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Safety management
The document provides an overview of safety management systems (SMS) for major hazard facilities. It discusses key elements of an SMS including policy, planning, implementation, assessment, and management review. An effective SMS ensures all work is conducted safely through comprehensive and integrated systems. It also recognizes potential errors and establishes robust controls. The importance of SMS is highlighted by past incidents where inadequate management systems contributed to accidents. Performance measurement and continual improvement are important aspects of an SMS.
Safety management
- 1. Major Hazard Facilities SafetyManagement Systems
- 2. 2 Overview The seminar hasbeen developed to provide: • Context with MHF Regulations • An overview of what is required • An understanding of the SMS and why it is important
- 3. 3 • AFAP -As far as (reasonably) practicable • Employer - Employer who has management control of the facility • ER or ERP - Emergency response or Emergency response plan • Facility - any building or structure at which Schedule 9 materials are present or likely to be present for any purpose • HAZID - Hazard identification • HSR - Health and safety representative • LOC - Loss of containment • LOPA – Layers of protection analysis • MA - Major accident • MHF - Major hazard facility • MOC – Management of change • OHS - Occupational health & safety • SR - Safety report • SMS - Safety management system Some Abbreviations & Terms
- 4. 4 Topics covered inThis Presentation • Introduction • Regulations • What is a safety management system? • SMS models and standards • Key elements of the SMS • The importance of SMS • What should the SMS do? • Measurement of performance • Examples of SMS performance standards • Emergency planning • SMS testing • Items to note • Critical success factors • Sources of additional information
- 5. 5 Regulations Occupational Health andSafety (Safety Standards) Regulations 1994
- 6. 6 What is aSafety Management System? • An SMS is a comprehensive and integrated system that ensures that all work at the facility is conducted safely • It should be fully documented, accessible and comprehensible to those that need to use it • It recognises the potential for errors and establishes robust defences (control measures) which are fully implemented, to ensure that errors do not result in accidents or near misses • It is comprises a set of work practices and procedures for monitoring and improving the safety and health of all aspects of the operation
- 7. 7 Key Terms Usedin Describing the SMS Comprehensive • Describes the way that all safety issues including control measures are managed • Clear link between controls management and the SMS Integrated • The structure is logical, systematic • Logically ties in to other management systems • Corporate systems do not contradict onsite systems Comprehensible • Abbreviations and terms used mean something to employees • Consideration of language issues
- 8. 8 Key Terms Usedin Describing the SMS Implemented • Procedures are approved and in circulation • Evidence is available – completed forms and/or checklists • Employees are trained and knowledgeable Accessible • Employees are aware of how to obtain the most up to date or relevant procedures • Employees can obtain the SMS information needed to support control measures
- 9. 9 SMS Models &Standards • Sound management systems are all similar in fundamental terms • Compliance with the MHF Regulations does not require any particular standard to be used, nor will compliance with an existing management standard ensure compliance with the SMS requirements of the MHF Regulations • There are a variety of ways in which the SMS can be structured. Most large organisations will have their own structure already • However, adoption of a proven standard may assist an MHF employer
- 10. 10 Examples of SMS OH&SManagement Systems Model – AS 4801 gg Safety PolicySafety Policy PlanningPlanning Implementation & Operation Implementation Checking &Correctiv Actio Measurement & Evaluation Continual Improvement Continual Improvement Manageme nt Revie Management Review Overall vision, goals and commitment to improve • Legal compliance • Objectives and targets • Implementation plans • 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 Suitable, adequate, effective Changes needed? Opportunities to improve?
