DEKRA

news COMAH article

By Eddie McCullough, Senior Vice President at DEKRA Organisational Reliability Ltd.

Piper Alpha was the event which lead to the oil and gas industry reassessing its approach to safety. Even with new standards and an increased awareness of what causes large process safety events like these, almost 30 years on from one of the biggest disasters the industry has experienced, we continue to see large and fatal disasters occurring: Texas City, Buncefield and Richmond refinery to name a few.

However, it is not only the oil and gas industry which is at risk of high consequence, low probability events such as these. Any industry where quantities of dangerous substances meet the threshold outlined in the Control of Major Accident Hazards (COMAH) Regulations are also at risk, including chemical, storage, explosives and nuclear sites. Distilleries are another industry at risk of a process safety event and some are even classed as top tier sites. Large events at distilleries have occurred, some within the last few years, suggesting a focus on process safety is required within this industry as well. The Burghead Malting Fire in Elgin (Scotland) in 2015, Cheapside Whisky Bond in Glasgow (Scotland) in 1960, and Silver Trail in Kentucky in 2015 are only a few distilleries to have experienced a major event.

Although the number of large events like those mentioned above occur less frequently these days, they still happen. In 2016, the International Association of Oil and Gas Producers (OGP) published their annual Safety Performance Indicators report which outlined the number and causes of process safety events in 2015 as reported by participating oil and gas organisations themselves. They reported 254 (rate 0.14) Tier 1 events (loss of primary containment (LOPC) with the greatest consequences) and 795 (rate 0.44) Tier 2 events (LOPC with lesser consequences). OGP also reported onshore Tier 1 process safety event rate (PSER) to be around 2.5 times the offshore Tier 1 PSER, and onshore Tier 2 PSER to be 1.6 times the offshore Tier 2 PSER.

High hazard industries, now more than ever, need to pay attention to not only their safety performance but also their process safety performance if they are to avoid experiencing the worst case scenario. It is important that high hazard industries such as COMAH sites operationalise their COMAH plan or process safety plan and ensure they are paying attention to even the weakest signals which may indicate the potential for an accident to occur.

However, the question is what can organisations do to prevent events like this from happening? The key to this is focusing on behaviours and decision making. Our experience has taught us that organisations tend to have all the systems and processes in place however how people interact with or use these systems opens the organisation up to the potential of a major event occurring. What influences a person’s behaviour and how they make decisions is the culture they work in. Specifically, the organisation’s safety culture; that is how much an organisation cares about their safety performance over their financial or operational performance and who within the organisation takes responsibility for safety.

There are specific concepts around behavioural safety that have been shown to make a real difference in improving a company’s safety culture. The most effective way to influence an organisation’s safety culture is by generating an input of care. When we talk about care we aren’t talking about hugs and kisses, we are talking about feeling concerned or interested for something. Explicitly, we are talking about caring for people, the systems and processes, the plant and equipment. This care can be demonstrated in many different forms such as by asking your team “can we do anything more”, or simply by following processes, rules and procedures, or even by maintaining your equipment and plant to ensure they are working effectively. If care is demonstrated in these areas, an organisation is likely to see an increase in their safety performance. Furthermore, with the creation of a culture of care, an organisation is also likely to see an improvement in their operational performance, the predictability of the performance of their people as well as their plant and equipment, and the efficiency in the way people and the organisation function, which itself can lead to a financial return.

Throughout our experience and research, and working with various high hazard industries including oil and gas, petrochemical, construction, mining, steel etc, the importance of process safety management has become apparent. Furthermore, as an organisation that is continually learning from our experience and the continuous research we do, we have noticed an increased focus on process safety wherever we go. As a result of this we have incorporated the creation of a process safety culture into how we create a culture of care.

Even with this increased attention being paid to process safety, one thing we have noticed is a lack of attention to the weak signals and warning signs which indicate the potential for danger. Through our in-field work and training workshops, we have discovered barrier defects in existence almost everywhere we go. For example, inhibits being put on fire and gas detection systems to allow work to be performed in that area without setting it off however these are not removed upon the completion of work meaning this barrier to detect something bad happening would be ineffective when it is needed. Furthermore, the level of knowledge that leadership and the workforce have in regards to process safety and the barriers to prevent a process safety event occurring is generally low. On a regular basis we often observe a mention of “pay attention to process safety hazards” from leaders to the workforce, however, this is not expanded upon to specify exactly what hazards people should be paying attention to. Combined with a low level of knowledge in regards to process safety hazards, it begs the question, is saying “pay attention” enough to prevent something bad from happening? Do people know what to pay attention to? If people aren’t aware of what process safety is, the barriers their organisation has in place or need in place to prevent something bad from happening and, more specifically the role they play in managing process safety, the prevention of a major incident will be difficult for any organisation. It is therefore essential everyone, from the CEO to front line supervisors to the person on the tools, know and understand process safety management, and more importantly, their role in preventing accidents from happening.

With our experience and learning, we believe there is a necessity to raise awareness to high hazard industries including COMAH sites of the need to focus on their process safety management to prevent something bad from happening. It is important organisations who are at the greatest risk of a process safety event understand how they can operationalise their COMAH plan or process safety plan, that is how they can bring to life what is written on paper to prevent the worst case scenario happening.

Lives are precious and it is up to an organisation, specifically the senior leaders within it, to take responsibility to take care of those lives. Research shows that humans are heavily influenced by the culture they work in when they make decisions, if this culture does not see safety as a priority, how decisions get made and how people behave will reflect this. This means an organisations culture is crucial to keep people safe and by creating a culture of care, everyone can do the right thing.