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Safety and environmental standards for fuel storage sites
Final report
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44 The evaluation of the SMS efficiency is based on:
(a) the identification of the safety barriers in the technical system;
(b) the assessment of the SMS using an audit; and
(c) an assessment of safety culture using questionnaires.
The results from (b) and (c) are processed and modify the nominal reliability of the safety barriers,
thereby linking the quality of the SMS with the quality of the barrier.
Summary
45 Dutyholders should ensure that they have suitable techniques to demonstrate and assess their
layers of protection for prevention and mitigation of major accident scenarios.
46 Dutyholders should update their COMAH safety reports in the light of current guidance on extent
and severity, and to describe the process for identification and assessment of control measures.
Roles, responsibilities and competence
47 Clear understanding and definition of roles and responsibilities, and assurance of competence
in those roles, are essential to achieve high reliability organisations for the control of major
accident hazards.
48 The final Buncefield MIIB Report
84
makes a specific recommendation for the sector to
prepare guidance for understanding and defining the roles and responsibilities of control room
operators (including in automated systems) in ensuring safe transfer operations. It also makes a
recommendation regarding supervision and monitoring of control room staff.
49 Problems have also been found, in the past, with competence assessment in the UK
hazardous industries sector. A review of practices in 2003 indicated that there was a wide
variation in standards (RR086
85
). In some cases companies had developed systematic
approaches, and made explicit links to the COMAH risk assessment. Others relied on
unstructured on-the-job reviews.
50 Elsewhere, the gas plant explosion in Longford, Australia (Lessons from Longford
86
) is an
example of a major incident in which organisational changes and a lack of skills or knowledge led
to errors that contributed to the incident.
51 Organisational changes such as multi-skilling, delayering or downsizing, in which staff are
expected to take on a wider range of responsibilities with less supervision, increase the need to
assure competence.
52 Dutyholders have a responsibility to ensure their medical (including mental) and physical fitness
standards are suitable for the risks involved (see Human Factors Briefing Note No 7 Training and
competence
87
). Fitness may be impaired through, for example, drink, drugs or fatigue.
Guidance on roles and responsibilities
53 COMAH guidance L111 identifies a range of personnel for which the roles, responsibilities,
accountability, authority, and interrelation of personnel should be identified. They include all those
involved in managing, performing or verifying work in the management of major hazards, including
contractors.