the safety case journey for singapore - wsh institute · hazard identification process ... process...
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A Great Workforce A Great Workplace
© 2015 Government of Singapore
The Safety Case Journey for Singapore
Jaime Lim Sr Assistant Director (Major Hazard Installations)
OSH Specialist Department Ministry of Manpower
WSHI ICES MOM 27 Nov 2015
© 2015 Government of Singapore
Background
How we got here
Our implementation plans ahead
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Presentation Outline
© 2015 Government of Singapore
Major Hazard Installations (MHIs)
• Fixed installations, including petroleum refining and manufacturing facilities, chemical processing plants and facilities where large quantities of toxic and flammable substances are stored or used
• The likelihood of a major accident for such installations is low due to the stringent workplace safety and health management system in place
• The complex operating environment and high inventory of hazardous chemicals means that any incident can potentially result in catastrophic consequences
Background
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© 2015 Government of Singapore
MHI Study Mission – May 2013
Key Recommendations:
1. Better coordination among regulating agencies
2. Better integration of safety protocols/requirements at MHI level e.g. safety case
3. Better management of domino effect risks
4. Enhanced capability building initiatives for regulators /industry
5. Structured process to share lessons learnt from MHI incidents
Visited Germany, United Kingdom and Netherlands to study how these countries manage MHIs
CAs are better able to identify gaps and monitor potential domino effects within MHI clusters
Competent Authorities (CAs) cooperate and coordinate efforts to manage risks posed by MHIs
Safety Case consolidates and demonstrates to authorities the integration of their various SHE* protocols
* Safety, Health and Environment 4
© 2015 Government of Singapore
Inter-Agency Taskforce for Major Hazard Installations (IAT-MHI)
Chaired by MOM with Director-Level representatives from
MEWR, MHA, MOM, MTI, NEA, SCDF, EDB & JTC
Review of Regulatory Framework for MHIs
In Mar 2014, MOM set up an Inter-Agency Taskforce to review and enhance existing regulatory framework for MHIs to be in line with international best practices
• Introduce Safety Case regime for MHIs
• Establish the National MHI Regulatory Office (NMRO)
In Dec 2014, IAT-MHI completed review & recommended:
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© 2015 Government of Singapore
Regulatory Framework for MHIs
Shifting away from Prescriptive One-Size-Fits-All Regulatory Approach
• Greater flexibility for MHIs to tailor risk mitigating measures to best suit needs • MHIs to take on greater responsibilities, proactively identifying & managing
SHE risks
Safety Case regime where MHIs integrate all SHE protocols onsite Demonstrate to regulators that MHI risks have been reduced to as low as
reasonably practicable (ALARP)
Effect Safety Case Regime
• Introduce MHI Regulations under the Workplace Safety and Health Act • Share pertinent information among MHIs when needed, to mitigate potential
domino effect in the event of a major incident, allowing neighbours to take the risks into account in their risk management and emergency response planning
National MHI Regulatory Office (NMRO) • Setting up NMRO, to better coordinate Safety Case assessments, inspections
and investigations • Led by MOM, the NMRO will also consist of officers from SCDF and NEA and
will serve as a single regulatory front for MHIs on SHE matters 6
© 2015 Government of Singapore
A Case which an MHI makes to the regulators, setting out how risks from major accidents hazards can be reduced to ALARP*, ensuring safe operations in a sustainable manner
* ALARP: As Low As Reasonably Practicable
What is a Safety Case?
A Safety Case includes details of:
Hazard identification process
Identification of hazards with the potential to cause major accidents
Evaluation of major accident risks
System/procedures put in place to control them
Measures to limit major accident consequences
MHIs to convince the regulators that the strategy for managing safety is satisfactory, through the adoption of ALARP principle
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© 2015 Government of Singapore
• Safety Case is an MHI regulatory tool used in European Union United Kingdom, Germany, Netherlands and Norway
• In the wake of the 1998 Longford gas plant incident, Australia has also implemented Safety Case to enhance oversight of MHIs
• Safety Case is also implemented in ASEAN countries, Malaysia and Brunei
• US Chemical Safety Board (CSB) broached the issue of adopting the Safety Case Regime following the 2012 Chevron Refinery fire
Countries with Safety Case Regime
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© 2015 Government of Singapore
Safety Case implemented in UK since 1984
• Seveso Directive, with subsequent revisions
Control of Major Accident Hazards (COMAH) Regulations require MHIs to
• Take all necessary measures to prevent major accidents involving dangerous substances
• Limit the consequences to people and the environment of any major accidents which do occur
Regulated by Competent Authorities (HSE jointly with Environment Agencies)
COMAH in the United Kingdom
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© 2015 Government of Singapore
“The need for the COMAH regulations is clearly
accepted by industry – being critical both to
managing the hazards and for maintaining public
confidence.”
