Safety and Risk

The perspective of a Researcher Dr. Michalis Christou - Joint Research Centre

E.U. and Richard Gowland – Director European Process Safety Centre

• IN EUROPE…………….

• Accidents in industry kill one person every 2 hours and injure one person every 15 seconds

• The death toll is approximately 4,900 every year from a total of 7.6 million accidents

The Facts about Industrial Accidents

Some approximate statistical comparisons

• Most of Chemical Industry is performing with an average accident rate of less than 1 per 200,000 man hours (a significant number are achieving 0.4 or lower)

• Translate this average to the working population of European Union and the number of accidents should be approximately 1.3 million – saving >6 million accidents

• Performance in the top quartile would result in 520000 accidents – > 90% improvement

• In 2003 a global major in the sector found that 70% of its sites had no reportable accidents

Outcomes

• Chemical Industry accident (Lost Time Injuries, Fatalities etc.) statistics are among the best for all industry ….BUT

• Perception (and unfortunately sometimes reality) is that when something goes wrong, many people can be affected in the worker population and the community

• An ‘Aversion’ factor is quite understandable

Significant milestones in improving safety and lowering risk

• Finding a way to identify what can go wrong• Finding a simple set of tools which allow ‘quantification’ of the

severity • Finding a way to communicate it within an organisation• Making everyone accountable for knowing what can go wrong,

what role they have in preventing it and if it happens, what they need to do to mitigate it.

• Making business leadership understand that they (and not the Safety Department) are primarily accountable for performance

• Board of Directors setting the risk governance criteria in the full knowledge of what it is likely to cost

KEY roles of the CEO, Board of Directors and Business Leaders

• Understand the risks for each business• Recognise their responsibility for performance• Dialogue with the Technical Expertise in the company who have

assessed the risks • Challenge the Technical Expertise on improvement programmes

– tell them ‘what must be done’ not ‘how it must be done’• Make binding agreements – with unambiguous metrics and

timings• Fund the programmes and discipline the organisation • Follow up with periodic reports

Transparency – putting your CEO reputation on the line!

• Tell the world that today’s performance is not good enough

• Tell what targets you have set (however ambitious – e.g. 90% reduction - they might seem)

• Tell them you will report progress (and do it)• Even the hard-nosed financial and insurance world are

interested today

Impact on the organisation

• Sometimes, telling them that their job depends on it seems to have more impact than telling them their life depends on it……….

• Initial shock – – “He promised Wall Street what!?”– “You cannot be serious; How on earth can we do

that?”– “Its an opportunity?”

Recognition of the task for process Safety Expertise

• I have to find ways to meet the CEO’s promises• I must research technical solutions, cost and

benefit• Test• I have to work with my businesses on

implementation• I am responsible for success and failure

Question: How to develop understanding among Seveso II establishments that implementation of safety regulation contributes

to accident prevention and mitigation of consequences

• Structure of Seveso II Safety Report

For Industry….

– Mirrors the structure of existing industry best practice– Sets the standard for those who have no system– Provides a document describing the agreed system for

SMS, Risk Assessment Emergency Planning etc – all in one place

– Useful for self assessment and auditing

Question: How to develop understanding among Seveso II establishments that implementation of safety regulation contributes

to accident prevention and mitigation of consequences - CHALLENGES

• Regulator needs to apply technical competence to Seveso II implementation

• Member state Competent Authorities across E.U need to have consensus on requirements

• Regulator needs to explain National requirements in a clear way to establishments

• If not, technical interpretation and dialogue break down and poor quality Safety Report results

• If not, industry cannot understand why the same installation/process has to comply with different rules in different countries

• If not, safety cases will miss the target and be rejected

Need a study of what difference Seveso II has actually made -

• More than paper?

• ……………

Need a study of what difference Seveso II has actually made – What are its achievements?

