background and content major accident prevention policy (mapp) and safety management system (sms)

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

This project is funded by the European UnionProjekat finansira Evropska Unija

BACKGROUND AND CONTENT MAJOR ACCIDENT PREVENTION POLICY (MAPP) AND SAFETY MANAGEMENT SYSTEM (SMS)

Ike van der PuttePhD Toxicology – EUROTOX registeredMSc Environmental [email protected]



ESSENTIAL ELEMENTS OF A SAFETY REPORT

Note: Structure is accordingto ANNEX II SEVESO II;In practice structure of Safety reports is not followed exactly



I. MAPP AND SMSMajor Accident Prevention Policy (MAPP), is a “self-commitment” by the operator of a Seveso type establishment to meet the requirements of Article 5. (operator obligations)

A safety management system (SMS) is instead a set of activities that ensures that hazards are effectively identified, understood and minimised to a tolerable level. In this sense, it may be regarded as the transposition of the general goals identified in the MAPP into specific objectives and procedures.



General Management System Principles

Management of any sizeable activity is based on the idea of a“management loop”, which involves agreeing an objective, defining a plan to achieve that objective, formulating the detailed work required to implement the plan, carrying out the work, checking the outcome against the plan, and planning and takingappropriate corrective action. Safety management is no exception to this general principle. This means that in addition to the goals of the Safety Management System, and the issues it addresses, the integrity of the management loop and the completeness and accurate functioning of the management system are essential.



PLAN-DO-CHECK-ACT THE KEY TO SAFETY SUCCESS


Project implemented by Human Dynamics ConsortiumPlan-Do-Check-Act the Key to Safety Success

WHAT IS PDCA?

PDCA (plan–do–check–act )

An iterative four-step management method used in business for the control

Continuous improvement of processes and products



Policy

Planning

ImplementationCheckingCorrective Action

ManagementReview

GENERAL MANAGEMENT SYSTEMMODEL – PLAN, DO, CHECK, ACT



MAPP and SMS should address the following issues:

1. organisation and personnel2. identification and evaluation of major-accident hazards3. operational control4. management of change5. planning for emergencies6. monitoring performance7. audit and review

MAPP



The MAPP is embedded in the overall management system of the company and sets the general goals for the SMS, the latter serving as basis for the risk/hazard analysis (as far as it concerns major accident hazards).



The operator has to produce MAPP as a written document, which deals specifically with the overall objectives and general principles of his procedures for limiting the risk of hazardous incidents. The document should specifically include the following points:

- Formulation of a company policy, which states that the prevention of hazardous incidents and the limitation of the effects of hazardous incidents which, despite all efforts do occur is a high priority in the company objectives.

- Presentation of the basic approach to implement this objective, for example in the form of guidelines which are part of company policy.

MAPP



The MAPP can be a much less detailed document than one which describes the Safety Management System but should clearly indicate the arrangements, structures and management systems required for each of the seven areas.

A MAPP is not a mini safety report and should refer to other detailed documentation where necessary. Indeed there will normally be a hierarchy of documentation: at the top of this hierarchy the MAPP sets out the policy and principles of majorhazard prevention, and then each subsequent level explains in more detail the application of these principles, finishing with working documents and instructions.

MAPP



MAPP -CORPORATE/COMPANY POLICIES AND GUIDELINES

The corporate policy is the basis for the measures to be outlined . In larger companies, it may be appropriate to complement the corporate policy,which is usually formulated in rather general terms, with guidelines thatshow predominantly the company’s strategy for achieving certain protection goals.

The corporate policy should not only make clear what the company is trying to achieveexternally, but above all focus on this towards his own staff. Therefore it is recommended that staff, or staff representatives, are involved in the policy formulation process from the beginning, and that the policy's validity is confirmed by signatures of the company management.

