Major Hazard Facilities

1
Major Hazard Facilities

• Preparing and Managing a Safety Report

2
Overview

• The seminar has been developed to provide
• Context with the MHF Regulations
• An overview of what is required by an employer
  who needs to prepare and maintain a safety report.

3
Some Abbreviations and Terms

• AFAP - So far as practicable
• ER or ERP - Emergency response or Emergency
  response plan
• HAZID Hazard Identification
• HSR - Health and safety representative
• MHF - Major hazard facility as defined in the
  Regulations
• MA - Major accident
• OHS -Occupational health safety
• Employer - Employer who has management control of
  the facility
• SMS - Safety management system
• SRO Safety report outline

4
Topics Covered In This Presentation

• Introduction
• Preparing a safety report
• What makes a good safety report
• Safety report outline - Core components
• Potential pitfalls
• Key success factors
• Managing and maintaining a safety report
• Review and revision
• Safety report for a new project

5
Preparing a Safety Report
Management Commitment and Support
So this is whats required
Project Management
Consultation Communication
Understand Requirements
6
Management Commitment and Support

• The safety report should feature in, and be
  consistent with, business goals and objectives
• The process is resource and time intensive so
  commitment for significant funding and employee
  time is required
• Consistency with company policy, philosophy and
  objectives is necessary to maintain and sustain a
  compliant safety report
• Essential that upper management show strong
  commitment, drive the process and provide the
  environment for the facility to develop,
  implement and maintain the safety report

7
Know The Regulatory Requirements

• Read the Regulations !!!
• Be sure to interpret the Regulations in the
  context of your facility
• Define the relationships between the safety
  report / MHF requirements and other OHS
  management activities
• Clarify any points of the Regulations that are
  not understood. Do this early as several matters
  require compliant practice from the very
  beginning of the activity (eg consultation)
• The MHF Regulations are relatively simple to
  grasp albeit difficult to comply with

8
Safety Report Planning

• Proper planning is an essential element in
  preparing a safety report
• An effective plan will cover all aspects of
  safety report development (or review and
  revision) including important aspects such as
  consultation

9
Safety Report Planning

• Definition of tasks to be completed
• What do you need to do ?
• Definition of constraints in place
• What resources do you have access to, funding
  available, regulatory timeframes etc
• Definition of task inter-relationships
• What has to come first, which tasks rely on
  information from another task, what are the
  constraints on availability of resources? etc
• Identification and allocation of resources to
  each task
• Who is needed to complete each task?
• What other projects/tasks are competing for the
  same resource?
• What tools, equipment or systems will you
  require?
• What data will you generate and how will you
  store, use and manipulate this data?
• What resources will you use to monitor progress?

10
Safety Report Planning

• Other elements in the safety report plan
• Estimation of task completion times and
  definition of task milestones in overall project
  schedule
• Consultation and reporting plan for the project
  who needs to be involved, who needs to be
  informed?
• A clear project organisation structure detailing
  roles, responsibilities reporting lines for
  project activities

11
Safety Report Planning

• Safety report outline for new safety reports
• Review/revision plan for update of an existing
  safety report
• Employees and HSRs should be briefed on the
  proposed plan to achieve a common understanding
  and agreement of what is required
• Acceptance by upper management of the resource
  requirements, process, and commitment is
  essential

12
Resources, Tools and Systems

• Safety report development is a resource intensive
  process
• Expect that high levels of employee participation
  are needed
• Plant operators, maintenance personnel, plant
  managers, engineers, OHS personnel, consultants,
  support personnel, administrative personnel,
  HSRs, contractors and corporate managers are all
  likely to be involved to a significant extent
• Often spin-off projects are identified to address
  deficiencies in related support systems (e.g.
  training systems, document management systems, IT
  systems)
• Core safety report development roles are not
  always best served by part time roles

