Presentation on theme: "Major Hazard Facilities"— Presentation transcript:
1Major Hazard Facilities Introduction to Safety Report
2Some Abbreviations and Terms AFAP - As far as practicableBPCS – Basic process control systemEmployer - Employer who has management control of the facilityFTA – Fault tree analysisHAZOP – Hazard and operability studyHSR - Health and safety representativeLOPA – Layer of protection analysisMHF - Major hazard facility – as defined in the regulationsMA - Major accidentOHS -Occupational health & safetyQRA – Quantitative Risk AssessmentSMS - Safety management system
3Topics Covered in This Presentation IntroductionKey principles and objectives of the MHF regulationsWhy is a Safety Report needed?What is the Safety Report?What must the Safety Report do?Main components of the Safety ReportHazard identificationSafety assessmentRisk controlsEmergency response plans
4Topics Covered in This Presentation Demonstration (of adequacy)What else is in the safety report?MHF regulations versus processSources of additional informationReview and reviseConclusionExamples of major accidents
5IntroductionThis seminar is a basic introduction to the Safety Report that is required under the MHF Regulations.It has been developed for the following purposes:To provide a simple overviewTo be suitable for new MHF EmployersOutline the reason for a safety reportOverview of all parts of a safety reportShow examples of major accidents
6Key Principles of MHF Regulations Focus on major hazards (catastrophic events i.e. typically high consequence and low frequency)Requires a proactive risk based approachPlaces the responsibility on the EmployerEmployer has to actively demonstrate safe operationProactive risk based approach – in the past it has been prescriptive based.Places responsibility on Employer
7Key Principles of MHF Regulations Consultation with different parties required at all critical stagesFacilitate culture change at major hazard facilitiesRegulator ‘peer review’, tied to a licenceAddresses both on-site and off-site safetyEmployer is expected to work closely with employees to actively seek to improve safety at the facility.
8Focus of MHF Regulations Increasing riskMinorrisksVery high risksshould alreadybe eliminatedafter riskassessmentRelative Frequency of OccurrenceOHS risksalreadyregulatedFocus of MHF Regulations ishigh consequence (catastrophic)but low frequency incidentsMinor Risks – OHSOHS risks already regulated – Insurance, Fire protectionVery high risks – high consequence, high frequency, failure likelyMHF FocusConsequence Severity
9Objective of the MHF Regulations The objective of the MHF Regulations is to provide for the safe operation of major hazard facilities to:Reduce the likelihood of an MA occurringReduce the consequences to health and safety and damage to property in the event of an MA occurringFocus in both areas – prevention of the MA and also mitigating consequences should it occur.
10MHF RegulationsSpecific parts of the MHF Regulations relevant for this seminar are:Hazard identification (9.43)Risk assessment (9.44)Risk control measures (9.45)Safety management system (9.46)Emergency planning (9.53)Provision of information to the community (9.50)These sections of the Regulations are covered in this presentation.
11Why is a Safety Report Needed? There is a need for specific control of major hazards due to:Changing scale and complexity of specific facilitiesAdvances/changes in technology - unforeseen hazardsChanging community perceptionsRange of major accidents that have occurredPrescriptive approach has proven inappropriateThese are some of the reasons why a safety report regime will be more effective than a prescriptive regulations approach.Changing scale & complexity of facilities –Old photo’s of industrial areas usually show no houses in vicinity. Now houses are on the boundary. Consequences can impact neighbouring facilities.No distinction drawn between employees & neighbours.Larger, more complex facilities mean more areas where things can go wrong.Changing community perceptions –Neighbour proximity has changed community expectations and perceptions about industry.
