safety indicators: an sme perspective - epsc

© Copyright CBA 2011 | www.chemical.org.uk

Safety Indicators:

An SME perspective

WHO IS CBA?

| © Copyright CBA 2011 | www.chemical.org.uk

131 member companies

• Represent

o Distributors;

o Logistics Service Providers; and

o Affiliates

Micro - 13%

Small - 37%

Medium - 35%

Non-SME - 15%

o 23 members operate 57 Major Hazard sites


Safety Performance

Indicators Process

Too many organisations have relied historically

on failure data,

• the so-called “lagging indicators”, to monitor safety

performance

Lagging indicators

• monitors re-actively the performance of critical risk

control systems:

o the employee accident rate (LTA),

o instances of containment failure,

o other significant failures.

BACKGROUND


Lagging Indicators

Improvements or changes are only determined after something has gone wrong.

Discovering a weakness in control systems by having a major incident: • is too late; and

• too costly.


SPLI’s and SME’s

SME’s have:

• Limited expertise; and

• Fewer resources to dedicate to technical issues

• Management often involved in numerous aspects of

the business

o Closer to the “coal face”

o More ‘in tune’ with the actual operating processes

o May be easier to identify appropriate indicators

Less bureaucracy


SPLI’s and SME’s

SPLI’s are an effective management tool

• Focus attention on the critical elements

o One accident can have devastating effects

Distillex

• Uncontrolled fire

• No fatalities

• Site never reopened

North West Aerosols

• LPG Explosion

• Fatalities

• Prosecutions

• Site never reopened


Leading Indicators

Positive leadership

• requires Directors and senior managers to monitor the

effectiveness of internal controls against business risks

o Often against a tolerance level

therefore highlight the need for action.

Early warning of dangerous deterioration

• within critical systems provides an opportunity to avoid

major incidents

Provide a routine systematic check

• that the safety system is working, and

o that key actions, or activities, are undertaken as intended.


CBA/UKWA Working Group

CBA agreed to work with UKWA to produce:

• Generic Safety Performance Leading Indicators

(SPLI)

• Relevant to warehouse sector

o Distributors

o Logistics Services

o HSE

o CBA/UKWA Secretariat

• SME friendly document and process


SCOPE

Primarily aimed at major hazard organisations in scope of COMAH (Seveso) • Reg.4, operators to take ‘all measures necessary’ to

prevent major accidents.

Other organisations that operate sites with the potential to cause significant off-site risk.

At any chemical warehouse to demonstrate that hazards are controlled.

Wherever it would enhance business Performance.


Document Development

The CBA secretariat prepared the SPLI

guidance based closely upon:

• HSG254, Developing Process Safety Indicators

• Guidance on Developing Safety Performance

Indicators, OECD Environmental, Health and Safety

Publications, Series on Chemical accidents, No 19.

Endorsed by HSE



Menu format to enable operational sites to

determine appropriate leading indicators.

• Users would select from a suite of SPLI, based upon

the risk assessments of their business.

• The list of SPLI would be neither prescriptive nor

exhaustive, and would be viewed as guidance only.



Areas for control were identified: • racking,

• handling,

• storage & segregation,

• fire & explosion,

• loading & unloading,

• equipment,

• management systems.

Critical elements were

identified for each

area:

• fire & explosion

o Site security

o Earthing

o Sources of ignition

o Fire detection

o Fire suppression

o DSEAR



Potential SPLI were developed for each critical

element:

• Fire detection

o The percentage of inspections and testing of controls

performed to schedule.

o The percentage of inspections where no defects are

detected.

e.g. the inspection and testing of smoke detectors, alarms and

break glasses.