- 11. 11 ISO 14001 EnvironmentalManagement Systems Environmental Policy Management Review Planning Implementation & Operation Checking & Corrective Actions Examples of SMS
- 12. 12 Key Elements ofthe SMS From the previous examples, there are common elements Policy Planning Implementing Assessing Management Review
- 13. 13 Key Elements ofthe SMS Policy Planning Implementing Assessing Management Review Effective health and safety policies set a clear direction for the organisation to follow
- 14. 14 Key Elements ofthe SMS An effective management structure and arrangements are in place for delivering the policy. There is a planned and systematic approach to implementing the health and safety policy Policy Planning Implementing Assessing Management Review
- 15. 15 Key Elements ofthe SMS The policies and procedures are put in place to manage all aspects of the control measures that ensure safe operation of the facility Policy Planning Implementing Assessing Management Review
- 16. 16 Key Elements ofthe SMS Performance is measured against agreed standards to reveal when and where improvement is needed. Policy Planning Implementing Assessing Management Review
- 17. 17 Key Elements ofthe SMS The organisation learns from all relevant experience and applies the lessons. Policy Planning Implementing Assessing Management Review
- 18. 18 The Importance ofSMS • In reviews of accidents, a common thread throughout is the inadequacy of management systems that might have prevented the accident from occurring • Examples of some issues identified are – Lack of hazard review and risk assessment to predict and prevent incidents – Insufficient investigation and follow up after previous incidents – Inadequate training of staff – Failure to implement effective mechanical integrity programs
- 19. 19 The Importance ofSMS The following information provides broad details on some US incidents and contributing causes
- 20. 20 The Importance ofSMS Management System Categories Contributing Causes 0 2 4 6 8 10 12 Em ergency Preparation Q uality Assurance O therTraining Industry G uidance IncidentInvestigation Em ployee P articipation Facility Siting InternalAuditing and O versight Safe W ork P ractices M anagem entofC hange Engineering D esign & R eview M aintenance P roceduresH AZC O M O peratorTraining O perating Procedures Process H azard Analysis Process Safety Inform ation Management System Cause Breakdown of management system categories identified as contributing causes in incident investigations
- 21. 21 The Importance ofSMS • Flixborough 1974 – Management of modification failure – Inadequate experience – Overstretched resources • Piper Alpha 1988 – Failures in shift handover – Permit to work – Training – Communications – Auditing
- 22. 22 The Importance ofSMS • Pasadena 1989 – Maintenance – Permit to work errors – Failure to follow-up on audits • Longford 1998 – Inadequate knowledge of hazards – Absent personnel – Poor procedures
- 23. 23 The Importance ofSMS • Corporate safety oversight, including the safe management of sites obtained through mergers and acquisitions • Corporate safety culture • Corporate and site SMS • Near miss reporting and investigation programs • Mechanical integrity programs • Hazard analysis programs • Change management BP America Refinery Explosion Texas City, 23 March 2005
- 24. 24 The Importance ofSMS - Exercise Buncefield Explosion, UK, 11 December 2005 • In the early hours on Sunday 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
- 25. 25 The Importance ofSMS - Exercise What control measures • Were in place? • Could have been in place? • Were they effective? Buncefield Explosion, UK, 11 December 2005
- 26. 26 The Importance ofSMS - Exercise Buncefield Explosion, UK, 11 December 2005 Control Measure Effectiveness? Level meter & alarm Failed before alarm Independent HLA & Trip Flow continued Auto tank gauge system Did not prevent overflow Preventive Operator surveillance Did not prevent overflow Ignition source control Vapour cloud went off site Fire water system Pump house destroyed Mitigative Bunding Penetrations / joints failed Common theme – failure to manage the control measures
- 27. 27 The Importance ofSMS - Exercise • What SMS elements were needed to ensure that the control measures worked when required? Buncefield Explosion, UK, 11 December 2005
- 28. 28 The Importance ofSMS - Exercise Buncefield Explosion, UK, 11 December 2005 Control Measure Supporting SMS Level meter & alarm Testing and inspection Independent HLA & Trip Critical safety function testing Auto tank gauging system Preventative maintenance program Preventive Operator surveillance Operating procedures and training Ignition source control Design standards, purchasing specs Fire water system Design standards Mitigative Bunding Maintenance and integrity inspection
- 29. 29 The Importance ofSMS – Australian Experience • Feedback from regulator site visits to Australian MHFs, together with examination of incident data has revealed the following issues are likely to be the weakest links within an SMS – Management of 3rd parties – Maintenance procedures and systems – Hazard identification and analysis – Engineering design and review – Operating procedures – Management of change
