SRO Core Components - Consultation

• Who do you have to consult?• 7 main groups of people

– HSRs– Employees– Emergency Services– Municipal Council(s)– Non-employees who enter the facility (e.g. contractors)– Local Community– Other persons who may reasonably

suspect risk to their health and safety

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SRO Core Components - Emergency Plan

• Emergency Plans exist because things can go wrong and preparation is needed for such an event

• Emergency Plans are more than response procedures; they also include the supporting framework of training, resources, performance measures and drills etc

• Consultation with all emergency services is necessary (because they have a role to play in combating incidents and provision of resources)

• Emergency Plan must be adopted as a control measure and as such the development of meaningful performance measures and indicators is required

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• All parts of the Regulations are systematically addressed• Early momentum is established• High levels of employee involvement• Wide and varied expertise has been made available• Thinking outside the established norms • Challenging the status quo• The safety report process is integrated into facility improvement

plans and business processes• Safety report is owned, understood and managed by the MHF • The safety report process provides clear benefits to stakeholders

What Makes a Good Safety Report?

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• Clear and consistent links between MAs, Hazards, Risk, Controls, Emergency Plan, SMS and Performance Monitoring Regimes

• Implemented control measures, SMS, performance monitoring regimes etc are sustainable given the size and complexity of the facility

• Documentation captures corporate memory• The process is logical and simple – don’t over complicate

What Makes a Good Safety Report cont…

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The safety report demonstrates that:

• The employer fully understands the facility’s processes/systems• The employer understands the facility’s risks• Appropriate control measures have been selected and

implemented to reduce risks AFAP at the facility• Systems are in place to manage each MA to ensure risks

continue to be reduced AFAP• The employer has systems to keep the control measures working

to their stated performance level• The employer has in place processes for reviewing and revising,

as needed

What Makes a Good Safety Report cont…

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• Not taking time to understand the Regulations properly• Inadequate planning• Wasting time and resources redoing work unnecessarily• Over committing to controls and systems which cannot be

reasonably sustained• Do things to “look impressive” but which don’t add real value

to the business• Not using valuable information already available (e.g.

independent audits etc)• Overlooking mitigative controls and the need to maintain them

Some Potential Pitfalls and Mistakes

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Some Potential Pitfalls and Mistakes

• Failing to carry forward changes into all relevant parts of the safety report (e.g. Emergency Plan)

• Inconsistencies between different parts of safety report or between different sources of information

• Losing sight of the big picture – unbalanced focus on certain aspects

• Losing sight of the overall objective of the regime• Failing to make safety report compliment overall

business objectives

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Adequate Planning and Education

• Understand the requirements in the Regulations and know what compliance looks like

• Don’t over complicate at the start• Test processes and methods of documentation before starting• Identify resource needs early and consider how on-going

maintenance of the safety report will be managed

In Conclusion - Keys to a Successful Outcome

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Involve the right people

• Commitment from senior management

• Appropriate depth & range of experience

• Suitably qualified people

• Operations staff, those who;– are exposed to the hazard – are the ones most likely to be impacted by, or contribute to an

incident– understand the true variance in operating conditions and

environments


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Clarity and Consultation

People understand what they are doing and why.

• It is essential to included ongoing consultation with employees

• Everyone exposed to hazards or involved in management of the risk needs to understand;

– The hazards– The risk– The controls – The relationship between them

• The safety report should form the basis of training and operating procedures

• Key documents are updated and available


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Cultural Match

• It is important that the process and methods used will work successfully within the organisation and the way it functions

E.g.• Don’t use highly technical approaches if that is not what you

usually do• Ensure that controls are appropriate to the capability of the

facility to manage them


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Sustainability

• Need to remain focused on the facilities ability to sustain both:– The processes introduced– The outcomes from the process (new controls)

• Ongoing resource requirements need to be considered before starting


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Belief in the Outcomes

• Focus on improving safety, not simply compliance (regulatory or internal)

• Effective real consultation & stakeholder ownership

• Preparedness to challenge established “norms”

• Process and procedure for resolving issues and agreeing assumptions

• Transparency of the process


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Continuous Improvement

• Focussed effort for continuous improvement in all aspects of the safety report and its supporting systems

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Managing A Safety Report

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• The facility has been given a licence for 5 years• Management congratulates all• Everyone breathes a sigh of relief• Onto the next project• Let the safety report sit in the draw until the next

investigators visit or licence renewal period

Managing a Safety Report

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• After all, the licence confirms: – Risks are in control

and

– There are management systems in place to deal with all of the required issues covered by the Regulations

• Tempting – yes• But WRONG!