MAPP



Policy.It is recommended that management signs the relevant documents. In addition to the company policies and any accompanying guidelines,MAPP must also state:

a) what risks of hazardous incidents are present in the establishment;b) what provisions have been made for preventing these, or limiting their effects; c) in which way it is ensured that these measures are implemented properly.

a) and b) are supplied in other sections of the safety report, particularly in theinstallation-specific safety analysis. c) Refers to the presentation of the safety management system which is dealt with seperately

MAPP



a) HAZARD POTENTIAL IN THE ESTABLISHMENT - what risks of hazardous incidents are present in the establishment-The basis of all considerations is the identification of possible hazards. The regulations emphasize on major accidents (hazardous incidents). Basic details for the identification and evaluation of hazards are supplied in the notification procedure, which should be included asa copy. A reference on this document is possible.In this section it should be clarified which hazards can originate in the establishment. To do this, the possible hazards should be specified and evaluated with regard to their relevance to safety.The following factors in particular should be taken into consideration:Geographical location (sensitive/susceptable areas)Substances (complete list)Type of process or activity (selected for MAHs)

MAPP



b) TECHNICAL AND ORGANISATIONAL MEASURES TO PREVENT OR LIMIT THE CONSEQUENCES OF MAJOR ACCIDENTS (1)- what provisions have been made for preventing these, or limiting their effects

In this section, the operator should explain the basic measures proposed to reduce and control the hazard potential described in the previous section, and to limit the consequences of a hazardous incident. These measures can be of technical and/or organisational nature.

Reference should also be made, if applicable, to other relevant documents, such as licences,permits. It is, however, strongly recommended that the operator makes clear in this section, which priorities are set in applying the safety policyto meet the general obligations of the regulations

MAPP



The following factors may be important when determining and presenting technical safety related measures:- Safety-related construction and design characteristics of installation components,such as the material used (e.g. steel, glass or graphite), as well as location andoverall design of these components.- Safety-related maintenance at the establishment/installation.- State-of-the-art of safety technology, regulations, standards, guidelines, etc. whichmust be observed.

b. TECHNICAL AND ORGANISATIONAL MEASURES TO PREVENT OR LIMITTHE CONSEQUENCES OF MAJOR ACCIDENTS (2)

MAPP



Measures to prevent, and limit the effects of events which could cause major accidents, may include:- process control systems to prevent excessive pressure or temperatures;- safe containment of hazardous substances;- safety valves;- measures to avoid explosive atmospheres (e.g. inertisation);- measures to avoid sources of ignition (for example, using electrical installations according to qualified, i.e. standardised, categories of explosion protection,grounding);- fire prevention measures;- defensive and constructional fire protection measures;- equipment of constructional explosion protection, such as rupture disks, explosion flaps and explosion suppression systems;- rapid closure devices;- spillage-collection facilities;- sprinkler systems;- gas detectors; and- water/steam curtains.

b. TECHNICAL AND ORGANISATIONAL MEASURES TO PREVENT OR LIMITTHE CONSEQUENCES OF MAJOR ACCIDENTS (3)

MAPP



c) in which way it is ensured that these measures are implemented properly.

The structure of the organisational measures is based on the principles for a Safety Management System (SMS) (only structure; not detailed; reference to be made to SMS procedures).

In general, the technical and organisational measures of the operator have to provide the premises of meeting all legal requirements (laws, ordinances, accident prevention regulations, permits and legal conditions). This particularly includes measures, which guarantee that the operator’s documentation is in line with the current situation.

MAPP



Q 1 Does the MAPP exist as a written document?Q 2 Does the senior management show commitment to the MAPP,

e.g. through signature?Q 3 Has the MAPP been communicated to the workforce?Q 4 Is the MAPP communicated to contractors and third parties

undertaking activities on site?Q 5 How does senior management review the MAPP

MAPP

MAPP QUESTIONS - CHECK



MAPP and SMS should address the following issues:

1. organisation and personnel2. identification and evaluation of major-accident hazards3. operational control4. management of change5. planning for emergencies6. monitoring performance7. audit and review

SMS



Elements of Safety Management System (SMS)A safety management system (SMS) is a set of activities that ensures that hazards are effectively identified, understood and minimised to a tolerable level.