Philosophy of Seveso II DirectivePhilosophy of Seveso II Directive

SafeManagement

Safe

Technology

Demonstrate safety

in the Safety Report

Philosophy of Seveso II DirectivePhilosophy of Seveso II Directive

SafeManagement

Safe

Technology

Demonstrate safety

in the Safety Report

Land-UsePlanning

EmergencyPlanning

Philosophy of Seveso II DirectivePhilosophy of Seveso II Directive

SafeManagement

Safe

Technology

Demonstrate safety

in the Safety Report

EmergencyPlanning

Land-UsePlanning

Info

rmat

ion

to th

e P

ubli

c

I N S P E C T I O N S

Actors in Seveso II DirectiveActors in Seveso II Directive

Operators Authorities

Public

Research

Education

Insurance

How to apply Land Use Planning for pipelines?

LUP Requirement:LUP Requirement: Appropriate distanceAppropriate distance between the source and the between the source and the receptors of risk (urban developments, sensitive areas,…)receptors of risk (urban developments, sensitive areas,…)

Example:Example:MZ OZ

Thickness of the pipelineProtection of pipeline from external interferenceexternal interference (major cause)Difficulties especially with existing settingsHarmonisation of L.U.P. practices ??????

Con

sulta

tion

dist

ance

Inne

r Z

one

Consideration of all credible scenarios for land use planning (Buncefield)

• Was the possibility of vapour cloud explosion overlooked?

• Large scale storage and pumping rate (600M3/hr) would have predicted a large event – even if limited to pool fire

• Was protection adequate – needed to control frequency to an order of 1E-05

Are concepts of Safeguards and Mitigation consistently understood among regulators?

Release

1a 1b 1c

1a 2a

3a 3b 3c

4a

Initiating Event 1

Initiating Event 2

Initiating Event 3

Initiating Event 4

Prevention Mitigation

No consequence

Consequence A

Consequence B

Consequence C

M1 M2LOPs / LODsLOPs / LODs

Example of Bow Tie

Are concepts of Safeguards and Mitigation consistently understood among regulators?

Safeguard and Barriers: layers of protection that will prevent an unsafe scenario from progressing regardless of the initiating event or the performance of another layer of protection. PREVENT the RELEASE e.g. Block Valve closes.

Mitigation: Apply after a release occurs and reduces the effect e.g. water sprays or containment

Promotion of the use of risk assessment in design and post design review

• Most large companies have formalised this– Have made them available via organisations like

CEFIC and EPSC

• Systems mostly use common, freely available tools:– HAZOP– Simple Gas dispersion, fire and explosion models– Endpoints with effect calculations bsed on

Emergency Response Planning Guidelines

An understanding of how safe is the design code

• Design codes are often industry driven and adopted by a wider range o stakeholders

• Design codes feature as Best Practice

• Care needed on how they are applied

Risk Assessments are uncertain. Predictive risk assessments are even more uncertain. How should one,

then understand precautionary principle in licensing?

• Define the ‘precautionary principle’• Are all risk assessments predictive?• Quantitative Risk Assessment has many

uncertainties and sensitivities• Does the data I have found apply to my case?• Check the case of IEC 61511 with Safety

Instrumented Systems specified for proven failure performance – is this approach able to reduce uncertainty?

Discussion/Conclusions and Calls to Action

• Risk Assessment in its predictive mode is not uncertain since it uses logical processes, however the knowledge used in the assessment is uncertain.

• Apply P.P. to Risk Assessment result and examine – critique data and assumptions used

• Inspectors must believe in the regulations they are required to enforce.• Protection of Critical Infrastructure is becoming a real challenge

– Integration – interdependency – domino effects – lack of fault tolerance – effects which cascade – starting small but growing in scale and severity.

• The challenge of complexity• Consultant services are an essential resource, particularly for SME's and for

some Competent Authorities• Remember that the Seveso Directive is more than just the Safety report. We

have become obsessed with the documentation and have not fully exploited whatever benefits it has.

• MARS database shows that there are still about 30 major accidents every year in establishments covered by Seveso II