- 30. 30 The Importance ofSMS – Australian Experience Other issues to note: • There are always fundamental failings in the “system” • Complacency and safety versus production conflicts • Deficiencies in practice with adherence to application of the SMS rather than system standards • Failure to accept and prepare for emergencies
- 31. 31 What Should theSMS Do? • The SMS is the tool with which the Employer meets the overall goal of the Regulations • The SMS should cover the following – Define safety roles and responsibilities – Ensure adequate skills, information, tools and decision-making are present in day to day and abnormal operations – Maintain awareness of hazards and risks – Plan, implement, measure and evaluate MA controls and the SMS – Develop performance requirements – Set targets for improvement of safety at the facility – Manage change
- 32. 32 What Should theSMS Do? • Manage and maintain knowledge • Instigate HAZID and risk assessments • Manage adequate human resources • Provide performance information to all levels of organisation • Review and improve the SMS itself
- 33. 33 What Should theSMS Do? • Manage safe operation at the facility, including MAs, specifically focusing on: – Prevention – Reduction – Mitigation • It is not just documentation - it is the actual implementation of processes, procedures and practices at the facility • Include and reflect the safety culture at the workplace
- 34. 34 What Should theSMS Do? • Some companies, in particular employers of multiple sites, may apply corporate standards for an SMS • These may prescribe the entire SMS, or only common high-level components such as the overall policies and procedures • In other cases corporate SMS requirements may be very limited, and the site will then need to develop its own systems
- 35. 35 What Should theSMS Do? • Many corporate systems specify that local regulations override corporate requirements if they are more stringent • Other companies may employ integrated management systems for the business as a whole • It is entirely up to the Employer to choose how the SMS is structured and developed • However, in all cases the SMS must provide a management focus on the specific control measures required for safe operation of the particular facility
- 36. 36 What Should theSMS Do? Accidents Hazards Causes Consequences Local procedures and practices (design, maintenance & operation) Prevention Controls Mitigatio n Controls Corporate Safety Management System MA Potential Level 1 Level 2 Level 3
- 37. 37 What Should theSMS Do? • The SMS should not just be seen as satisfying MHF requirements • It should be used as a performance management tool to assist in managing the entire operation, including other performance based regulatory requirements • Most modern management system “standards” or "models" feature a set of generic elements, forming a continual improvement cycle
- 38. 38 Measurement of Performance •Performance standards/indicators must be developed and implemented as part of the SMS (e.g. measure the effectiveness of SMS) to support the MHF safety objectives • The following principles apply in defining performance standards: Make them SMART • Specific • Measurable • Achievable • Realistic • Targeted • The purpose of performance standards/indicators for the SMS is to enable the objective measurement of its target and (subsequently) effective maintenance and improvement of performance
- 39. 39 Measurement of Performance •Standards and systems need to be practical • Should not place an unworkable burden on employees • Ensure open, comprehensive and accurate reporting of errors or problems Is an absence of evidence of problems really indicating high performance?
- 40. 40 Measurement of Performance •Performance indicators need to be meaningful and contribute to the overall evaluation of the SMS effectiveness • If a control is stated to be in place for prevention of an MA, then: – Is it implemented? – Is it effective? – Is it audited? – Are the results used for improving the effectiveness of controls management?
- 41. 41 Measurement of Performance •Performance indicators should be established covering (as a minimum): – How often audits are to be undertaken – Scope of the audits – Are the controls implemented? – Are the controls functional? – % compliance, partial compliance and non compliance • Performance indicators should be sufficiently detailed and transparent to enable the effectiveness of the SMS to be apparent from the documentation
- 42. 42 Measurement of Performance •The audits need to be evaluated against criteria developed by the MHF • They should include steps to continually improve the SMS, so there needs to be processes and measures designed to identify and implement improvements to the system itself • Three main types of audits – First audit: Self audit – Second party: audit of suppliers – 3rd party: external agencies e.g. regulator, certification bodies.