13
Resources, Tools and Systems

• Attempt to identify early any important tools
  which may be required. For example, are CAD
  drafting facilities required to update drawings?
  Will access to certain database information be
  required? What reference materials must be
  sourced?
• Early consideration on how to record, store,
  manipulate and use the vast quantity of data
  generated from the safety report development
  process is recommended
• Where existing systems, tools etc are to be used
  for the safety report tasks, it is prudent to
  verify early that those systems and tools will
  provide compliant outcomes
• If the systems and tools of third parties (e.g.
  consultants) are to be utilised, the employer
  should include tasks to test and verify the
  adequacy of these for achieving a compliant
  safety report

14
Availability of Resources

• The significant effort and time commitment
  required to complete activities such as hazard
  identification and risk assessment can be wasted
  if all relevant facts and knowledge are not
  available
• Early consideration and coordination with many
  people is generally required
• An objective evaluation of available skills is
  necessary to ensure additional expertise can be
  sourced where necessary
• A low tolerance approach to workshop
  non-attendance is often required from senior
  management level. Workshops may be arduous, time
  consuming and often repetitive. Management and
  HSR support is required to overcome this
• Plant and corporate managers need to agree and
  commit to the safety report program, and manage
  conflicting demands on resources accordingly

15
Project Management

• The safety report plan needs to not only be
  defined, but also tracked and monitored to ensure
  successful completion by the due date and within
  all constraints
• Good project management is required to ensure
  tasks are completed on schedule, over-runs are
  identified early and rectified, barriers to
  achieving compliance are identified and overcome
• Consider the need for dedicated project resources
  (e.g. Safety Report Manager) to ensure process is
  not derailed by conflicting responsibilities

16
Quality Assurance

• A great deal of effort and resource is expended
  by facilities in developing and documenting
  safety report components. It is important that
  this effort is accurately reflected in the final
  documentation
• Facilities should be careful to ensure data
  presented in their submitted safety report is
• Accurate
• Consistent
• Unambiguous
• Complete

17
Safety Report Outline (SRO) Core Components

• Safety report philosophy
• Scope of work to be undertaken
• Resources, timetable, milestones
• Key definitions and criteria (risk, property
  damage)
• Methodology statements (HAZID, risk assessment
  etc.)
• Details of the scope of consultation that will be
  undertaken
• The emergency plan

18
SRO Core Components - Safety Report Philosophy

• Inherent risks within the facility
• Chief methods of ensuring safe operation at the
  facility
• Description of safety management system
• Safety culture within the organisation

19
SRO Core Components Description of Methods

• The methods chosen for hazard identification and
  risk assessment are likely to have a major impact
  on resource requirements and timeline
• Identify these early in the safety report
  planning
• The methods used should align with the approach
  to safety adopted at the facility

20
SRO Core Components - Consultation

• The MHF Regulations require you to consult with
  employees and external stakeholders during the
  development of the safety report
• The safety report outline should describe
• Who will be consulted
• How the consultation will occur
• How the information from the consultation will be
  included in the safety report

21
SRO Core Components - Consultation

• Who do you have to consult?
• 7 main groups of people
• HSRs
• Employees
• Emergency Services
• Municipal Council(s)
• Non-employees who enter the facility (e.g.
  contractors)
• Local Community
• Other persons who may reasonably suspect risk to
  their health and safety

22
SRO Core Components - Emergency Plan

• Emergency Plans exist because things can go wrong
  and preparation is needed for such an event
• Emergency Plans are more than response
  procedures they also include the supporting
  framework of training, resources, performance
  measures and drills etc
• Consultation with all emergency services is
  necessary (because they have a role to play in
  combating incidents and provision of resources)
• Emergency Plan must be adopted as a control
  measure and as such the development of meaningful
  performance measures and indicators is required

23
What Makes a Good Safety Report?

• All parts of the Regulations are systematically
  addressed
• Early momentum is established
• High levels of employee involvement
• Wide and varied expertise has been made available
• Thinking outside the established norms
• Challenging the status quo
• The safety report process is integrated into
  facility improvement plans and business processes
• Safety report is owned, understood and managed by
  the MHF
• The safety report process provides clear benefits
  to stakeholders