12Why is a Safety Report Needed? Some major accidents that have occurredCoode Island, Australia – storage terminal fire, August 1991, 0 dead, 0 injuredLongford, Australia – explosion and fire, September 1998, 2 dead, led to the development of Victorian MHF legislationEntschede, Holland – fireworks factory explosion, May 2000, 21 dead, 1,000 injuredTexas City, USA – fire and explosion, March 2005, 15 dead, over 170 injuredVery large consequences:Coode Island - Community outrage even though no fatalities.Longford – no gas for 10 days in Victoria
13Why is a Safety Report Needed? Port Kembla Ethanol Tank Fire, NSW, Australia, 28th January 2004Points to failures in the management systems in place at the site.Quote from the Coroner…“not a lack of adequate safety procedures but rather the failure to adhere to them”.(Welding was carried out in an unsuitable area without a ‘hot work’ permit)
14Why is a Safety Report Needed? This has led to Regulations where:The Employer knows what technical and human activities occurThe Employer decides on the appropriate means of major hazard control for the facility, and prepares a Safety Report explaining thisThe Regulator assesses and audits performance adequacy against the safety reportThe range of industries and complex technologies means that prescriptive style regulations (eg. specify controls) cannot work effectively. The regulations are based around general risk management processes.
15Why is a Safety Report Needed? The introduction of regulations were ‘fast tracked’ in Victoria primarily as a result of the Royal Commission into the incident at Longford in 1998.The Victorian MHF regime is now mature and is working well.Historical major accidents have often resulted in regulatory change.The Longford accident is an example which triggered vast change to the major hazards regime in Victoria. The Victorian model is now mature and proving to be very successful.
16What is the Safety Report? The safety report must address all hazardous events that could result in MAs that pose serious danger or harm to:PersonsThe communityPropertyThe environmentMust consider on site and off site impactsHarm to the environmentProperty damage
17What is the Safety Report? A safety report is a detailed document that outlines:The identification and control mechanisms in place to prevent and mitigate all MAs for the facilityThe types of safety studies undertakenThe results obtained for such studiesThe management arrangements in placeto ensure the continued safety of the facility and its people and the surrounding community.The safety report must be prepared in consultation with employees and be a true reflection of the state of the safety arrangements for the facility.Should contain all the information needed to show that the facility can be operated safely.Focus on control measures that prevent or mitigate major accidentsOutline of the safety management systems at the site to ensure the control measures are properly managed.Consultation is a key aspect of the MHF regulations.
18What is the Safety Report? The Role of the Safety ReportRegulatory role: The primary document used by an approved assessor to verify that the facility is operated safely to support the Employer’s licence application.Information Repository: Contains all information about the safe operation of the facility which contributes to continuous improvement of safety at the facility.The safety report will be the key document used by the assessor to determine compliance with the MHF regulations.
19What Must the Safety Report Do? Document the state of safety arrangements for the facilityDemonstrate to the satisfaction of the Commission, through content and supporting material, that:The employer knows what technical and human activities occurHow activities are managedHow safety will be managed in the event of an emergency
20What Must the Safety Report Do? Identify methods to be used for monitoring and reviewing all activities for continual improvement of the safety arrangements of the facility over its lifetime.ReviewMonitorSaferFacilityRisk assessments done just to get approval for a new facility (“tick the box”) then ignored – often leads to failure.If it becomes a living, breathing management document that is integrated with day-to-day management – usually leads to success.Systems need to be in place to monitor and review how well the safety arrangements and controls are working and to implement improvements.Improve
21The Safety Report Should… Reflect the facility safety cultureContain information about the facility and interaction with its surroundingsDescribe the systems used to achieve safetyIdentify, assess and show controls for potential major accidentsDemonstrate ongoing consultation between the employer and workforceBe integrated into the Employers management systems rather than a collection of separate individual safety studiesA safety report that imposes processes or methods that are not part of the regular approach used for safety management at the site will be difficult to maintain into the future.‘Workforce’ includes contractors. Consultation needs to happen through Safety Report preparation, implementation and monitoring phases.The safety report should be well integrated into the wider management systems of the facility rather than a stand-alone study.
22Safety Report Timeline Refer Guidance note for this information and further details.Key Points:Regulations in force on 15 Mar 2007SRO required after 15 months (Jun 2008)Safety report by 24 months (Mar 2009)Refer Guidance Booklet 4 for this timeline
23Main Components of a Safety Report The main components of the safety report are:Facility descriptionRisk assessmentHazard and MA identificationRisk control measuresSafety management system descriptionEmergency response planDemonstration of adequacyControl measuresSafety Management SystemThese topics will be covered in more detail over the next few slidesAspects of demonstration:Safety controls – are there enough, can they be proved to be working.Safety management system – auditing to show that it is working effectively.