In this sense, it may be regarded as the transposition of the general goals identified in the Major Accident Prevention Policy (MAPP) into specific objectives and procedures.



The MAPP is embedded in the overall management system of a company or site. The MAPP sets the general goals for the SMS, the latter serving as basis for the risk/hazard analysis (as far as it concerns major accident hazards).

reference: http://www.uba.de/uba-info-medien-e/4510.html .



In practice a SMS consists of a compilation of written principles, plans, formal organisation charts, responsibility descriptions, procedural recommendations, instructions, data sets etc (character of “underlying documents”)For the purpose of a safety report, the description of the SMS is of a summarising character and should address the following subsets. It shall at least consist of:

• The major accident prevention policy (MAPP);• An explanation of the relationship of the MAPP to the site-specific aims and safety-related objectives;• Explanations in generic terms concerning how these objectives are met, especially with respect to consistency between the approaches followed and the measures taken.



It is useful to link the SMS to other existing or planned management systems in the company. If a holistic management system is already in place, the SMS should be integrated into it.This allows the operator to take company specific factors into account, for example, the SMS can be integrated into existing managements systems which comply with e.g. ASCA-based systems, ISO 9000 ff, ISO 14001, EMAS



1. ORGANISATION AND STAFFEstablishing the principal responsibility of the operatorThe operator, i.e. the management, is responsible for devising the SMS and for ensuring it is adhered to.Structural organisationThe structural organisation of the SMS must be detailed, providing a clear assignation of tasks, functions and competences at the different levels of the company. Organisation charts and job descriptions are particularly suitable for this task.Establishment organisationDetails must be given of the principle used in the SMS to deal with establishment Processes in order to comply with the regulations (particularly establishment processes which cover more than one function or department). This covers establishment processes throughout the SMS, so detailed descriptions are not necessary in this section.CommitteesQualifications and trainingInvolvement of staff and where appropriate of third parties and subcontractors



2. IDENTIFYING AND ASSESSING THE RISK OF HAZARDOUS INCIDENTSThe SMS must ensure that the potential for hazardous incidents is identified and that the probability and severity of these incidents is assessed. Suitable systematic methods should be used to achieve this. All sections of the establishment, and where appropriate external sources of potential hazards, are to be taken into account. Appropriate measures should be taken on the basis of the risk assessment.The SMS provides the more detailed definitions on which the identification and assessment of risks of major accidents are based

Ref. Hazid (with Hazop. DOW, What if etc)Ref. Hazard & Scenario Analysis (Fault tree, Event tree, Bowtie etc.)

Descriptions of how the outcomes of hazard identification and risk assessment have been used to determine the physical control measures and management risk control systems needed for the prevention and mitigation of major accidents.



3. OPERATIONAL CONTROL (1)

General The SMS must ensure that for all safety-related procedures:- there are written work and operating instructions;- staff are informed in writing or orally in an appropriate way;- the work and operating instructions are exercised in practice where necessary; & - are monitored, to see whether they are reasonable and viable, and whether they are obeyed

The inclusion of temporarily employed staff, outside companies and subcontractors should be taken into consideration when drawing up work and operating instructions. When drawing up this section of the SMS, it is important to remember that work and operating instructions are required under a number of other national regulations.



Work and operating instructionsWork and operating instructions can be related to the workplace, the activity, or thesubstances handled. According to context and validity, they should resolve the followingissues in particular:- competence and responsibility;- start of the installation or facility;- normal operation of installations, facilities and work materials;- handling of hazardous substances and preparations;- recognising disruptions, procedure for establishing the cause and both methods andresponsibility for resolving the disruptions (return to normal operation);- fixed-term or special operating circumstances;- operation during maintenance and cleaning;- close down of the installations and facilities under normal conditions;- procedures for installation stoppages; and- procedure in the event of operational disruptions and in emergencies, includingemergency stoppages, first aid procedures and appropriate disposal of wastes.

