Health and Safety Executive

Health and Safety Executive

Major Accident Hazards

Linda Donachie

HM Principal Inspector of

Health and Safety

What I will cover…………………

COMAH SITES AND MAJOR ACCIDENT PREVENTION

REGULATION OF COMAH SITES

THE ROLE OF THE CONTRACTOR IN PREVENTION OF MAJOR ACCIDENTS

ANY GENERAL QUESTIONS

What is a contractor?

• Temp workers/Agency workers

• Specialists – IT, C&I, Electrical, NDT

testing of tanks, PSSR/LOLER examiners

• Consultants – Assistance with Safety

reports etc

• Water treatment company (cooling tower

management)

• Construction projects

WHY COMAH ?

To protect people and the environment from

the effects of major accidents

Devecser Hungary

Major Accidents involve……..

• A dangerous substance

• A loss of control

• Serious harm or risk of serious harm to

people and

environment…………………….

• SHOW DVD

Examples of major accidents

• Flixborough 1974

• Buncefield 2005

• Terra Nitrogen 2006

THE REGULATORY APPROACH

Inspection

Safety Report Assessment

Investigation

Stakeholder engagement

……….leading to

»Advice

»Enforcement

»Prosecution

Regulation

• Control of Major Accident Hazard

Regulations 1999 (as amended)

- the operator of a COMAH site shall take

all measures necessary to prevent major

accidents and limit their consequences to

people and the environment-

- parallel duties on other organisations that

work on site (under HSAWA)

Planning controls

Major Hazard Management Systems

People Processes

Plant

Risk Assessment

Risk Profile

Loss of Control

OutcomeMAJORHAZARD

Preventive Barriers Mitigation Barriers

Determine the Control Measures (Barriers)

Major Hazard Control Measures (Barriers)

Potential

Impact/

Consquences

Probability

Challenges to

Integrity or

Containment

Corrosion

High/LowPressure

Overfilling

Human Error

Physical Damage

High/LowTemperature

CHECK,MEASURE& REVIEW

Leading & lagging indicators to measure performance of control

measures

Audit Programme to check the design and suitability of control

measures

Investigate loss of containment events and major hazard incidents to identify failures in the control

measures

MAJOR HAZARD MANAGEMENT

(the big picture)

Hazard IdentificationProcesses or

Activities

Undertaken

Hazardous-

Property:

Condition

Volume

Activity/ Processes:

Storage

Reacting

Separating, Distillation

Mixing, Blending

Product Transfer

Propagating

Concentrating

Plant Life

CycleStart-up

Operate

Modify

Shutdown

Toxic

Flammable

Reactive

Corrosive

Explosive

Infectious

Temperature

Pressure

Solid

Liquid

Gas

Intrinsic Hazard

Physical PropertyFor example:

Stage in Plant Life Cycle – where relevant

LeadershipTo set an effective vision

ans culture for major hazard management

©

Barriers are a combination of PPP People Processes

Plant

Loss of

ContainmentOutcomeMAJOR

HAZARD

Preventive Barriers Mitigation Barriers

Process Safety Control Measures (Barriers)

PLANT INTEGRITY

• INSPECTION

• MAINTENANCE

PROCESSES

• CONTROL SYSTEMS

• REMOTE ISOLATION

PEOPLE

• PERMIT TO WORK

• SAFE PROCEDURES

• COMPETENCE

BP Texas City

Deepwater Horizon

Terra Nitrogen 2006

RISK ASSESSMENT

PROCESS

MAINTENANCE REGIME

SELECTION OF

CONTRACTOR

QUALITY OF SITE WORK

AUDIT/REVIEW PROCESS

LATENT FAILURE

LOSS OF CONTAINMENT OF

HYDROCARBON

Scaffolders working on petrochemicals plant

suffered effects of inhalation of

hydrocarbons in the area they were working

in when a small instrument branch line

appeared to have sheared off and 3 tonnes

of highly flammable liquids was lost to

atmosphere.

LOSS OF CONTAINMENT OF

HYDROCARBONS

Conclusions

• Activities undertaken on behalf of the operator by contractors are a fundamental part of the operation of most COMAH establishments

• Contractors form an integral part of the overall safety management system and should be accorded the same respect/standards as employees in the work they are required to do

• Are often at the “sharp end” of an incident

• Contractors should be proactive in identifying whether their work forms part of a safety critical plant and process

Guidance

• HSG159 – Managing contractors –

A Guide for Employers

• INDG368(rev1) Using Contractors -

A Brief Guide

• http://www.hse.gov.uk/humanfactors

/topics/contractorisation.htm

• http://www.hse.gov.uk/humanfactors

/topics/customers.htm

www.hse.gov.uk