“Since the introduction of the OHS (Major Hazard Facility) Regulations in July 2000, WorkSafe has observed: • No major incidents since the 1998
Longford Explosion • In-depth regulatory inspections and
verifications are continuing to achieve assurance of safety at MHFs.”
Department for Business Innovation & Skills, UK Manager, Health and Safety Operations,
WorkSafe Victoria, Australia
Benefits of a Safety Case Regime
• Improved understanding of hazards and risks • Enhanced knowledge of technical & managerial controls
required to manage major accident hazards and risks • Better oversight by regulators
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© 2015 Government of Singapore
Safety Case Regime
Intention:
To cover industrial installations which pose a major potential hazard, to:
• Workforce
• Neighbouring communities
• The environment
due to the quantities and nature of substances they handle
Safety Case regime to be effected through the enactment of the Workplace Safety and Health (Major Hazard Installations) Regulations,
under the WSH Act
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© 2015 Government of Singapore
Type of Trade Activities
Chemical Types and Threshold Quantities
Definition of MHIs
Premises engaging in processing, manufacturing
and/or bulk storage of dangerous substances
specified in the Tables of Dangerous Substances
— Listed in the WSH (MHI) Regulations
The maximum quantities of dangerous substances
equal to or exceed threshold quantities as
indicated in the Tables of Dangerous Substances; or
The aggregation of the ratios of dangerous
substances equals to or exceeds one
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© 2015 Government of Singapore
• A single consolidated Safety Case
• ALARP demonstration • Integrate &
demonstrate robustness of all SHE protocols to regulators
• Sharing of domino information with neighbouring plants
• Reviewed once every 5 years
Single front, jointly regulated by MOM, NEA & SCDF
Proposed Safety Case Regime
Quantitative Risk
Assessment
(QRA)
Safety & Health
Management System
(SHMS) including PSM
Emergency Response
Plan
(ERP)
Process Hazard Analysis
(PHA)
Major Accident Prevention Policy (MAPP) establish guiding principles and action plans
to prevent major accidents
SAFETY CASE
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© 2015 Government of Singapore
Committee of Supply Debate
On 9 Mar 2015, MOM’s Senior Parliamentary Secretary, Mr Hawazi Daipi, announced in Parliament the introduction of WSH (MHI) Regulations and the establishment of NMRO
Announcement at Budget 2015
Managing Major Hazard Installations (MHI)
MOM will adopt a Safety Case regime where MHI Operators will need to
integrate all their Safety, Health and Environment protocols onsite, and
demonstrate to regulators that they have managed their risks to as low as
reasonably practicable. We will introduce a set of MHI Regulations under the
Workplace Safety and Health Act to effect the Safety Case regime. A
National MHI Regulatory Office will be set up in 2016 to better coordinate
Safety Case assessments, inspections and investigations.
