Safety Management System Rel02

8/18/2019 Safety Management System Rel02

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Major Hazard Facilities

Safety Management Systems


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Overview

The seminar has been developed to provide:

• onte!t with MHF "eg#lations

• $n overview of what is re%#ired

• $n #nderstanding of the SMS and why it is important


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• $F$& ' $s far as (reasonably) practicable

• *mployer ' *mployer who has management control of the facility• *" or *"& ' *mergency response or *mergency response plan

• Facility ' any b#ilding or str#ct#re at which Sched#le + materials arepresent or li,ely to be present for any p#rpose

• H$-./ ' Hazard identification

• HS" ' Health and safety representative

• 0O ' 0oss of containment

• 0O&$ 1 0ayers of protection analysis

• M$ ' Major accident

• MHF ' Major hazard facility

• MO 1 Management of change

• OHS ' Occ#pational health 2 safety• S" ' Safety report

• SMS ' Safety management system

Some $bbreviations 2 Terms


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Topics covered in This &resentation

• .ntrod#ction• "eg#lations

• 3hat is a safety management system4

• SMS models and standards

• 5ey elements of the SMS

• The importance of SMS

• 3hat sho#ld the SMS do4

• Meas#rement of performance

• *!amples of SMS performance standards

• *mergency planning

• SMS testing

• .tems to note

• ritical s#ccess factors

• So#rces of additional information


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"eg#lations

Occupational Health and Safety (Safety Standards) Regulations 1994


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3hat is a Safety Management System4

• $n SMS is a comprehensive and integrated system thatens#res that all wor, at the facility is cond#cted safely

• .t sho#ld be f#lly doc#mented6 accessible and comprehensible

to those that need to #se it

• .t recognises the potential for errors and establishes rob#stdefences (control meas#res) which are f#lly implemented6 to

ens#re that errors do not res#lt in accidents or near misses

• .t is comprises a set of wor, practices and proced#res for

monitoring and improving the safety and health of all aspects

of the operation


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5ey Terms 7sed in /escribing the SMS

Comprehensive

• /escribes the way that all safety iss#es incl#ding controlmeas#res are managed

• lear lin, between controls management and the SMS

Integrated

• The str#ct#re is logical6 systematic

• 0ogically ties in to other management systems

• orporate systems do not contradict onsite systems

Comprehensile

• $bbreviations and terms #sed mean something to employees

• onsideration of lang#age iss#es


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5ey Terms 7sed in /escribing the SMS

Implemented

• &roced#res are approved and in circ#lation

• *vidence is available 1 completed forms and8or chec,lists

• *mployees are trained and ,nowledgeable

!ccessile

• *mployees are aware of how to obtain the most #p to date orrelevant proced#res

• *mployees can obtain the SMS information needed to s#pportcontrol meas#res


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SMS Models 2 Standards

• So#nd management systems are all similar in f#ndamentalterms

• ompliance with the MHF "eg#lations does not re%#ire anypartic#lar standard to be #sed6 nor will compliance with ane!isting management standard ens#re compliance with the SMSre%#irements of the MHF "eg#lations

• There are a variety of ways in which the SMS can be str#ct#red9Most large organisations will have their own str#ct#re already

• However6 adoption of a proven standard may assist an MHFemployer


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*!amples of SMS

OH"S #anagement Systems #odel $ !S 4%&1

gg

Safety PolicySafety Policy

PlanningPlanning

Implementation

& Operation

ImplementationChecking

&CorrectivActio

Measurement

& Evaluation

Continual

Improvement

Continual

Improvement

ManagementRevie

ManagementReview

Overall

vision, goals

and

commitment

to improve

• Legal compliance• Obectives and targets• !mplementation plans

• "eso#rces• Leaders$ip responsibilit%• &raining and competenc%• 'ons#ltation and comm#nication• (oc#mentation• )a*ard identi+ication, ris assessment

and controls• -mergenc% response

• .onitoring and

meas#rement• !ncident investigation• "ecords management• /#dits

#itable, ade#ate,

e++ective '$anges needed Opport#nities to

improve


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ISO 14&&1 'nvironmental #anagement Systems

Environmental

Policy

Management

Review

Planning

Implementation

& Operation

Checking &Corrective Actions

*!amples of SMS


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5ey *lements of the SMS

From the previo#se!amples6 there arecommon elements

&olicy

&lanning

.mplementing

$ssessing

Management "eview


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&olicy

&lanning

.mplementing

$ssessing

Management "eview

*ffective health andsafety policies set aclear direction for theorganisation to follow


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$n effective managementstr#ct#re and arrangementsare in place for deliveringthe policy9

