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Major Hazard Facilities

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Presentation on theme: "Major Hazard Facilities"— Presentation transcript:

1 Major Hazard Facilities
Introduction to Safety Report

2 Some Abbreviations and Terms
AFAP - As far as practicable BPCS – Basic process control system Employer - Employer who has management control of the facility FTA – Fault tree analysis HAZOP – Hazard and operability study HSR - Health and safety representative LOPA – Layer of protection analysis MHF - Major hazard facility – as defined in the regulations MA - Major accident OHS -Occupational health & safety QRA – Quantitative Risk Assessment SMS - Safety management system

3 Topics Covered in This Presentation
Introduction Key principles and objectives of the MHF regulations Why is a Safety Report needed? What is the Safety Report? What must the Safety Report do? Main components of the Safety Report Hazard identification Safety assessment Risk controls Emergency response plans

4 Topics Covered in This Presentation
Demonstration (of adequacy) What else is in the safety report? MHF regulations versus process Sources of additional information Review and revise Conclusion Examples of major accidents

5 Introduction This 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 overview To be suitable for new MHF Employers Outline the reason for a safety report Overview of all parts of a safety report Show examples of major accidents

6 Key Principles of MHF Regulations
Focus on major hazards (catastrophic events i.e. typically high consequence and low frequency) Requires a proactive risk based approach Places the responsibility on the Employer Employer has to actively demonstrate safe operation Proactive risk based approach – in the past it has been prescriptive based. Places responsibility on Employer

7 Key Principles of MHF Regulations
Consultation with different parties required at all critical stages Facilitate culture change at major hazard facilities Regulator ‘peer review’, tied to a licence Addresses both on-site and off-site safety Employer is expected to work closely with employees to actively seek to improve safety at the facility.

8 Focus of MHF Regulations
Increasing risk Minor risks Very high risks should already be eliminated after risk assessment Relative Frequency of Occurrence OHS risks already regulated Focus of MHF Regulations is high consequence (catastrophic) but low frequency incidents Minor Risks – OHS OHS risks already regulated – Insurance, Fire protection Very high risks – high consequence, high frequency, failure likely MHF Focus Consequence Severity

9 Objective 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 occurring Reduce the consequences to health and safety and damage to property in the event of an MA occurring Focus in both areas – prevention of the MA and also mitigating consequences should it occur.

10 MHF Regulations Specific 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.

11 Why is a Safety Report Needed?
There is a need for specific control of major hazards due to: Changing scale and complexity of specific facilities Advances/changes in technology - unforeseen hazards Changing community perceptions Range of major accidents that have occurred Prescriptive approach has proven inappropriate These 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.

12 Why is a Safety Report Needed?
Some major accidents that have occurred Coode Island, Australia – storage terminal fire, August 1991, 0 dead, 0 injured Longford, Australia – explosion and fire, September 1998, 2 dead, led to the development of Victorian MHF legislation Entschede, Holland – fireworks factory explosion, May 2000, 21 dead, 1,000 injured Texas City, USA – fire and explosion, March 2005, 15 dead, over 170 injured Very large consequences: Coode Island - Community outrage even though no fatalities. Longford – no gas for 10 days in Victoria

13 Why is a Safety Report Needed?
Port Kembla Ethanol Tank Fire, NSW, Australia, 28th January 2004 Points 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)

14 Why is a Safety Report Needed?
This has led to Regulations where: The Employer knows what technical and human activities occur The Employer decides on the appropriate means of major hazard control for the facility, and prepares a Safety Report explaining this The Regulator assesses and audits performance adequacy against the safety report The 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.

15 Why 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.

16 What is the Safety Report?
The safety report must address all hazardous events that could result in MAs that pose serious danger or harm to: Persons The community Property The environment Must consider on site and off site impacts Harm to the environment Property damage

17 What 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 facility The types of safety studies undertaken The results obtained for such studies The management arrangements in place to 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 accidents Outline 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.

18 What is the Safety Report?
The Role of the Safety Report Regulatory 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.

19 What Must the Safety Report Do?
Document the state of safety arrangements for the facility Demonstrate to the satisfaction of the Commission, through content and supporting material, that: The employer knows what technical and human activities occur How activities are managed How safety will be managed in the event of an emergency

20 What 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. Review Monitor Safer Facility Risk 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

21 The Safety Report Should…
Reflect the facility safety culture Contain information about the facility and interaction with its surroundings Describe the systems used to achieve safety Identify, assess and show controls for potential major accidents Demonstrate ongoing consultation between the employer and workforce Be integrated into the Employers management systems rather than a collection of separate individual safety studies A 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.