- 43. 43 Measurement of Performance •Likewise, 100% compliance is a desirable objective - but realistically not practical • Setting a tiered acceptability criteria could be an option Item Compliance Partial Compliance Non- compliance Audit frequency for controls met 90% 10% 0% Audit time frame achieved 90% 10% 0% Controls implemented 100% 0% 0% Controls functional 95% 5% 0% Example only:
- 44. 44 Examples of SMSPerformance Indicators Permit to work Management of change Operating procedures Auditing Number of accidents or near misses caused by a failure of this system % permits audited compliant with procedure Number of accidents or near misses caused by a failure of this system % of MoC forms completed in compliance with procedures % temporary changes beyond their time limit % of new procedures completed % of procedures reviewed % audits completed to schedule Number of non conformances closed out/month
- 45. 45 Items to Note- Emergency Planning • The MHF must prepare an emergency plan addressing the on- site/off-site consequences • Must consult with employees and emergency services • Plan should consider – Accident type (e.g. major/minor, environmental, personal safety, on-site, off-site, property damage) – Command hierarchy and contact information – Equipment required – Contingency plans • Plan should be tested, reviewed, updated
- 46. 46 Items to Note- Management of Change • Management of change needs to be considered very carefully within the safety report • An issue often discussed is: – When is a change really a change? – When is a change not a change?
- 47. 47 Items to Note- When is a change really a change? • Any change to an MHF needs to be evaluated in the context of the safety report • Examples of this include but are not limited to: – Organisational change – Addition of a new unit – Closure of a unit – Any modification to a potential MA • Desired Outcome: Demonstrate that at least the same level of risk or lower is achieved after the change and that all the processes within the safety report are followed and transparent
- 48. 48 Items to Note- When is a change not a change? • Any change to an MHF that involves swapping like for like is not considered to be a change • This assumes the equipment or systems being changed are fit for purpose
- 49. 49 Items to Note- Incident Investigations • Incidents that occur or could have occurred at an MHF are a valuable source of information • As with good practice, all incidents at a facility should be reviewed for lessons learned and their findings implemented for prevention in the future • For an MHF, investigation of MAs is of particular importance as it will provide insight into the mechanism of occurrence
- 50. 50 SMS - CriticalSuccess Factors • Adequate resources for both development and improvement • Personnel are aware of their responsibility and accountability • Personnel are trained/competent • Consistent with the understanding of risk gained from the risk assessment • There should be sufficient focus on MAs, from planning through to operations • The Employer must document the basis for the facility's SMS, and the SMS itself
- 51. 51 SMS – CriticalSuccess Factors • Adequate resources for both development and improvement • Responsibilities & accountabilities defined • Adequate education and training is provided for employees • Covers the whole facility as defined in the safety report • Employees know how to access it and understand it • Performance indicators & standards for the control measures and the SMS as a whole are defined • Planning, implementation and monitoring processes are provided for control measures and the system as a whole and failures are addressed • Processes are provided for review and revision of control measures and the SMS More information is available in Booklet 3 on the SMS Comprehensive and Integrated
- 52. 52 Review and Revision •The SMS needs to be reviewed on a regular basis to ensure it is fit for purpose for management of an MHF • Over a period of time the lessons learned together with results of performance reviews should enable improvements to be documented
- 53. 53 Sources of AdditionalInformation • Safety Management, Hazardous Industry Planning Advisory Paper No. 9, Guidelines for the Development of Safety Management Systems, Department of Urban Affairs and Planning, 1995 • AS/NZS 4801:2001, Occupational Health and Safety Management Systems – Specification with Guidance for Use, Standards Australia,15 November 2001 – General Guidelines on Principles, Systems and Supporting Techniques, Standards Australia,15 November 2000
- 54. 54 • AS/NZ ISO9001:2000, Quality Management Systems • AS/NZ ISO 14001:2004, Environmental Management Systems • API Recommended Practice 750, Management of Process Hazards • API Publication 9100, Model Environmental Health and Safety Management System and Guidance Sources of Additional Information
- 55. 55 • UK Healthand Safety Executive HSG65, Successful Health and Safety Management • US Department of Labour. OSHA Standard CFR 29 1910.119, Process Safety Management • AIChE, CCPS, Guidelines for Implementing Process Safety Management Systems • Management System Failures Identified in Incidents Investigated by the U.S. Chemical Safety and Hazard Investigation Board, Angela S Blair PE Chemical Incident Investigator, Process Safety Progress, December 2004, Volume 23, No.4 Sources of Additional Information
- 56.