24
What Makes a Good Safety Report cont

• Clear and consistent links between MAs, Hazards,
  Risk, Controls, Emergency Plan, SMS and
  Performance Monitoring Regimes
• Implemented control measures, SMS, performance
  monitoring regimes etc are sustainable given the
  size and complexity of the facility
• Documentation captures corporate memory
• The process is logical and simple dont over
  complicate

25
What Makes a Good Safety Report cont

• The safety report demonstrates that
• The employer fully understands the facilitys
  processes/systems
• The employer understands the facilitys risks
• Appropriate control measures have been selected
  and implemented to reduce risks AFAP at the
  facility
• Systems are in place to manage each MA to ensure
  risks continue to be reduced AFAP
• The employer has systems to keep the control
  measures working to their stated performance
  level
• The employer has in place processes for reviewing
  and revising, as needed

26
Some Potential Pitfalls and Mistakes

• Not taking time to understand the Regulations
  properly
• Inadequate planning
• Wasting time and resources redoing work
  unnecessarily
• Over committing to controls and systems which
  cannot be reasonably sustained
• Do things to look impressive but which dont
  add real value to the business
• Not using valuable information already available
  (e.g. independent audits etc)
• Overlooking mitigative controls and the need to
  maintain them

27
Some Potential Pitfalls and Mistakes

• Failing to carry forward changes into all
  relevant parts of the safety report (e.g.
  Emergency Plan)
• Inconsistencies between different parts of safety
  report or between different sources of
  information
• Losing sight of the big picture unbalanced
  focus on certain aspects
• Losing sight of the overall objective of the
  regime
• Failing to make safety report compliment overall
  business objectives

28
In Conclusion - Keys to a Successful Outcome

• Adequate Planning and Education

• Understand the requirements in the Regulations
  and know what compliance looks like
• Dont over complicate at the start
• Test processes and methods of documentation
  before starting
• Identify resource needs early and consider how
  on-going maintenance of the safety report will be
  managed

29
In Conclusion - Keys to a Successful Outcome

• Involve the right people

• Commitment from senior management
• Appropriate depth range of experience
• Suitably qualified people
• Operations staff, those who
• are exposed to the hazard
• are the ones most likely to be impacted by, or
  contribute to an incident
• understand the true variance in operating
  conditions and environments

30
In Conclusion - Keys to a Successful Outcome

• Clarity and Consultation

• People understand what they are doing and why.
• It is essential to included ongoing consultation
  with employees
• Everyone exposed to hazards or involved in
  management of the risk needs to understand
• The hazards
• The risk
• The controls
• The relationship between them
• The safety report should form the basis of
  training and operating procedures
• Key documents are updated and available

31
In Conclusion - Keys to a Successful Outcome

• Cultural Match

• It is important that the process and methods used
  will work successfully within the organisation
  and the way it functions
• E.g.
• Dont use highly technical approaches if that is
  not what you usually do
• Ensure that controls are appropriate to the
  capability of the facility to manage them

32
In Conclusion - Keys to a Successful Outcome

• Sustainability

• Need to remain focused on the facilities ability
  to sustain both
• The processes introduced
• The outcomes from the process (new controls)

• Ongoing resource requirements need to be
  considered before starting

33
In Conclusion - Keys to a Successful Outcome

• Belief in the Outcomes

• Focus on improving safety, not simply compliance
  (regulatory or internal)
• Effective real consultation stakeholder
  ownership
• Preparedness to challenge established norms
• Process and procedure for resolving issues and
  agreeing assumptions
• Transparency of the process

34
In Conclusion - Keys to a Successful Outcome

• Continuous Improvement

• Focussed effort for continuous improvement in all
  aspects of the safety report and its supporting
  systems

35
Managing A Safety Report
36
Managing a Safety Report

• The facility has been given a licence for 5 years
• Management congratulates all
• Everyone breathes a sigh of relief
• Onto the next project
• Let the safety report sit in the draw until the
  next investigators visit or licence renewal
  period

37
Managing a Safety Report

• After all, the licence confirms
• Risks are in control
• and
• There are management systems in place to deal
  with all of the required issues covered by the
  Regulations
• Tempting yes
• But WRONG!