There is a planned andsystematic approach toimplementing the healthand safety policy

&olicy

&lanning

.mplementing

$ssessing

Management "eview


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The policies andproced#res are p#t inplace to manage allaspects of the control

meas#res that ens#re safeoperation of the facility

&olicy

&lanning

.mplementing

$ssessing

Management "eview


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&erformance ismeas#red against

agreed standards to

reveal when and whereimprovement is needed9

&olicy

&lanning

.mplementing

$ssessing

Management "eview


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The organisation learnsfrom all relevante!perience and appliesthe lessons9

&olicy

&lanning

.mplementing

$ssessing

Management "eview


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The .mportance of SMS

• .n reviews of accidents6 a common thread thro#gho#t is theinade%#acy of management systems that might haveprevented the accident from occ#rring

• *!amples of some iss#es identified are

1 0ac, of hazard review and ris, assessment to predict andprevent incidents

1 .ns#fficient investigation and follow #p after previo#s incidents

1 .nade%#ate training of staff

1 Fail#re to implement effective mechanical integrity programs


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The following information provides broad details on some 7Sincidents and contrib#ting ca#ses


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Management System Categories Contriuting Causes

0

2

4

6

8

10

12

Management System

C a u

s e

rea,down of management system categories identified as

contrib#ting ca#ses in incident investigations


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• liorough 19*4

1 Management ofmodification fail#re

1 .nade%#ate e!perience

1 Overstretched reso#rces

• +iper !lpha 19%%

1 Fail#res in shift handover

1 &ermit to wor,

1 Training1 omm#nications

1 $#diting


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• +asadena 19%9

1 Maintenance

1 &ermit to wor, errors

1 Fail#re to follow'#p ona#dits

• ,ongford 199%

1 .nade%#ate ,nowledge ofhazards

1 $bsent personnel

1 &oor proced#res


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• orporate safety oversight6incl#ding the safe managementof sites obtained thro#ghmergers and ac%#isitions

• orporate safety c#lt#re

• orporate and site SMS• ;ear miss reporting and

investigation programs

• Mechanical integrity programs

• Hazard analysis programs

• hange management

-+ !merica Refinery 'plosion .eas City/ 0 #arch 0&&2


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The .mportance of SMS ' *!ercise

-uncefield 'plosion/ 3/ 11 5ecemer 0&&2

• .n the early ho#rs onS#nday a n#mber ofe!plosions occ#rred at#ncefield Oil Storage/epot6 Hemel Hempstead6Hertfordshire

• $t least one of the initiale!plosions was of massiveproportions and there was alarge fire6 which eng#lfed ahigh proportion of the site

• Over fort#nately therewere no fatalities


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6hat control measures

• 3ere in place4

• o#ld have been in place4

• 3ere they effective4



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Control #easure 'ffectiveness7

0evel meter 2 alarm Failed before alarm

.ndependent H0$ 2 Trip Flow contin#ed

$#to tan, ga#ge system /id not prevent overflow & r e v

e n t i v e

Operator s#rveillance /id not prevent overflow

.gnition so#rce control ?apo#r clo#d went off site

Fire water system mp ho#se destroyed

M i t i g a t i v e

:#nding &enetrations 8 joints failed

Common theme – failure to manage the control measures


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• 3hat SMS elements were needed to ens#re that the controlmeas#res wor,ed when re%#ired4



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Control #easure Supporting S#S

0evel meter 2 alarm Testing and inspection

.ndependent H0$ 2 Trip ritical safety f#nction testing

$#to tan, ga#ging system &reventative maintenance program & r e v

e n t i v e

Operator s#rveillance Operating proced#res and training

.gnition so#rce control /esign standards6 p#rchasing specs

Fire water system /esign standards

M i t i g a t i v e

#nding Maintenance and integrity inspection


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The .mportance of SMS 1 $#stralian *!perience

• Feedbac, from reg#lator site visits to $#stralian MHFs6together with e!amination of incident data has revealed thefollowing iss#es are li,ely to be the wea,est lin,s within anSMS

1 Management of @rd parties

1 Maintenance proced#res and systems

1 Hazard identification and analysis

1 *ngineering design and review

1 Operating proced#res

1 Management of change


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The .mportance of SMS 1 $#stralian *!perience

Other issues to note8• There are always f#ndamental failings in the AsystemB

• omplacency and safety vers#s prod#ction conflicts

• /eficiencies in practice with adherence to application of theSMS rather than system standards

• Fail#re to accept and prepare for emergencies


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3hat Sho#ld the SMS /o4

• The SMS is the tool with which the *mployer meets the overall goalof the "eg#lations