Where there are extensive procedures and protection measures, it has always beenworthwhile to expand work and operating instructions with checklists or step-by-step lists (see system UK)




Training

The SMS should ensure that not only there is regular training on the content of the operatingand working instructions, but special instructions are provided:- before new or modified installations, facilities or work materials begin to operate;- before new or transferred staff take up related functions;- before processes, establishments or working arrangements are modified;- before different substances or operating media are used;- before major disconnections, closures or other activities which are particularly hazardous;- after incidents involving accidents, damage or emissions;- when legal requirements have an effect on establishment processes; and- in the event of any other changes which have to be made to the operating and work instructions, for whatever reason.




4. MANAGEMENT OF CHANGE (1)

The following issues shall be addressed by the safety management system:Management of change - adoption and implementation of procedures for planning modifications to, or the design of new installations, processes or storage facilities.



The operator should adopt and implement management procedures for planning and controlling all changes in people, plant, processes and process variables, materials, equipment, procedures, software, design or external circumstances which are capable of affecting the control of major accident hazards. This approach should cover permanent, temporary and urgent operational changes, and should address:• definition of what constitutes a change• assignment of responsibilities and authorities for initiating change• identification and documentation of the change proposed and of its implementation;• identification and analysis where appropriate of any safety implications of the change proposed;• definition, explanation where appropriate, documentation, and implementation of the safety measures deemed appropriate, including information and training requirements, as well as the necessary changes to operational procedures;• definition and implementation of appropriate post-change review procedures and corrective mechanisms, and subsequent monitoring.

4. MANAGEMENT OF CHANGE (2)



5. PLANNING FOR EMERGENCIES

Implementing the emergency plansThis section of the SMS contains a description of the procedure for identifying foreseeableemergencies, and for drawing up, testing and reviewing the internal emergency plans (alertand disaster control plans), and for the identification and passing on of information requiredfrom the operator for drawing up external emergency plans.The SMS should determine the following, in particular:- The procedure for identifying foreseeable emergencies, based on a systematicanalysis (scenarios). This must ensure that all installations and storage facilities aresystematically examined for potential technical, organisational or human failureswhich could cause an emergency situation.- The group of people who will carry out this analysis. Teamwork is recommended. Inthe event of insufficient internal expertise, outside resources have to be brought in.- The different competences for carrying out the analysis, and for devising, testing andreviewing the resultant emergency plans.- The procedure for devising internal emergency plans.



6. MONITORING PERFORMANCE

Relevant text from the Directive:The following issues shall be addressed by the safety management system:Monitoring performance - adoption and implementation of procedures for the ongoing assessment of compliance with the objectives set by the operator’s major accident prevention policy and safety management system, and the mechanisms for investigation and taking corrective action in case of non-compliance. The procedures should cover the operator’s system for reporting major accidents or near misses, particularly those involving failure of protective measures, and their investigation and follow-up on the basis of lessons learnt.



The operator should maintain procedures to ensure that safety performance can be monitored and compared with the safetyobjectives defined.

This should include determining whether plans and objectives are being achieved, and whether arrangements to control risks are being implemented before an incident or accident occurs (active monitoring), as well as the reporting and investigation of failures which have resulted in incidents or accidents (reactive monitoring).

6. MONITORING PERFORMANCE (2)



Active monitoring should include inspections of safety critical plant, equipment and instrumentation as well as assessment of compliance with training, instructions and safe working practices.Reactive monitoring requires an effective system for reporting incidents and accidents and an investigation system which identifies not only the immediate causes but also any underlying failures which led to the event. It should pay particular attention to cases of failure of protective measures (including operational and management failures), and should includeinvestigation, analysis, and follow-up (including transfer of information to personnel involved) to ensure that the lessons learnt are applied to future operation.