38
Managing a Safety Report
39
Managing a Safety Report

• The safety report should become integrated into
  the daily management activities of an MHF
• The safety report process will have identified
  all of the performance parameters required for
  managing the risk from each MA

How to use the information to keep the risk from
each MA as low as practicable?
40
Managing a Safety Report

• How to validate that controls identified in the
  safety report are
• Implemented?
• Functional?
• Meeting the performance standards nominated
• Changes to circumstances are handled in
  accordance with the safety report process
  requirements
• A system must be in place to verify all of these
  issues in an explicit and transparent manner

41
Managing a Safety Report

• The control measures need to be managed through
  an audit system by the employer and documented in
  such a manner that allows the performance of
  every control to be verified
• The overall performance of every control managing
  an MA should therefore be audited

42
Managing a Safety Report
43
Managing a Safety Report

• The SMS becomes the primary means of managing
  safety
• As with the concept of management systems, if it
  is stated to do something, then it should be
  verified
• Performance indicators should be developed to
  measure the success or otherwise

44
Reviewing and Revising

• The effectiveness of the SMS can be measured
  through a specifically developed auditing process

45
Reviewing and Revising

• The auditing process is considered essential to
  demonstrate
• Continuing compliance with the safety report
• Effectiveness of all the processes and systems
• For the facility
• The employer can develop a schedule for auditing
  the SMS elements and each of the MA controls
  identified in the safety report throughout the
  year
• Undertake the audit and report on outcomes

46
Reviewing and Revising
47
Reviewing and Revising

• It is natural that with any system there will be
  opportunities for improvements to be made to the
  safety report process
• Such improvements could relate to
• Feedback from employees regarding training
• Performance of controls (positive or negative)
• Management of change
• Emergency response exercises
• Training
• Incidents that occur
• Communications with Regulator

48
Reviewing and Revising

• Feedback from various sources will enable the
  safety report to be continually used as a key
  management business platform for the MHF
• It will provide demonstration to all stakeholders
  of how the process is working
• It will aid transparency and continued
  demonstration of adequacy that the safety report
  is fit for purpose

49
New Projects
50
New Project

• How do we achieve the right outcome?

Project Lifecycle
New Project!
51
New Project

• MHF issues need to be considered as early as
  possible during a project lifecycle
• Decisions taken at early stages of a project will
  have an impact on the MA profile of the facility
  good and bad
• The employer needs to focus on short, medium and
  long term issues required for the safety report
  during project development

52
New Project
Concept

• Major hazard issues should be considered during
  each step in the project life cycle
• Important decisions at the concept phase can
  impact upon the overall risk profile of the
  facility throughout its life

Design
Construction
Commission
Production
Decommission
Disposal
53
New Project

• It is cheaper to fix an issue at the design phase
  than the operational phase
• Retrofitting control measures or fundamental
  design changes during the operational phase
• Is always more expensive
• Places a very large burden financially on
  operational budgets
• Delays the facility from reaching the designed
  throughput targets
• If the process is well structured, the reasons
  for specific controls adopted and rejected can be
  documented corporate memory
• The corporate memory approach is extremely
  valuable

54
New Project Potential Issues

• For example, XYZ company engages a contractor for
  developing a project on a lump sum basis and the
  project requires MHF licensing
• In many cases the contractor will engage a
  resource to deal with MHF requirements

55
New Project Potential Issues
Possible Project Organisation
56
New Project Potential Issues

• The question for all concerned is how can the
  objectivity of a safety report development be
  achieved without competing elements of the
  project being compromised?
• The key to a successful outcome is how the
  contract is set up between XYZ company and the
  contractor

57
New Project Potential Issues

• Conflicts of interest can easily occur there
  are many examples of this and the end result
  would be costly for both XYZ company and the
  contractor
• MHF issues that arise which are outside the basis
  on which the contractors lump sum price was
  developed will need to be addressed as opposed
  to being ignored
• This may lead to protracted delays between
  employer (XYZ company), contractor and regulator