22 Safety Report Timeline
Refer Guidance note for this information and further details. Key Points: Regulations in force on 15 Mar 2007 SRO required after 15 months (Jun 2008) Safety report by 24 months (Mar 2009) Refer Guidance Booklet 4 for this timeline

23 Main Components of a Safety Report
The main components of the safety report are: Facility description Risk assessment Hazard and MA identification Risk control measures Safety management system description Emergency response plan Demonstration of adequacy Control measures Safety Management System These topics will be covered in more detail over the next few slides Aspects 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.

24 Facility Description History Daily operations
Schedule 9 materials and their characteristics Demographic description Facility topography & meteorological data Simplified process flow diagrams Site layout drawings Location plans, surrounding facilities and sensitive neighbours Proposed changes This is typical content for the Facility description.

25 Risk Assessment Requirements
Hazard identification – for determining MAs Risk assessment studies – for determining controls Risk evaluation - for determining risk acceptability Recommendations and review – for continuous improvement Aspects of the risk assessment process are shown. First identify hazards and then which hazards may lead to potential major incidents Risk assessments for potential MAs – determine the control measures that need to be managed and maintained to control the risk of the MA Evaluate 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.

26 Hazard 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 Assessments Unit Technical Review Input (Specialist Review) Incident History (internal / external) Dangerous Goods Present and Material Properties Major Accident Event Grouping These 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.

27 Outcomes Causes Risk Assessment Hazards Controls Preventative Controls
The information for assessment can be presented as a bow-tie diagram Hazards Controls Preventative Controls Mitigative Controls MA Causes Outcomes Consequences This 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)

28 Example: Layer of Protection Analysis
Risk Assessment Example: Layer of Protection Analysis Analysing the safety measures and controls that are between an uncontrolled event and the worst potential consequence - risk reduction study Documented 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.

29 Risk 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.

30 Description of the Safety Management System
A comprehensive and integrated management system for all aspects of control measures adopted Documented and describes how compliance is to be achieved Site safety philosophy and how it is reflected in the SMS Safety policy and safety objectives Organisation and personnel responsible for the implementation and compliance with the SMS Major features/elements of the SMS SMS performance monitoring processes Consultative processes used to develop and implement the SMS The 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.

31 OH&S Management System Model – AS 4801
Overall vision, goals and commitment to improve Suitable, adequate, effective Changes needed? Opportunities to improve? Legal compliance Objectives and targets Implementation plans In many cases, an SMS framework will already exist If 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 cycle PLAN – DO - CHECK - ACT Resources Leadership responsibility Training and competency Consultation and communication Documentation Hazard identification, risk assessment and controls Emergency response Monitoring and measurement Incident investigation Records management Audits

32 Emergency Response Plans
Promote preparation Ensure necessary equipment is available Ensure personnel are trained and prepared to respond Identify communication methods Identify community resources Consultation with emergency services, local council & community Emergency 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.

33 Emergency Incident Scenario Plans
Analysis of the consequences of specific MA’s to determine fire fighting access and to identify affected areas Determination of firewater and foam requirements for extinguishing the fire and/or protecting affected equipment Available as a resource for training These 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.

34 Demonstration of Adequacy
The safety report must demonstrate that the Employer is achieving safe operation of the facility by : Use of adequate control measures Satisfactory management systems Each 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)

35 Demonstration of Adequacy of Control Measures
Controls linked to hazards and proportionate to risk Depth and breadth of control measures Performance indicators defined and performance monitored Risk has been reduced AFAP Standards, industry practices Decisions are documented and justifiable Improvement programs – past and future Controls are: Appropriate to the hazard Sufficient number A range of different types Effective at preventing or mitigating the hazard Monitored, maintained and improved More information is available in the Comcare guidance Booklet 3 (control measures).

36 Demonstration of Adequacy of SMS
Comprehensive and Integrated Performance standards for the control measures are defined Control measures are monitored and failures are addressed Adequate education and training is provided for employees Processes are provided for review and revision of control measures Sufficient resources are provided, responsibilities, accountabilities defined Planning, implementation and monitoring processes are provided for control measures and the system as a whole More 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.