SIX STEP PROCESS

1. Establish an implementation team Leadership, technical knowledge, resources, timescale

2. Decide on the scope of the SPLI Programme • Activity, site, company level,

• Safety critical factor, establish priorities

3. Identify the risk control systems already in place

4. Identify the critical elements of each risk control system

• Identify the leading indicators

5. Establish a data collection and reporting system

6. Review the data.


The Guidance Document

Annex 1

• The warehouse example

Annex 2

• Key Indicators

Annex 3

• Recording and reporting examples from working

group members

Glossary & Definitions


Sector Performance


38 (68%) COMAH

sites inspected

• 13 LT

• 25 TT

Regulator visits

• Assessment criteria

o Delivery guides

o Scoring matrix

o 10 to 60

Traffic light system

95% high scores

• 10 to 30

o 71% (10 to 20)

5% (2 sites)

• Scored 40

• In planning stages

o 6 to 12 month

CONCLUSIONS

Performance indicators aid companies

• Not just in regulatory compliance

o Performance enhancement

o Sustainability

Being an SME not a barrier

• May be an advantage

o Smaller, less bureaucratic structure



CASE STUDY:

RASE Distribution Limited

Contract Logistics

UK and European service

Hazardous Goods

Specialist Storage and Handling • 2 COMAH ‘Top Tier’ sites

www.rase.co.uk

CBA – Safety Performance Leading Indicators (SPLI) Working Group

Ian Lovely (RASE General Manager) attended the 1st meeting on 28th January 2009 - Agenda • Welcome and Introductions

• Scene setting

• SPLI Brainstorming

• SPLI refinement

• Testing programme and timescales

• Sector engagement

• Date of next meeting

Objective • To draw up, trial and recommend to HID a suite of SPLIs for COMAH sites by 31st

December 2009

Methodology • Brainstorming by all companies present on possible SPLIs

• SPLIs were developed in categories

RASE already had a trial of 2 SPLIs in operation prior to attending this meeting.

Example of SPLI category with some sub-categories

Fire & Explosion

Site Security

Sources of Ignition – Earthing & Controls (Smoking & Mobile Phones)

Detection (Fire, Smoke & Heat)

Suppression

% of on-time inspections of security

% of defect free inspections

% of on-time inspections & testing


Number of false alarms

& of on-time inspections & testing


Number of false alarms

% of on-time inspections & testing


SPLI Working Group 2nd meeting on 9th March 2009 - Agenda • Welcome and Introductions

• Review outcome of last meeting

• HSE viewpoint by Ian Travers

• Timetable for pilot trials

• Volunteers for pilot trials


All companies present reviewed the proposed list of SPLIs and volunteers agreed to produce individual SPLIs

RASE elected to trial the following SPLIs; • Racking

• Segregation

and where possible information from the previous 6 months was to be included

2009 RASE held an internal meeting with Warehouse Managers and Supervisors to; • Update his staff on the progress of the 9th March SPLI Working Group

meeting

• Agree that initially the SPLIs would be trialled at one site, with a planned later roll-out at the second site

• Brainstorm; o How the SPLI concept is delivered to the staff

o How to engage the site operators to gather information for the specific SPLIs

o How to record the information

o How to present the SPLIs (both internally and externally) e.g. Graphs, Bar Charts

RASE added their allocated SPLIs of Racking and Segregation to their 2 SPLIs (currently being trialled - Loading / Unloading and Fire Detection) as identified from the representative set of scenarios presented in the latest RASE Wickenby COMAH Safety Report submitted to HSE.

SPLI Working Group 3rd meeting on 18th September 2009 - Agenda • Welcome and Introductions

• Review outcome of last meeting

• Progress on pilot trials

• Review of draft guidance

• Potential Workshop


• Ian Lovely presented to the group the findings of the 2 RASE SPLIs; o Racking

o HSG71 Segregation

Both SPLIs were shown in combined Spreadsheet and Graph forms

The information was from February to August 2009

In light of the draft SPLI guidance and findings internally the style will be modified slightly going forward

Learning opportunity

during the SPLI trial

• Racking

Learning opportunity

during the SPLI trial

• HSG71 (Segregation)

HSE Intervention

on 18th November

2011

• Agenda Item 2

o Check on the

Company’s progress

with PSPIs (SPLIs)

Conclusion • The HSE Intervention concluded

that RASE had progressed development and implementation of a representative set of SPLIs sufficient to achieve PSPI stage 4 – criterion met.

• RASE programme of implementation commenced in Q1 2009 and in Q4 2011 HSE deemed that stage 4 had been completed – a working set, which are changed as the business changes.

RASE SPLIs are an agenda item at; • Management Review

• Safety Committee Meetings

• Departmental Meetings etc.

safety indicators: an sme perspective - epsc

Documents