24Facility Description History Daily operations Schedule 9 materials and their characteristicsDemographic descriptionFacility topography & meteorological dataSimplified process flow diagramsSite layout drawingsLocation plans, surrounding facilities and sensitive neighboursProposed changesThis is typical content for the Facility description.
25Risk Assessment Requirements Hazard identification – for determining MAsRisk assessment studies – for determining controlsRisk evaluation - for determining risk acceptabilityRecommendations and review – for continuous improvementAspects of the risk assessment process are shown.First identify hazards and then which hazards may lead to potential major incidentsRisk assessments for potential MAs – determine the control measures that need to be managed and maintained to control the risk of the MAEvaluate the risk vs risk tolerance criteria – can the risk with controls in place be accepted? Standard off site risk tolerance criteria are available. Tolerance criteria for on site risk need to be developed company by company – more on this follows.Improvements will flow for the risk assessment to improve the effectiveness of existing controls or implement new controls to further reduce the risk.
26Hazard and MA Identification Hazards that can lead to major accidents are identified. From these, MA scenarios can be developed for further analysis.Process Hazard Studies(HAZOP/What If)Past Risk AssessmentsUnit Technical Review Input(Specialist Review)Incident History (internal / external)Dangerous Goods Present and Material PropertiesMajor Accident EventGroupingThese are just examples of the data sources for hazard identification. In most cases, hazard identification workshops will be needed to ensure the appropriate range of depth of experience is available.HAZID will be covered in detail in a later session.
27Outcomes Causes Risk Assessment Hazards Controls Preventative Controls The information for assessment can be presented as a bow-tie diagramHazardsControlsPreventative ControlsMitigative ControlsMACausesOutcomesConsequencesThis is a bowtie diagram which is a very useful tool to visually link controls to hazards.It is useful for training and communication.Helps show adequacy of controls (ie..all hazards have more than one control, different types etc)
28Example: Layer of Protection Analysis Risk AssessmentExample: Layer of Protection AnalysisAnalysing the safety measures and controls that are between an uncontrolled event and the worst potential consequence - risk reduction studyDocumented risk assessment technique (Centre for Chemical Process Safety – USA)This method requires a selection of controls from the different layers of the ‘onion’.Requires more than one control. Requires different types of controls (engineering, administrative)Most suited to process industries.
29Risk Assessment Example Risk Matrix For higher consequence events, the event likelihood must be driven lower (by having sufficient number of effective controls) for the risk to be at an acceptable level.These are defined by the company. The likelihood shown is just an example.
30Description of the Safety Management System A comprehensive and integrated management system for all aspects of control measures adoptedDocumented and describes how compliance is to be achievedSite safety philosophy and how it is reflected in the SMSSafety policy and safety objectivesOrganisation and personnel responsible for the implementation and compliance with the SMSMajor features/elements of the SMSSMS performance monitoring processesConsultative processes used to develop and implement the SMSThe description of the SMS is required for the safety report.These are some of the topics that would be expected to be covered in the SMS summary.More information will be provided in the SMS seminar later today.
31OH&S Management System Model – AS 4801 Overall vision, goals and commitment to improveSuitable, adequate, effectiveChanges needed?Opportunities to improve?Legal complianceObjectives and targetsImplementation plansIn many cases, an SMS framework will already existIf developing an SMS from scratch or looking to restructure an existing SMS, existing SMS models are a good starting point.A commonly used ‘standard’ on which to base a safety management system is the AS 4801 model.Major elements of the model are shown. The process is broken into the commonly referred to steps in the management cyclePLAN – DO - CHECK - ACTResourcesLeadership responsibilityTraining and competencyConsultation and communicationDocumentationHazard identification, risk assessment and controlsEmergency responseMonitoring and measurementIncident investigationRecords managementAudits
32Emergency Response Plans Promote preparationEnsure necessary equipment is availableEnsure personnel are trained and prepared to respondIdentify communication methodsIdentify community resourcesConsultation with emergency services, local council & communityEmergency response plans are control measures and need to be evaluated accordingly.The key aspects of the emergency response plan are listed.More information will be provided in a later seminar.