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© 2015 Government of Singapore
• Single front, jointly regulated by MOM (Lead), NEA & SCDF, to be set up in mid-2016
• Oversee Safety, Health and Environment (SHE) matters in MHIs
• Receive and assess Safety Cases from MHIs
• Conduct onsite verification of Safety Cases
• Investigate MHI incidents
• Engage and outreach to MHIs
• Plan and coordinate multi-agency work, including QRA submissions
Major Hazards Department (MHD)*
Roles of MHD
* NMRO officially recognised as a government department 15
© 2015 Government of Singapore
Proposed Implementation Timeline
Mid-2015 onwards
• Safety Case capability building for regulators and MHI industry
• Develop Safety Case technical guidance, through Joint Gov-Industry Work Group (JWG)
• SC technical guidance to be published before enactment of WSH (MHI) Regulations
3Q 2017 to 3Q 2020 Phased-in Safety Case
submissions from MHIs
2015 2016 2017
Enact WSH (MHI) Regulations, to require Safety Case submissions by MHIs
3Q 2016
Safety Case regime for MHIs takes effect
3Q 2017
2018
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© 2015 Government of Singapore
Role of the SC JWG
• Support enhancement of Process Safety Regulatory Framework in Singapore by developing implementation proposals for Safety Case Regime
• Coordinate with SRMC/SCIC QRA Work Group to ensure revised QRA Guidelines are fit for adoption into Safety Case Regime
Safety Case Joint Gov-Industry Work Group (SC JWG)
Government Representatives
MOM Mdm Jaime Lim (Co-Lead)
SrAD (MHI)
SCDF LTC Ng Geok Meng Assistant Dir (HazMat)
Maj Lo Wai Mun Assistant Dir (Licensing)
NEA Mr Chen Fu Yi Sr Engineer (Central Building Plan)
Industry Representatives
SCIC
Mr Amit Bhatnagar (Co-Lead)
Singapore Refining Company
Mr Evert Klein ExxonMobil
Ms Gloria Wang Shell
Ms Agmer Lee Secretariat
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© 2015 Government of Singapore
SC JWG Deliverables
• Develop Technical Guidance for Safety Case regulatory regime Consistent with Seveso Directives
• Develop strategy to build industry capability in implementing Safety Case
• Identify potential opportunities to
harmonise Safety Case regime against existing regulatory requirements
• WSH (MHI) Regulations • Guide to MHI
Regulations
Safety Case Technical Guidance Document • Technical Guidance • Safety Case Assessment
Guide
By Regulatory Agencies
By JWG
Safety Case Joint Gov-Industry Work Group (SC JWG)
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© 2015 Government of Singapore
• Industry consultations indicate that MHIs understand the benefits of the Safety Case Regime and are receptive to it
• Agencies will continue to work closely with the industry to jointly develop guidelines, including technical guidance, for the Safety Case regime
• Future streamlining of existing SHE regulatory requirements for MHIs, with the introduction of Safety Case Regime
– With greater clarity of Safety Case requirements/implications, refinements can be made to further streamline existing regulatory requirements
Industry Feedback Thus Far…
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© 2015 Government of Singapore
• Safety Case allows MHIs flexibility to showcase ALARP demonstration and better management of domino effects
• Authorities will work together with MHIs to co-develop technical guidance on Safety Case
– SC JWG
• Single, coordinated regulatory front for Safety Case matters among MOM, NEA and SCDF
– MHD
• With the introduction of a Safety Case Regime, regulators are prepared to streamline existing regulatory requirements
In Summary…
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A Great Workforce A Great Workplace
© 2015 Government of Singapore
Thank You!
© 2015 Government of Singapore
# Description Key Components
1 Management system and organisation to prevent major accidents (a) MAPP includes MHI’s overall aims and principles of action
with respect to control of major accidents (b) SMS includes general management system and addresses:
• Identify and evaluate major hazards • Operational control and Management of Change (MOC) • Planning for emergencies • Monitoring performance
• Major Accident Prevention Policy (MAPP)
• Safety Management System (SMS)
2 Description of the MHI and its environment (a) Site description and location (b) Description of main activities and products, sources of
major accident risks and conditions under which major accidents could happen and preventive measures
(c) Description of processes and operating methods (d) Description of dangerous substances
• Description of MHI
• Hazard Identification
Key Components of a Safety Case
Existing requirements are in red
© 2015 Government of Singapore
# Description Key Components
3 Risk assessment and prevention methods (a) Detailed description of major accident scenarios
• Probability or conditions which they can occur • A summary of trigger events in each scenario • The causes being internal or external to the MHI
(b) Consequence assessment including extent and severity of identified major accidents
(c) Description of safety equipment and their technical parameters
• Quantitative Risk Assessment (QRA)
• Process Hazard Analysis (PHA)
• Prevention methods, risk controls, mitigation systems
4 Protection measures to limit consequences of an accident (a) Description of equipment installed to limit
consequences of major accidents (b) Organisation of alert and intervention (c) Description of deployable resources (internal or
external) (d) Summary of elements needed to draw up emergency
plans for Internal ERP and External ERP
Emergency Response Plan (ERP)
Key Components of a Safety Case
© 2015 Government of Singapore
# Description Key Components
5 ALARP demonstration, improvement plans
Including monitoring of process safety performance indicators (PSPIs)
ALARP Demonstration
6 Information sharing
Share appropriate information about the installation’s nature and extent of the overall hazard of major accidents with other installations in the cluster, to enable them to take into account of the aforesaid into their MAPP documents and on-site emergency plans
Info Sharing
Key Components of a Safety Case