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Safety and environmental standards for fuel storage sites

Final report

178

failure after the event. It includes monitoring the achievement of specific plans and objectives, the

operation of the SMS, and compliance with performance standards. This provides a firm basis for

decisions about improvements in risk control and the SMS.

271 Dutyholders need to decide how to allocate responsibilities for monitoring at different levels

in the management chain, and what level of detail is appropriate. In general, managers should

monitor the achievement of objectives and compliance with standards for which their subordinates

are responsible. Managers and supervisors responsible for direct implementation of standards

should monitor compliance in detail. Above this immediate level of control, monitoring needs to be

more selective, but provide assurance that adequate first line monitoring is taking place.

272 Various forms and levels of active monitoring include:

examination of work and behaviour;

systematic examination of premises, plant and equipment by managers, supervisors,

safety representatives, or other employees to ensure continued operation of workplace risk

precautions;

the operation of audit systems;

monitoring of progress towards specific objectives, eg training/competence assurance

objectives.

273 Many of these topics are not specific to process integrity, but are equally applicable to all

areas. Topics of particular relevance to process integrity include:

change control;

process safety study (eg HAZOP or PSA) close out;

control of process plant protection systems/inhibits etc;

control of alarms/alarm system status;

operating procedures, including consignment transfer procedures and stock reconciliation

procedures;

shift handover procedures;

management of fatigue and shift work;

maintenance of safety-critical systems;

control of contractors.

274 They should also include other key systems that are equally relevant to preventing a major

incident, such as:

workplace risk assessments;

permit to work systems;

isolation standards;

controls at high pressure/low pressure interfaces;

control of relief devices etc.

Reactive monitoring

275 Reactive monitoring involves identifying and reporting on incidents to check the controls in

place, identify weaknesses and learn from mistakes (see L111 and HSG65). It includes:

identification and analysis of injuries/causes of ill health;

identification and analysis of other incidents, near misses, and weaknesses or omissions in

performance standards;

assessing incident/near miss potential;

investigation and identifying remedial actions to deal with root causes;

communication of lessons learned;

tracking of remedial actions arising from incidents/near misses etc;

contributing to the corporate memory.