Storing & handling hazardous substances – How do you do?
Dr Julian Hought examines the results of a recent exercise to benchmark process safety management performance across a range of high-hazard chemicals and processing sites, emphasising where more work needs to be done to bring about further improvement in the sector.
Process safety management (PSM) is a hot topic for the Health and Safety Executive in terms of its regulation of high-hazard sites but, in general, industry’s approach to it has been very disjointed. Consequently, a benchmarking programme1 was recently carried out to determine commonality among chemical-manufacturing and processing sites and help them strike a practical balance between aspirations, standards and reality.
As PSM is such a wide-ranging topic, the focus of the exercise was on asset integrity management – a critical risk-control system in the prevention of major accidents. Routine inspections are vital – never more so than in the current climate, when companies are exerting increasing pressure on existing equipment to deliver competitively-priced products.
In all, 12 complex manufacturing sites – ranging from multinational plcs to specialist SMEs – participated in the programme. All are regulated under COMAH and, with one exception, are designated top-tier sites. This gave a broad range in terms of organisation and complexity, as well as a fair representation of the chemicals industry as a whole.
Overall, the results of the benchmarking programme were broadly in line with expectations, in that the exercise supported the belief that there are some excellent examples of world-class performance to be found in terms of asset integrity management, which is extremely encouraging. It was also clear that the technical aspects of PSM scored most highly. For example, considering the results against the HSE’s POPMAR model,2 the Organisation, Planning & Implementation, and Monitoring aspects attained the highest scores. This indicates that operators are doing what needs to be done in practice and, in many cases, are doing it very well.
Conversely, the Policy, Audit and Review aspects relating to leadership and administration were much weaker, emphasising a reliance on engineers at the coalface – they are expected to know what needs to be done and to get on with it. This can cause significant problems – for example, if the company’s policy on identifying critical equipment is unclear or ambiguous, then some items of equipment may be overlooked. But a leak from even a small-bore pipe can be a problem if it contains a very toxic/liquefied gas.
Insufficient knowledge and experience of degradation mechanisms can also lead to flawed inspection procedures, meaning weak points could be missed.
This lack of attention to detail in high-level policies covering asset integrity must be addressed if senior managers are to remain confident of meeting business needs. One solution is policy deployment – an established methodology designed to harness the collective ability of all employees in an organisation to make it the best in its field. Widely used in the world of business improvement, it provides a structured approach to plan, monitor and control team and individual involvement in the achievement of company targets and objectives. It also fits nicely with the aforementioned POPMAR model by allowing individuals at any level in a business to see what activities are being carried out to meet the strategic plans for the company and view progress against a set of KPIs/measures.
Interestingly, but perhaps not surprisingly, the scores across all companies were higher in those areas where more prescriptive legislation exists, such as compliance with the Pressure Systems Safety Regulations. Critical risk-control systems around safety instrumented systems were also well understood and managed, again because of the existence of clear and structured guidance, and a continued push from the regulator.
However, performance tailed off, to differing degrees, for lower-risk non-codal systems. For example, greater opportunities for improvement were to be found in the inspection and testing of secondary and tertiary containment systems, and medium and lower-risk process systems. The control of maintenance spares in relation to critical systems was also highlighted.
The impetus to improve performance in non-codal areas must come through leadership in individual companies if they are to avoid falling into the reactive compliance trap. Self-regulation, led from the top, gives sites greater clarity on what needs to be done, where and when, in accordance with budgets.
Systems approach is key
If an asset integrity programme is to be sustainable and focused, a systems approach to inspection must be adopted. While many of the companies participating in the benchmarking programme believed they were already doing this, it became evident during the assessments that, in the majority of cases, this only applied to high-risk systems. Elements such as piping, structures and secondary/tertiary containment systems were often excluded.
As a rule, even basic schemes of examination should be put together using the following steps:
- Register – if you don’t know what you have, how can you inspect it?
- Categorise – the consequences of failure are not the same for all systems;
- Assess – understand how, where and when failures are likely to occur;
- Document – record the outcomes of assessments in a structured way;
- Inspect – you need to inspect things correctly, at the correct place, and in the correct way.
As a minimum, an examination scheme should list all of the components within the system. It should state which parts of the system are to be examined and which are not. The type of examination required should also be specified, and reference should be made to relevant procedures, including inspection and testing to be carried out on any protective devices. Finally, the minimum frequency of examinations should be fixed.
More complex schemes may also need to address the preparatory work needed for the plant items to be examined; any special requirements relating to the remnant life of equipment; modified inspection frequencies based on PHA and history; etc.
Inspection of structures was also highlighted, specifically the way in which items such as handrails, flooring, hangers and drains should be evaluated as part of a structural survey. Redundant structures should also form part of the same survey, especially where failure could be a precursor to a major accident. The process pipework may be good but if the supports fail, a loss of containment could still occur.
Perhaps the simplest form of inspection is regular ‘eyes on’ checks, which can identify many issues at an early stage before they are allowed to escalate into a catastrophic failure. For example, you don’t need expensive thermographic surveys to identify poor insulation – if you have weeds growing out of lagging, it’s a good indication that you have water-ingress issues!
In terms of procedures, companies generally scored more highly in design, inspection, mechanical, and C&I maintenance, with management of change and failure reporting scoring particularly well in most cases. However, room for improvement was identified with regard to identification of critical equipment and assessment of degradation mechanisms.
Feedback from the companies involved suggests that this PSM benchmarking programme has been highly beneficial, in that it has given them the opportunity to learn from experts within the sector, share experiences and work together for a common cause, i.e. improved process safety within their industry. This enthusiasm means future benchmarking activity, looking at other PSM elements, is being planned to continue the programme of work and build on its findings.3
1 Launched in November 2010 and culminating in February 2011, the programme was led by HFL Risk Services and supported by the Chemical Industries Association, the HSE and the National Skills Academy for the Process Industries
2 Policy, Organising, Planning, Measuring, Auditing, Reviewing – as outlined in the HSE’s guidance HSG 65 Successful health and safety management – www.hse.gov.uk/pubns/priced/hsg65.pdf
3 Relevant companies interested in taking part in future exercises can e-mail the author – [email protected]
Dr Julian Hought is managing director of HFL Risk Services.
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