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What are the key things

to be addressed

on an ongoing

basis


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• The safety report should become integrated into the daily management activities of an MHF

• The safety report process will have identified all of the performance parameters required for managing the risk from each MA


How to use the information to keep the risk from each MA as low as practicable?

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• How to validate that controls identified in the safety report are:

– Implemented?– Functional? – Meeting the performance standards nominated– Changes to circumstances are handled in accordance with the

safety report process requirements

• A system must be in place to verify all of these issues in an explicit and transparent manner


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• The control measures need to be managed through an audit system by the employer and documented in such a manner that allows the performance of every control to be verified

• The overall performance of every control managing an MA should therefore be audited


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Non-MAs (ie OH&S)

Implementation

Hazard Identification

Define Control Activities

Major Accidents

Performance Requirements

Risk Analysis

Dem

on

stration

of

Ad

equ

acy

Safety M

anag

emen

t System


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• The SMS becomes the primary means of managing safety • As with the concept of management systems, if it is stated to

do something, then it should be verified• Performance indicators should be developed to measure the

success or otherwise


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• The effectiveness of the SMS can be measured through a specifically developed auditing process

Reviewing and Revising

Safety management

system

Control activities performance

standard

Demonstration of adequacy

Audit and verification

process

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• The auditing process is considered essential to demonstrate – Continuing compliance with the safety report– Effectiveness of all the processes and systems

• For the facility– The employer can develop a schedule for auditing the SMS

elements and each of the MA controls identified in the safety report throughout the year

– Undertake the audit and report on outcomes


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Example Pressure Safety Valve (PSV)

Performance indicator

• Passes test within acceptable +/- kPa limits

In Place • PSV confirmed, correct location, correct set pressure and relief path open to correct location

Effective • PSV test records indicate that it is within test interval

• PSV passed ‘pop’ test before last recalibration i.e. it was ‘effective’ when removed for overhaul

Corrective Actions

• If failure was noted, what reporting of control failure was done

• What corrective action was identified • Have corrective actions been completed


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• It is natural that with any system there will be opportunities for improvements to be made to the safety report process

• Such improvements could relate to:– Feedback from employees regarding training– Performance of controls (positive or negative)– Management of change– Emergency response exercises – Training– Incidents that occur– Communications with Regulator


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• Feedback from various sources will enable the safety report to be continually used as a key management business platform for the MHF

• It will provide demonstration to all stakeholders of how the process is working

• It will aid transparency and continued demonstration of adequacy that the safety report is fit for purpose


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New Projects

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How do we achieve the right outcome?

New Project!Project

LifecycleSafety Report Requirements

New Project

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• MHF issues need to be considered as early as possible during a project lifecycle

• Decisions taken at early stages of a project will have an impact on the MA profile of the facility – good and bad

• The employer needs to focus on short, medium and long term issues required for the safety report during project development

New Project

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Concept

Design

Commission

Production

Decommission

Disposal

Construction

• Major hazard issues should be considered during each step in the project life cycle

• Important decisions at the concept phase can impact upon the overall risk profile of the facility throughout its life

New Project

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• It is cheaper to fix an issue at the design phase than the operational phase

• Retrofitting control measures or fundamental design changes during the operational phase:

– Is always more expensive – Places a very large burden financially on operational budgets– Delays the facility from reaching the designed throughput targets

• If the process is well structured, the reasons for specific controls adopted and rejected can be documented – corporate memory

• The corporate memory approach is extremely valuable

New Project

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• For example, XYZ company engages a contractor for developing a project on a lump sum basis and the project requires MHF licensing

• In many cases the contractor will engage a resource to deal with MHF requirements

New Project – Potential Issues

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XYZ Company

EPC Contractor

MHF ResourceSub contractor 2Sub contractor 1

Possible Project Organisation


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• The question for all concerned is “how can the objectivity of a safety report development be achieved without competing elements of the project being compromised”?