58
New Project Potential Issues
Start the safety report early -at the concept
phase
Clearly defined responsibilities,
accountabilities and authorities
Resources (internal versus external)
Clearly defined deliverables
Contractual arrangements
59
New Project Potential Issues

• The contractual arrangement should address
• Commitment of client
• Contractual and planning arrangements
• Resources (internal versus external)
• Clearly defined deliverables
• Establishment of milestones
• Establishment of key criteria and methods
• Clearly defined responsibilities,
  accountabilities and authorities
• Start the safety report early (at the concept
  phase)

60
Questions?
61
Supporting SlidesEmergency Plan
62
SRO Core Components - Emergency Plan

• An emergency response plan is a mitigative
  control that may prevent an incident from
  escalating to a more severe outcome

63
SRO Core Components - Emergency Plan

• Develop your EP/ERP based on your credible Major
  Accident Scenarios
• Involve all emergency services in the
  consultative process
• Ensure involvement of council and community
• Simplify procedures
• Develop and implement performance standards that
  will value-add to the emergency plan
• Conduct exercises based on the plan

64
SRO Core Components - Emergency Plan

• When an emergency occurs, the first steps taken
  will have an impact on the outcome (consequences)
• The outcome can be minimised by having control
  measures and systems in place to mitigate the
  consequences of an emergency situation
• This takes
• Planning
• Evaluation
• Adequacy of systems in place
• Training
• It is an ongoing process over the lifetime of the
  MHF

65
SRO Core Components - Emergency Plan

• Emergency planning is a cyclical process
• The plan should be
• Dynamic and interactive
• Ensuring ongoing relevance to the needs of the
  facility and all stakeholders by continual
• Monitoring
• Review
• Consultation

66
SRO Core Components - Emergency Plan
67
SRO Core Components - Emergency Plan

• Aim of the Plan
• Provide a system and resources to protect people,
  property and the environment
• To minimise adverse impact on people, property
  and the environment
• Objectives of the Plan
• Comprehensive, yet concise, simple and flexible

68
Emergency Plan Contents - Example
69
Emergency Plan Site and Hazard Detail

• Links the risk assessment outcomes to the
  emergency plan
• Identifies personnel resourcing issues
• Details assumptions
• Details the combating resources available on site
• Details Emergency Response Plans

70
Emergency Plan Site and Hazard Detail

• Assumptions affecting the emergency plan
• Assumptions on the availability of resources and
  services and the execution of responses within an
  estimated time frame
• Assumptions should be evaluated and contingency
  plans developed when assumptions fail or cannot
  be justified
• Typical assumptions include
• Availability of external resources
• Response time of emergency services
• Correct operability of equipment
• Key personnel will be available on site at time
  of incident
• Personnel will be competent to undertake duties
  as detailed in the plan
• Fire water containment capability

71
Emergency Plan Site and Hazard Detail

• Estimation of Consequences
• The effects/impacts can be estimated from
  information available on material released,
  operating conditions, facility layout, nature of
  the surroundings and environmental conditions
• Nature and rate of material released
• Radiated heat generated by a fire
• Blast generated by an explosion
• Toxic concentration in the atmosphere
• Escalation potential

72
Emergency Plan Site and Hazard Detail

• Estimation of Consequences
• Once the analysis of the scenario has occurred,
  the emergency response scenario information can
  be presented in a consistent format
• Format is site specific but must meet the needs
  of those expected to use the information
  including site and emergency services personnel.