37 What Else is in a Safety Report?
Detailed Risk Assessment Records Risk analysis of the hazards on site. E.g. LOPA FTA Risk matrix QRA Provides a more detailed analysis of causes/frequency/consequences/controls for each identified MA Assessment of off-site risk Comparison of risk reduction options Often provided a Appendices in the safety report. A summary of the risk assessment may be provided.

38 What Else is in a Safety Report?
Occupied Buildings Risk Assessment Analysis of the impact of MAs on occupied buildings Mainly risks (due to flame impingement, explosions, toxic gas) from other buildings/operations Important 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.

39 What Else is in a Safety Report?
Risk Assessment Procedures Details of all the hazard and risk assessment work documented in procedures and referenced Procedures provide step by step guidance on how the assessments were undertaken – enables corporate memory retention Consistency of approach for all assessments Justification for selection of risk assessment processes Resources/guidance for the conduct of future assessments Risk 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.

40 What Else is in a Safety Report?
Community Consultation Community consultation philosophy Summary of Safety Report information for community Community bulletins Community has to be made aware of what they are exposed to. EPA requires consultation with community.

41 What Else is in a Safety Report?
Recommendations and Improvements Identification of opportunities to reduce risk via risk assessments Recommendations are assessed and prioritised Recommendations from risk assessments Cost/benefit analysis may help to prioritise Feed into facility overall improvement plan => integration.

42 MHF Regulation vs. Suggested Process
Reg No. Regulation Process 9.43 Identify, in consultation with employees, all: Hazards that could cause or contribute to causing a potential Major Accident Potential Major Accidents Hazard identification workshop using What If / HAZOP, checklists or other suitable methods 9.44 The Employer, in consultation with employees, must ensure that any risks associated with the hazards or potential major accidents are assessed Risk 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.

43 MHF Regulation vs. Suggested Process
Reg No. Regulation Process 9.45 The 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

44 Review & Revision Employers must review (and revise) the safety report for an MHF to ensure risks remain reduced AFAP: Prior to modification When new information becomes available regarding possible MA hazards previously unknown Upon licence renewal conditions or at least every 5 years At the direction of the Commission After a major accident

45 Conclusion The safety report must demonstrate adequacy of all Safety Duties required by the MHF regulations Safety Duties are ongoing requirements An 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.

46 Sources of Additional Information
Part 9 of the Occupational Health and Safety (Safety Standards) Regulations 1994 Major Hazard Facility Guidance Material – Comcare website WorkSafe Victoria NSW Major Industry Hazard Advisory Papers 1 to 9 Centre for Chemical Process Safety UK Health and Safety Executive,

47 Questions?

48 Publicly 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)

49 Buncefield 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, Hertfordshire At least one of the initial explosions was of massive proportions and there was a large fire, which engulfed a high proportion of the site Over 40 people were injured; fortunately there were no fatalities

50 Buncefield Incident Off-Site Consequences
“Significant damage” to commercial and residential neighbours 2000 people evacuated Sections of M1 Motorway closed Very large smoke plume over Southern England → Air pollution Large quantities of foam and water → contaminated water courses and ground water

51 Buncefield Incident HSE/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-site First explosion at hours There were multiple root causes (failures) identified Many related to management system failures Still some unanswered questions Why was there so much explosive force?

52 Buncefield Fuel Storage – before incident

53 Buncefield – during the incident

54 Buncefield – after the incident
We’ll follow the Buncefield incident in later seminars.

55 Dubai 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“.

56 Dubai 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.

57 Dubai Dry Dock Incident
Everything looks normal!!

58 Dubai Dry Dock Incident
Moments after the first breach at 09:30 on

59 Dubai Dry Dock Incident
Larger vessels coming off the blocks

60 Dubai Dry Dock Incident
Cargo barge getting ready to roll. Many trapped inside, a few on deck getting ready to jump

61 Dubai Dry Dock Incident
“KEY BERMUDA” coming off blocks. “INDRA-1” swinging towards rig

62 Dubai Dry Dock Incident
Accommodation barge “SEP 350” sinking

63 Dubai Dry Dock Incident
“SEP 350” touching bottom

64 Dubai Dry Dock Incident
The aftermath. Official reports account for 26 persons killed.

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