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Safety and environmental standards for fuel storage sites

Final report

177

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