• The key to a successful outcome is how the contract is set up between XYZ company and the contractor


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• Conflicts of interest can easily occur – there are many examples of this and the end result would be costly for both XYZ company and the contractor

• MHF issues that arise which are outside the basis on which the contractor’s lump sum price was developed will need to be addressed – as opposed to being ignored

• This may lead to protracted delays between employer (XYZ company), contractor and regulator


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Contractual arrangements

Resources (internal versus

external)

Clearly defined deliverables

Establishment of milestones

Establishment of key criteria and

methods

Clearly defined responsibilities, accountabilities and authorities

Start the safety report early -at the concept phase


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The contractual arrangement should address:

• Commitment of client • Contractual and planning arrangements• Resources (internal versus external) • Clearly defined deliverables• Establishment of milestones• Establishment of key criteria and methods• Clearly defined responsibilities, accountabilities and

authorities• Start the safety report early (at the concept phase)


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Questions?

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Supporting SlidesEmergency Plan

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• An emergency response plan is a mitigative control that may prevent an incident from escalating to a more severe outcome


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• Develop your EP/ERP based on your credible Major Accident Scenarios

• Involve all emergency services in the consultative process• Ensure involvement of council and community• Simplify procedures• Develop and implement performance standards that will

value-add to the emergency plan• Conduct exercises based on the plan

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• When an emergency occurs, the first steps taken will have an impact on the outcome (consequences)

• The outcome can be minimised by having control measures and systems in place to mitigate the consequences of an emergency situation

• This takes: – Planning – Evaluation – Adequacy of systems in place – Training

• It is an ongoing process over the lifetime of the MHF


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• Emergency planning is a cyclical process• The plan should be:

– Dynamic and interactive – Ensuring ongoing relevance to the needs of the facility and all

stakeholders by continual: ◦ Monitoring◦ Review◦ Consultation


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Hazards Controls Controls

Preventative Control Measures

Mitigative Control Measures

MA

Ca

use

s

Ou

tcom

es

Consequences

Eliminationmeasures

Prevention measures

Mitigation measures

Land-use planning

Emergency response

Reduction measures

Hazards Controls Controls

MA

Ca

use

s

Ou

tcom

es

MA

Ca

use

sC

au

ses

Ou

tcom

es

Ou

tcom

es

Consequences

Eliminationmeasures

Prevention measures

Mitigation measures

Land-use planning

Emergency response

Reduction measures

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Aim of the Plan• Provide a system and resources to protect people, property

and the environment • To minimise adverse impact on people, property and the

environment

Objectives of the Plan• Comprehensive, yet concise, simple and flexible


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Emergency Plan Contents - Example

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Emergency Plan – Site and Hazard Detail

• Links the risk assessment outcomes to the emergency plan• Identifies personnel resourcing issues• Details assumptions• Details the combating resources available on site• Details Emergency Response Plans

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Assumptions affecting the emergency plan:• Assumptions on the availability of resources and services and

the execution of responses within an estimated time frame• Assumptions should be evaluated and contingency plans

developed when assumptions fail or cannot be justified

Typical assumptions include:– Availability of external resources– Response time of emergency services– Correct operability of equipment– Key personnel will be available on site at time of incident– Personnel will be competent to undertake duties as detailed in

the plan– Fire water containment capability


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Estimation of Consequences:

• The effects/impacts can be estimated from information available on material released, operating conditions, facility layout, nature of the surroundings and environmental conditions:

– Nature and rate of material released– Radiated heat generated by a fire– Blast generated by an explosion– Toxic concentration in the atmosphere– Escalation potential


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Estimation of Consequences:

• Once the analysis of the scenario has occurred, the emergency response scenario information can be presented in a consistent format

• Format is site specific but must meet the needs of those expected to use the information including site and emergency services personnel.


