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Safety and environmental standards for fuel storage sites
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setting and reviewing of process safety performance indicators;
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investigation procedures/analysis of underlying causes;
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sharing of lessons learned;
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emergency procedures/testing of emergency plans;
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review arrangements/improvement plans.
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302 Such audits are formal and infrequent. Dutyholders may decide to audit a small range of
activities on a more frequent basis (eg yearly), or a more extensive range on a less frequent basis
(eg 3–5 years). The dutyholder should decide the range and scope of its audit programme, taking
into account such factors as audits/inspections imposed by others (eg the CA, parent companies
or joint venture partners, insurers, trade associations), and the extensiveness of the active
monitoring programme.
303 Audits that focus primarily on ‘compliance’ (ie verifying that the right systems are in place
rather than ensuring that they deliver the right safety outcome) are not sufficient.
Guidance on review
304 Reviewing should be a continuous process undertaken at different levels in the organisation.
An annual review should be the norm, but dutyholders may decide on a system of intermediate
reviews at, for example, department level. The result should be specific remedial actions which
establish who is responsible for implementation, with deadlines for completion.
305 Issues to be considered in the review process include:
the major accident prevention policy;
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audit programme achievement and findings;
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active monitoring records and findings;
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process safety performance indicators;
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incident/near miss history;
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relevant lessons from incidents etc elsewhere;
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analysis of root/basic causes of incidents and near misses;
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issues from safety committees;
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tracking of safety actions;
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risk assessment status, including reviews against changing standards.
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Summary
306 Dutyholders should adopt and implement audit plans defining:
the areas and activities to be audited, with a particular focus on process; safety/control of
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major accident hazards;
the frequency of audits for each area covered;
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the responsibility for each audit;
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the resources and personnel required for each audit;
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the audit protocols to be used;
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the procedures for reporting audit findings; and
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the follow-up procedures, including responsibilities.
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307 Dutyholders should ensure that they have implemented suitable arrangements for a formal
review of arrangements for control of major accident hazards, including:
the areas and activities to be reviewed, with a particular focus on process safety/control of
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major accident hazards;
the frequency of review (at various levels of the organisation);
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responsibility for the reviews;
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the resources and personnel required for each review;
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procedures for reporting the review findings; and
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arrangements for developing and progressing improvement plans.
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