33Emergency Incident Scenario Plans Analysis of the consequences of specific MA’s to determine fire fighting access and to identify affected areasDetermination of firewater and foam requirements for extinguishing the fire and/or protecting affected equipmentAvailable as a resource for trainingThese are specific plans/procedures for an individual MA.Provides additional information specific to the MA such as fire hydrant locations, heat contours (for fire fighting), evacuation routes etc.These are tested in emergency exercises and valuable for training.
34Demonstration of Adequacy The safety report must demonstrate that the Employer is achieving safe operation of the facility by :Use of adequate control measuresSatisfactory management systemsEach of these is dealt with.The SMS must ensure the control measures are being adequately managed and also ensure the SMS itself is working effectively (i.e.. through auditing programs)
35Demonstration of Adequacy of Control Measures Controls linked to hazards and proportionate to riskDepth and breadth of control measuresPerformance indicators defined and performance monitoredRisk has been reduced AFAPStandards, industry practicesDecisions are documented and justifiableImprovement programs – past and futureControls are:Appropriate to the hazardSufficient numberA range of different typesEffective at preventing or mitigating the hazardMonitored, maintained and improvedMore information is available in the Comcare guidance Booklet 3 (control measures).
36Demonstration of Adequacy of SMS Comprehensive and IntegratedPerformance standards for the control measures are definedControl measures are monitored and failures are addressedAdequate education and training is provided for employeesProcesses are provided for review and revision of control measuresSufficient resources are provided, responsibilities, accountabilities definedPlanning, implementation and monitoring processes are provided for control measures and the system as a wholeMore information is available in Booklet 3 (SMS)Does the SMS adequately manage the control measures such that it can be demonstrated that they are properly identified, implemented, effective and improved.Does the SMS ensure that the SMS itself is working effectively through defining audit programs and continuous improvement.These are a few of the important check points to ensure that the SMS is working effectively.
37What Else is in a Safety Report? Detailed Risk Assessment RecordsRisk analysis of the hazards on site. E.g.LOPAFTARisk matrixQRAProvides a more detailed analysis of causes/frequency/consequences/controls for each identified MAAssessment of off-site riskComparison of risk reduction optionsOften provided a Appendices in the safety report. A summary of the risk assessment may be provided.
38What Else is in a Safety Report? Occupied Buildings Risk AssessmentAnalysis of the impact of MAs on occupied buildingsMainly risks (due to flame impingement, explosions, toxic gas) from other buildings/operationsImportant where buildings are subject to MA impact because of the likelihood of high exposure of people.Appropriate building design is an important factor.Likely to be an important analysis for explosions.
39What Else is in a Safety Report? Risk Assessment ProceduresDetails of all the hazard and risk assessment work documented in procedures and referencedProcedures provide step by step guidance on how the assessments were undertaken – enables corporate memory retentionConsistency of approach for all assessmentsJustification for selection of risk assessment processesResources/guidance for the conduct of future assessmentsRisk assessment procedures are usually defined in an element of the SMS to ensure a consistent approach both during the safety report development and then into the future.
40What Else is in a Safety Report? Community ConsultationCommunity consultation philosophySummary of Safety Report information for communityCommunity bulletinsCommunity has to be made aware of what they are exposed to.EPA requires consultation with community.
41What Else is in a Safety Report? Recommendations and ImprovementsIdentification of opportunities to reduce risk via risk assessmentsRecommendations are assessed and prioritisedRecommendations from risk assessmentsCost/benefit analysis may help to prioritiseFeed into facility overall improvement plan => integration.
42MHF Regulation vs. Suggested Process Reg No.RegulationProcess9.43Identify, in consultation with employees, all:Hazards that could cause or contribute to causing a potential Major AccidentPotential Major AccidentsHazard identification workshop using What If / HAZOP, checklists or other suitable methods9.44The Employer, in consultation with employees, must ensure that any risks associated with the hazards or potential major accidents are assessedRisk assessment workshop using structured risk assessment process (for example fault tree analysis or LOPA)No definitive view on what process should be used. The Employer decides.
