Safety and environmental standards for fuel storage sites
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262 Used effectively process safety indicators can provide an early warning, before catastrophic
failure, that critical controls have deteriorated to an unacceptable level. The use of process safety
performance indicators fits between formal, infrequent audits and more frequent inspection and
safety observation programmes. It is not a substitute for auditing, but a complementary activity.
263 The main reason for measuring process safety performance is to provide ongoing assurance
that risks are being adequately controlled. In order to measure safety performance, many
dutyholders have incorporated leading and lagging indicators, also known as ‘metrics’ or ‘key
performance indicators’, into their safety management systems. Managers use these metrics to
track safety performance, to compare or benchmark safety performance.
264 Many organisations rely on auditing to highlight system deterioration. However, audit intervals
can be too infrequent to detect rapid change, or the audit may focus on ‘compliance’, ie verifying
that the right systems are in place rather than ensuring that systems are delivering the desired
safety outcome (see HSG254).
265 Many organisations do not have good information to show how they are managing major
hazard risks. This is because the information gathered tends to be limited to measuring failures,
such as incident or near misses. System failures following a major incident frequently surprise
senior managers, who believed the controls were functioning as designed (see HSG254).
API RP 754 on process safety performance indicators
266 Recommendation 10 of the MIIB’s Design and operations report asks the sector to ‘agree
with the CA on a system of leading and lagging performance indicators for process safety....in line
with HSG254’. This is similar to the US Chemical Safety Board’s (CSB’s) recommendation post-
Texas City asking ‘API, ANSI, USW to develop a new consensus ANSI standard which identifies
leading and lagging indicators for nationwide public reporting as well as indicators for use at
individual facilities. Include methods for the development and use of performance indicators’.
267 Given the multinational nature of the industry there are clear advantages to a common
approach internationally, capable of consistent use throughout an international company and
across refining, chemical and storage sectors, and it was agreed that on behalf of PSLG, UKPIA
should accept API’s invitation to participate in the committee to develop the standard, known as
RP 754. HSE’s guidance HSG254 is well-recognised in the US, and this theme has been further
developed in guidelines published by the Centre for Chemical Process Safety in December 2007.
268 The API committee has sought to build on the CCPS guidelines and develop a standard
for ballot and completion by end 2009. The model of a ‘safety triangle’ has been successful in
helping improve the management of occupational safety, and the model proposed for process
safety involves four tiers – ie significant events, other lesser loss of containment, challenges to
safety systems, and management system issues. The lower tiers represent near misses and are
likely to be helpful indicators.
Guidance
Active monitoring
Active monitoring is primarily a line management responsibility (see HSG65). It should be distinguished
from the requirement for ‘independent’ audits, which are a separate activity. HSG65 refers to auditing
as the structured process of collecting independent information on the efficiency, effectiveness, and
reliability of the total health and safety management system, and drawing up plans for corrective action.
269 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.
270 Active monitoring gives an organisation feedback on its performance before an incident
occurs. It should be seen as a means of reinforcing positive achievement, rather than penalising