• The SMS sho#ld cover the following

1 /efine safety roles and responsibilities

1 *ns#re ade%#ate s,ills6 information6 tools and decision'ma,ing arepresent in day to day and abnormal operations

1 Maintain awareness of hazards and ris,s

1 &lan6 implement6 meas#re and eval#ate M$ controls and the SMS

1 /evelop performance re%#irements

1 Set targets for improvement of safety at the facility

1 Manage change


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• Manage and maintain ,nowledge• .nstigate H$-./ and ris, assessments

• Manage ade%#ate h#man reso#rces

• &rovide performance information to all levels oforganisation

• "eview and improve the SMS itself


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• Manage safe operation at the facility6 incl#ding M$s6specifically foc#sing on:

1 &revention

1 "ed#ction

1 Mitigation

• .t is not j#st doc#mentation ' it is the act#al implementationof processes6 proced#res and practices at the facility

• .ncl#de and reflect the safety c#lt#re at the wor,place


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• Some companies6 in partic#lar employers of m#ltiple sites6 mayapply corporate standards for an SMS

• These may prescribe the entire SMS6 or only common high'levelcomponents s#ch as the overall policies and proced#res

• .n other cases corporate SMS re%#irements may be very limited6and the site will then need to develop its own systems


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• Many corporate systems specify that local reg#lations overridecorporate re%#irements if they are more stringent

• Other companies may employ integrated managementsystems for the b#siness as a whole

• .t is entirely #p to the *mployer to choose how the SMS isstr#ct#red and developed

• However6 in all cases the SMS must provide a managementfoc#s on the specific control meas#res re%#ired for safeoperation of the partic#lar facility


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Accidents

H

a z a r d s

C a u s e s

C o n s e q u e n c e s

Local proced#res and practices design, maintenance operation

Prevention

Controls

Mitigatio

n

Controls

'orporate a+et% .anagement %stem

MA Potential

Level 1

Level 2

Level 3


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• The SMS sho#ld not j#st be seen as satisfying MHFre%#irements

• .t sho#ld be #sed as a performance management tool to assistin managing the entire operation6 incl#ding other performancebased reg#latory re%#irements

• Most modern management system AstandardsB or CmodelsCfeat#re a set of generic elements6 forming a contin#alimprovement cycle


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Meas#rement of &erformance

• &erformance standards8indicators m#st be developed andimplemented as part of the SMS (e9g9 meas#re theeffectiveness of SMS) to s#pport the MHF safety objectives

• The following principles apply in defining performancestandards: Ma,e them S#!R.

• Specific

• #eas#rable• !chievable

• R ealistic

• .argeted

• The p#rpose of performance standards8indicators for the SMSis to enable the objective meas#rement of its target and

(s#bse%#ently) effective maintenance and improvement ofperformance


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• Standards and systems need to be practical• Sho#ld not place an #nwor,able b#rden on employees

• *ns#re open6 comprehensive and acc#rate reporting of errors orproblems

Is an absence of evidence of problems really indicatinghigh performance?


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• &erformance indicators need to be meaningf#l and contrib#te tothe overall eval#ation of the SMS effectiveness

• .f a control is stated to be in place for prevention of an M$6then:

1 .s it implemented4

1 .s it effective4

1 .s it a#dited4

1 $re the res#lts #sed for improving the effectiveness of controlsmanagement4


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• &erformance indicators sho#ld be established covering (as aminim#m):

1 How often a#dits are to be #nderta,en

1 Scope of the a#dits

1 $re the controls implemented4

1 $re the controls f#nctional4

1 D compliance6 partial compliance and non compliance

• &erformance indicators sho#ld be s#fficiently detailed andtransparent to enable the effectiveness of the SMS to beapparent from the doc#mentation


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• The a#dits need to be eval#ated against criteria developed bythe MHF

• They sho#ld incl#de steps to contin#ally improve the SMS6 sothere needs to be processes and meas#res designed toidentify and implement improvements to the system itself

• Three main types of a#dits

1 First a#dit: Self a#dit1 Second party: a#dit of s#ppliers

1 @rd party: e!ternal agencies e9g9 reg#lator6 certification bodies9


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• 0i,ewise6 E==D compliance is a desirable objective ' b#t realistically

not practical• Setting a tiered acceptability criteria co#ld be an option

Item Compliance +artialCompliance

on:compliance

$#dit fre%#encyfor controls met

+=D E=D =D

$#dit time frameachieved

+=D E=D =D

ontrolsimplemented

E==D =D =D

ontrolsf#nctional

+D D =D

'ample only8


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*!amples of SMS &erformance .ndicators