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Example Emergency Response Plan

Product

Fire Consequences

Foam and Water Requirements

Fire Fighting Equipment

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Example Emergency Response Plan

Site Plan

Pool Fire

Heat Flux with Wind (4.7 kW/m2 for personnel accessibility)

Heat Curve irrespective of wind direction

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• Identifies roles for individuals within the emergency plan• Identifies:

– Who is in charge– What personnel should do– Why they do it– When they do it– Who is communicating with whom– How to contact persons, organisations or additional resources

Emergency Response – Command Structure & Personnel

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• Roles and responsibilities needs to clearly detailed and should to be consistent with the Command Structure

• Role statements need to be available for all positions and persons need to be familiar with their role and also their contingency role (if any)

Emergency Response – Command Structure & Personnel

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• On site personnel• Off site facilities• Emergency services• Applicable authorities

Emergency Plan – Notifications

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• Information required by fire services when responding to a notification should be “fit for purpose”

• i.e. for Chemical Spill– Type and scale of the spill (eg within bund or uncontained)– Name of the substance involved– UN Number– Estimated quantity

Emergency Plan – Notifications

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• The plan must identify all resources available on site that are available for use during an emergency

– Where the equipment/material (foams, neutralisers, etc) are located or how they are to be obtained

– Fixed fire fighting systems should be explained, in particular their design intent (eg. Deluge systems -cooling or mitigation) & method of activation

– Flow rates and water supply duration should also be detailed

Emergency Plan – Resources

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• These procedures must enable any person on site to understand what is expected of them and what actions they are required to undertake

• The procedures must explain who is responsible for accounting for personnel and how it is to be achieved (links to Command Structure)

Emergency Plan – Evacuation Procedures

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Control Isolation Points:

• Provides details for the isolation of:– Utilities (gas, water and electricity)– Road Traffic

• Isolation points need to be identifiable, accessable and maintained

Emergency Plan – Isolation Procedures

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The Emergency Plan as a Control Measure

• The emergency plan must be included among the control measures adopted under Regulation 9.45.

– Need to identify appropriate Performance Indicators and Standards that will ensure the on-going effectiveness for each individual control, to enable ongoing assurance.

– Indicators of failure need to be identified– Actions to be taken in reporting any such failure– Other corrective actions to be taken in the event of any such

failure.

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Emergency Plan – Example Performance Standards

• Emergency response personnel are nominated and manned on all shifts

• Response plans are in place for all emergency scenarios• Emergency response personnel training is current• Emergency response resources are available, capable and

tested• Drill/exercises are conducted according to the schedule

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Emergency Plan – Example Performance Indicators

• % of fire equipment inspected and tested as per schedule• Evacuation of non essential personnel to assembly point within

7 minutes• Notification to Emergency Services within 2 minutes of

potential major accident being identified• Emergency Response Team to assemble within 3 minutes of

alarm• Emergency response plan exercises are completed within one

month of scheduled date

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Emergency Plan - Testing

What is the desired outcome of conducting an emergency exercise?

• To be able to demonstrate so far as is reasonably practicable that in the event of emergency (eg MA), the mitigation control measures will work as expected to reduce the likelihood of injury to all persons and restrict damage to plant, equipment and local community to a minimum.

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Emergency Plan - Testing

What else is tested in an emergency exercise?

• Alarm and communications systems• Call-out of internal/external emergency personnel• Critical emergency equipment availability• Evacuation procedures

Ensure participation of appropriate emergency services.

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Emergency Plan Testing – Desktop Exercise

• Useful training for familiarisation with procedures and site emergency issues

• Can identify resource limitations, issues and knowledge amongst personnel

• May not adequately test communication, site evacuations processes or equipment accessibility.

• Desktop exercise should not be used as the means of compliance with Regulation 9.53(4)

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Emergency Plan Testing – Simulated MA Scenario

• Will test effectiveness of evacuation procedures• Coordination between onsite procedures and emergency

services• Extended test of onsite/offsite communication systems• Tests capability of emergency services to response• Identify limitation/restrictions in equipment access

major hazard facilities preparing and managing a safety report

Documents

revision safety report

safety report review

safety report planning

safety report mhf requirements

support slide

mhf regulations

new project slide

upper management