73
Example Emergency Response Plan
Product
Fire Consequences
Fire Fighting Equipment
Foam and Water Requirements
74
Example Emergency Response Plan
Site Plan
Pool Fire
Heat Flux with Wind (4.7 kW/m2 for personnel
accessibility)
Heat Curve irrespective of wind direction
75
Emergency Response Command Structure Personnel

• Identifies roles for individuals within the
  emergency plan
• Identifies
• Who is in charge
• What personnel should do
• Why they do it
• When they do it
• Who is communicating with whom
• How to contact persons, organisations or
  additional resources

76
Emergency Response Command Structure Personnel

• Roles and responsibilities needs to clearly
  detailed and should to be consistent with the
  Command Structure
• Role statements need to be available for all
  positions and persons need to be familiar with
  their role and also their contingency role (if
  any)

77
Emergency Plan Notifications

• On site personnel
• Off site facilities
• Emergency services
• Applicable authorities

78
Emergency Plan Notifications

• Information required by fire services when
  responding to a notification should be fit for
  purpose
• i.e. for Chemical Spill
• Type and scale of the spill (eg within bund or
  uncontained)
• Name of the substance involved
• UN Number
• Estimated quantity

79
Emergency Plan Resources

• The plan must identify all resources available on
  site that are available for use during an
  emergency
• Where the equipment/material (foams,
  neutralisers, etc) are located or how they are to
  be obtained
• Fixed fire fighting systems should be explained,
  in particular their design intent (eg. Deluge
  systems -cooling or mitigation) method of
  activation
• Flow rates and water supply duration should also
  be detailed

80
Emergency Plan Evacuation Procedures

• These procedures must enable any person on site
  to understand what is expected of them and what
  actions they are required to undertake
• The procedures must explain who is responsible
  for accounting for personnel and how it is to be
  achieved (links to Command Structure)

81
Emergency Plan Isolation Procedures

• Control Isolation Points
• Provides details for the isolation of
• Utilities (gas, water and electricity)
• Road Traffic
• Isolation points need to be identifiable,
  accessable and maintained

82
The Emergency Plan as a Control Measure

• The emergency plan must be included among the
  control measures adopted under Regulation 9.45.
• Need to identify appropriate Performance
  Indicators and Standards that will ensure the
  on-going effectiveness for each individual
  control, to enable ongoing assurance.
• Indicators of failure need to be identified
• Actions to be taken in reporting any such failure
• Other corrective actions to be taken in the event
  of any such failure.

83
Emergency Plan Example Performance Standards

• Emergency response personnel are nominated and
  manned on all shifts
• Response plans are in place for all emergency
  scenarios
• Emergency response personnel training is current
• Emergency response resources are available,
  capable and tested
• Drill/exercises are conducted according to the
  schedule

84
Emergency Plan Example Performance Indicators

• of fire equipment inspected and tested as per
  schedule
• Evacuation of non essential personnel to assembly
  point within 7 minutes
• Notification to Emergency Services within 2
  minutes of potential major accident being
  identified
• Emergency Response Team to assemble within 3
  minutes of alarm
• Emergency response plan exercises are completed
  within one month of scheduled date

85
Emergency Plan - Testing

• What is the desired outcome of conducting an
  emergency exercise?
• To be able to demonstrate so far as is reasonably
  practicable that in the event of emergency (eg
  MA), the mitigation control measures will work as
  expected to reduce the likelihood of injury to
  all persons and restrict damage to plant,
  equipment and local community to a minimum.

86
Emergency Plan - Testing

• What else is tested in an emergency exercise?
• Alarm and communications systems
• Call-out of internal/external emergency personnel
• Critical emergency equipment availability
• Evacuation procedures
• Ensure participation of appropriate emergency
  services.

87
Emergency Plan Testing Desktop Exercise

• Useful training for familiarisation with
  procedures and site emergency issues
• Can identify resource limitations, issues and
  knowledge amongst personnel
• May not adequately test communication, site
  evacuations processes or equipment accessibility.
• Desktop exercise should not be used as the means
  of compliance with Regulation 9.53(4)

88
Emergency Plan Testing Simulated MA Scenario

• Will test effectiveness of evacuation procedures
• Coordination between onsite procedures and
  emergency services
• Extended test of onsite/offsite communication
  systems
• Tests capability of emergency services to
  response
• Identify limitation/restrictions in equipment
  access