The information from performance monitoring should also be a significant input to the processes of audit and review (see next slides)

6. MONITORING PERFORMANCE (3)



7. AUDIT AND REVIEW (1)

Relevant text from the Directive:The following issues shall be addressed by the safety management system:Audit and review - adoption and implementation of procedures for periodic systematic assessment of the major accident prevention policy and the effectiveness and suitability of the safety management system; the documented review ofperformance of the policy and safety management system and its up-dating by senior management.



The terms “audit” and “review” are used here for two different activities.

An audit is intended to ensure that the organisation,processes, and procedures as defined and as actually carried out are consistent with the Safety Management System; It should be carried out by people who are sufficiently independent from the operational management of the unit being audited to ensure that their assessment is objective.

A review is a more fundamental study of whether the Safety Management System Is appropriate to fulfil the operator’s policy and objectives, and may extend to considering whether the policy and objectives should themselves be modified.




Audit (1)In addition to the routine monitoring of performance, the operator should carry out periodic audits of its SMS as a normal part of its business activities. An audit should determine whether the overall performance of the Safety Management System conforms to requirements, both external and those of the operator. The results of these audits should be used to decide whatimprovements should be made to the elements of the SMS and their implementation.

For this purpose the operator should adopt and implement an audit plan covering items 1-6.




The audit plan, which should be reviewed at appropriate intervals, should define:• the areas and activities to be audited;• the frequency of audits for each area concerned;• the responsibility for each audit;• the resources and personnel required for each audit, bearing in mind the need for expertise, operational independence, and technical support;• the audit protocols to be used (which can include questionnaires, checklists, interviews both open and structured,measurements and observations);• the procedures for reporting audit findings;• the follow-up procedures.

Audit Plan(2)7. AUDIT AND REVIEW (4)



ReviewSenior management should, at appropriate intervals, review the operator's overall safety policy and strategy for the control of major-accident hazards, and all aspects of the SMS to ensure its consistency with these. The findings of the monitoring and of the audit are to be specifically included.

This review should provide information to determine whether the policy or the objectives themselves need to be modified.

This review should also address the allocation of resources for SMS implementation, and should consider changes in the organisation as well as those in technology, standards, and legislation.




Q .1 Is the organisation of the facility documented, the process safety related units roles and responsibilities clearly identified?Q .2 Have processes for identifying and monitoring the process safety requirements on personnel and their roles and responsibilities been developed?Q .3 Have processes for the identification of hazards and assessment of their risks been defined?Q .4 Have processed been defined for the communication of the results from hazard identification and risk assessment?Q .5 Do processes exist for addressing changes in documents as a result of changes?Q .6 Do processes exist for developing internal emergency plans?Q .7 Do processes / procedures exist for training / drills related to the internal emergency plan?Q .8 Are there complete processes and procedures in place for monitoring compliance with defined requirements?Q .9 Does an accident reporting mechanism exist?Q .10 Is a process defined for regular audits?Q .11 How does senior management review the MAPP and the SMS?

SMS - QUESTIONS - CHECK



REFERENCES

Sectoral Checklist for preparation and inspection of a Safety Report.UNECE Convention on the transboundary effects of industrial accidents & the EU Directive 96/82/EC (SEVESO II) by a consistent Checklist SystemThis publication is only available online. It can be downloaded as ANNEX 3from http://www.uba.de/uba-info-medien-e/4510.html .

Guidelines on a Major Accident Prevention Policyand Safety Management System,as required by Council Directive 96/82/EC (SEVESO II). Neil Mitchison & Sam Porter (Eds.)ISBN92-828-4664-4

Guidance on the preparation of a Safety Report to meet the requirements of Directive 96/82/EC as amended by Directive 2003/105/EC (SEVESO II).Luciano Fabbri, Michael Struckl and Maureen Wood (Eds.), 2005.ISBN 92-79-01301-7

background and content major accident prevention policy (mapp) and safety management system (sms)

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