&ermit to wor,

Management of change

Operating proced#res

$#diting

;#mber of accidents or near misses ca#sed by afail#re of this systemD permits a#dited compliant with proced#re

;#mber of accidents or near misses ca#sed by afail#re of this systemD of Mo forms completed in compliance withproced#resD temporary changes beyond their time limit

D of new proced#res completedD of proced#res reviewed

D a#dits completed to sched#le;#mber of non conformances closed o#t8month


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.tems to ;ote ' *mergency &lanning

• The MHF m#st prepare an emergency plan addressing the on'site8off'site conse%#ences

• M#st cons#lt with employees and emergency services

• &lan sho#ld consider

1 $ccident type (e9g9 major8minor6 environmental6 personal safety6on'site6 off'site6 property damage)

1 ommand hierarchy and contact information

1 *%#ipment re%#ired

1 ontingency plans

• &lan sho#ld be tested6 reviewed6 #pdated


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.tems to ;ote ' Management of hange

• Management of change needs to be considered very caref#llywithin the safety report

• $n iss#e often disc#ssed is:

1 3hen is a change really a change4

1 3hen is a change not a change4


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.tems to ;ote ' 3hen is a change really a change4

• $ny change to an MHF needs to be eval#ated in the conte!t ofthe safety report

• *!amples of this incl#de b#t are not limited to:

1 Organisational change

1 $ddition of a new #nit

1 los#re of a #nit

1 $ny modification to a potential M$

• 5esired Outcome8 /emonstrate that at least the same level ofris, or lower is achieved after the change and that all theprocesses within the safety report are followed and transparent


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.tems to ;ote ' 3hen is a change not a change4

• $ny change to an MHF that involves swapping li,e for li,e isnot considered to be a change

• This ass#mes the e%#ipment or systems being changed are fitfor p#rpose


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.tems to ;ote ' .ncident .nvestigations

• .ncidents that occ#r or co#ld have occ#rred at an MHF are aval#able so#rce of information

• $s with good practice6 all incidents at a facility sho#ld bereviewed for lessons learned and their findings implementedfor prevention in the f#t#re

• For an MHF6 investigation of M$s is of partic#lar importance as

it will provide insight into the mechanism of occ#rrence


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SMS ' ritical S#ccess Factors

• $de%#ate reso#rces for both development and improvement• &ersonnel are aware of their responsibility and acco#ntability

• &ersonnel are trained8competent

• onsistent with the #nderstanding of ris, gained from the ris,assessment

• There sho#ld be s#fficient foc#s on M$s6 from planningthro#gh to operations

• The *mployer m#st doc#ment the basis for the facilityGs SMS6and the SMS itself


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SMS 1 ritical S#ccess Factors

• $de%#ate reso#rces for both development and improvement

• "esponsibilities 2 acco#ntabilities defined

• $de%#ate ed#cation and training is provided for employees

• overs the whole facility as defined in the safety report

• *mployees ,now how to access it and #nderstand it

• &erformance indicators 2 standards for the control meas#res andthe SMS as a whole are defined

• &lanning6 implementation and monitoring processes are providedfor control meas#res and the system as a whole and fail#res areaddressed

• &rocesses are provided for review and revision of controlmeas#res and the SMS

More information is available in Booklet 3 on the SMS

Comprehensive and Integrated


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"eview and "evision

• The SMS needs to be reviewed on a reg#lar basis to ens#re itis fit for p#rpose for management of an MHF

• Over a period of time the lessons learned together with res#ltsof performance reviews sho#ld enable improvements to bedoc#mented


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So#rces of $dditional .nformation

• Safety Management6 Hazardo#s .nd#stry &lanning $dvisory&aper ;o9 +6 #idelines for the /evelopment of SafetyManagement Systems6 /epartment of 7rban $ffairs and&lanning6 E++

• $S8;-S


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• $S8;- .SO +==E:J===6 K#ality Management Systems• $S8;- .SO E


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• 75 Health and Safety *!ec#tive HS6 S#ccessf#l Health andSafety Management

• 7S /epartment of 0abo#r9 OSH$ Standard F" J+ E+E=9EE+6&rocess Safety Management

• $.h*6 &S6 #idelines for .mplementing &rocess SafetyManagement Systems

• Management System Fail#res .dentified in .ncidents.nvestigated by the 79S9 hemical Safety and Hazard.nvestigation oard6 $ngela S lair &* hemical .ncident.nvestigator6 &rocess Safety &rogress6 /ecember J==


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K#estions4

Documents

Safety Management System Rel02