CDOIF Guidance

Safety and environmental standards for fuel storage sites

Final report

146

management of change;

––

operational readiness;

––

conduct of operations;

––

emergency management.

––

Learn from experience:

■

incident investigation;

––

measurement and metrics;

––

auditing;

––

management review and continuous improvement;

––

implementation (of a risk-based process safety management system).

––

25 The HSE internal document

Process safety management systems

also identifies principles

of process safety management. Although intended for process safety management of offshore

installations, many of the principles are equally applicable onshore. Key points are:

There is no single ‘correct’ model of a process safety management system; some companies

■

have separate safety management systems for different sites, whereas others may adopt a

more functional approach.

Some companies give greater emphasis than others to corporate procedures. Each should

■

adopt arrangements that are appropriate for its business and culture.

In principle, different standards and procedures could be used within each of the sites or

■

functions. In practice, however, systems need to be developed within the constraints of the

corporate SMS, and there will inevitably be areas of overlap.

There is no legal requirement for a company to have a policy statement that is specific to

■

process safety management, but it is recognised good practice, and helps to define the

management requirements.

A good policy statement, or supporting documentation, would indicate the organization’s

■

approach to process safety management. This would include commitment to matters such as:

principles of inherent safety;

––

a coherent approach to hazard and risk management;

––

communication of the hazard and risk management process;

––

ensuring competence, and adequacy of resources;

––

recognition of the role of human failure – particularly unintentional human failure – on

––

process safety;

assurance that the reliability of process safety barriers that depend on human behaviour

––

and performance are adequately assessed;

working within a defined safe operating envelope;

––

careful control of changes that could impact on process safety;

––

maintaining up to date documentation;

––

maintenance and verification of safety critical systems;

––

line management monitoring of safety critical systems and procedures;

––

setting of process safety performance indicators;

––

independent audits of management and technical arrangements;

––

investigation and analysis of incidents to establish root causes;

––

reviewing process safety performance on a regular (eg annual) basis;

––

continuous improvement, with regularly updated improvement plans;

––

principles of quality management, eg ISO 9000.

––

26 The COMAH Regulations require dutyholders to set out a Major Accident Prevention Policy

(MAPP). This would be the logical place to record policies relating to process safety management.

Dutyholders also need to ensure that they have effective arrangements to implement each

element of the policy.

Summary

27 Dutyholders should ensure they have implemented an integrated and comprehensive

management system that systematically and continuously identifies, reduces and manages

process safety risks, including risk of human failure.