43MHF Regulation vs. Suggested Process Reg No.RegulationProcess9.45The Employer, in consultation with employees, must adopt control measures that eliminate or reduce as far as practicable the risk to health and safety. This relates to both the likelihood of the potential Major Accident and the severity of the consequences.Risk assessment workshop using suitable risk assessment process and risk register.Workshops are an excellent tool to demonstrate involvement of employees and HSRs
44Review & RevisionEmployers must review (and revise) the safety report for an MHF to ensure risks remain reduced AFAP:Prior to modificationWhen new information becomes available regarding possible MA hazards previously unknownUpon licence renewal conditions or at least every 5 yearsAt the direction of the CommissionAfter a major accident
45ConclusionThe safety report must demonstrate adequacy of all Safety Duties required by the MHF regulationsSafety Duties are ongoing requirementsAn Employer at a MHF who fails to comply with the MHF regulations may be subject to civil proceedings or criminal prosecution under the OHS Act.Employers may go to jail.
46Sources of Additional Information Part 9 of the Occupational Health and Safety (Safety Standards) Regulations 1994Major Hazard Facility Guidance Material – Comcare websiteWorkSafe VictoriaNSW Major Industry Hazard Advisory Papers 1 to 9Centre for Chemical Process SafetyUK Health and Safety Executive,
48Publicly Available Data/Incidents Several examples of incidents are available. These include:Tosco Avon refinery fire incident, Martinez California, 23rd February 1999 (source: U.S. Chemical Safety and Hazard Investigation Board, Report No CA, issue date March 200)Buncefield fire, December 2005 (source: UK HSE)Dubai Dry Dock Incident (source: Web site, US Naval Sea Systems Command)
49Buncefield Incident (UK) – December 2005. In the early hours of Sunday 11 December 2005, a number of explosions occurred at Buncefield Oil Storage Depot, Hemel Hempstead, HertfordshireAt least one of the initial explosions was of massive proportions and there was a large fire, which engulfed a high proportion of the siteOver 40 people were injured; fortunately there were no fatalities
50Buncefield Incident Off-Site Consequences “Significant damage” to commercial and residential neighbours2000 people evacuatedSections of M1 Motorway closedVery large smoke plume over Southern England → Air pollutionLarge quantities of foam and water → contaminated water courses and ground water
51Buncefield IncidentHSE/EA investigation determined the direct cause (initiating event) as follows:“Tank 912 ……. overflowed at around hours …….. while being filled at a high rate”Large vapour cloud formed and flowed off-siteFirst explosion at hoursThere were multiple root causes (failures) identifiedMany related to management system failuresStill some unanswered questionsWhy was there so much explosive force?
54Buncefield – after the incident We’ll follow the Buncefield incident in later seminars.
55Dubai Dry Dock Incident On 27 March, 2002 in Dubai there was a breach and failure in one of the dock gates that caused uncontrolled flooding in the dry dock.Several vessels were set on blocks inside the dry dock at the time of the failure. The vessels included the large vessel "Key Burmuda," a cargo barge and the accommodation barge "SEP 350“.
56Dubai Dry Dock Incident The dry dock gates failed at during a working day.The dock is 500 metres long by 100 metres wide and 11 metres deep.
57Dubai Dry Dock Incident Everything looks normal!!
58Dubai Dry Dock Incident Moments after the first breach at 09:30 on
59Dubai Dry Dock Incident Larger vessels coming off the blocks
60Dubai Dry Dock Incident Cargo barge getting ready to roll. Many trapped inside, a few on deck getting ready to jump
61Dubai Dry Dock Incident “KEY BERMUDA” coming off blocks. “INDRA-1”swinging towards rig
62Dubai Dry Dock Incident Accommodation barge “SEP 350” sinking
63Dubai Dry Dock Incident “SEP 350” touching bottom
64Dubai Dry Dock Incident The aftermath. Official reports account for 26persons killed.