Editor's Notes
- #6 Occupational Health and Safety (Safety Standards) Regulations 1994, Part 9 MH facilities, Division 9.4 Duties of an employer, Subdivision B (duties applying to an employer of certain MF facilities), 9.46 Safety Management System.
- #7 Some of these important terms will be discussed in the following slides.
- #8 Group discussion on each of these key terms.
- #10 – two examples follow
- #13 Note that terminology may vary in the previous examples but that there are common elements
- #17 E.g. auditing.
- #18 Usually an annual activity. Take a step back and review how well the systems are performing, what are the performance indicators saying, are there consistent negative trends in audit results that need to be addressed etc.
- #20 Management System Failures Identified in Incidents Investigated by the U.S. Chemical Safety and Hazard Investigation Board, Angela S Blair PE Chemical Incident Investigator, Process Safety Progress, December 2004, Volume 23, No.4
- #21 Management System Failures Identified in Incidents Investigated by the U.S. Chemical Safety and Hazard Investigation Board, Angela S Blair PE Chemical Incident Investigator, Process Safety Progress, December 2004, Volume 23, No.4
- #24 Taken from U.S Chemical Safety and Hazard Investigation Board, Urgent Recommendations, 17 August 2005
- #27 Automatic Tank Gauge
- #28 Level meter and alarm : Testing and inspection Independent HLA and trip : Critical safety function testing Auto tank gauging system : Preventative maintenance system Operator surveillance : Operating procedures and training Ignition source control: Design standards, purchasing specs Fire water system: Design standards Bunding: Integrity inspection program
- #30 Ex-Worksafe Victoria. These are the major areas of concern (not necessarily in order) that need to be proactively managed to ensure regulatory conditions are satisfied.
- #31 If you do not maintain a system in accordance with its stated requirements, then false hope will be placed on a system that will sooner rather than later, be found wanting, to the detriment of all concerned
- #32 The SMS needs to manage these important areas.
- #34 The system is not just the documentation. The ‘system’ includes all aspects of the implementation and management of the controls.
- #35 Corporate systems help to ensure standardisation of minimum requirements across different facilities. These corporate systems always need to be supported by local systems and procedures (to manage the locally defined controls).
- #37 An example of how a ‘layered’ SMS may look. The corporate systems deals with common elements (e.g. policy, incident reporting requirements etc). Local procedures explain how work is done at the facility and/or groups of control measures are managed (e.g. operating procedures, maintenance planning etc) Individual control measures are defined through local risk assessments.
- #38 Difficulties will arise if different stand-alone management systems are put in place for different aspects of the operations (e.g. MHF, OH&S, business etc). Ensure the SMS is fully integrated into the overall management system at the facility and not just MHF focussed. For example, the training system should manage MHF related training records within the same system as all other training conducted at the facility.
- #39 As for control measures, performance standards need to set on the SMS and performance indicators monitored.
- #40 The SMS should enable the Employer to look into the detail of the performance monitoring information and decide: If an absence of evidence of problems really is indicating high performance Whether there is a breakdown in recognition or communication of problems
- #41 Implemented means it exists, in place, available for use as described in the SC Functional means is used, is working, is reliable and performs as stated in the SC Audited means an auditing program exists, is used, checks performance of SMS against performance described in the SC
- #42 Audits on the control measures helps to identify whether the SMS is working effectively.
- #43 As an example, very low performance compliance for every control audited would not provide confidence that there is an effective and functional SMS
- #44 The above % figures are indicative only and will need to be developed by each MHF site.
- #45 Just some examples.
- #46 Further information is available in Seminar 1 on the safety report.
- #48 Change to people, plant or process that changes the risk or the control measures for a MA.
- #50 What incident recording systems are in place? Is incident data tracked versus goals? What systems are in place to ensure corrective and preventative actions are completed? Is past incident data reviewed to help identify potential hazards?
- #52 These are the key points that can be used as a check list against your own SMS. How well does your SMS stack up?
- #53 The SMS should be a living, breathing system and should be constantly reviewed and updated based on audit findings, incidents, changes, risk assessments etc.