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Safety and environmental standards for fuel storage sites
Final report
7
The recent Texas City and Buncefield incidents have moved industry and regulators beyond the
pure science and engineering responses to develop ways to prevent a recurrence. They have
caused us to also critically examine the leadership issues associated with delivering what has to
be excellent operation and maintenance of high-hazard processes.
The responses by industry and regulators to these incidents, and the recommendations arising
from their investigations, are essential to ensuring they never happen again. Such responses
need to be effective and measured, requiring a dialogue between industry and the community to
determine the balance between risk prevention, the viability of the operations and their value to
society. In this regard the regulators are the effective representatives and arbiters for society.
The formation of the Process Safety Leadership Group (PSLG) in September 2007 was designed
to meet the need for an effective framework for interaction between industry, trade unions and
the COMAH Competent Authority (CA); a framework in which they could carry out a dialogue to
jointly develop, progress and implement meaningful, effective recommendations and practices that
improve safety in our industries.
PSLG membership consisted of senior representatives of the relevant trade associations, the CA
and trade unions. It built on the work of the Buncefield Standards Task Group (BSTG), set up
in 2006 to translate the lessons learned from that incident into effective and practical guidance
that the industry could implement quickly. PSLG expanded the membership to include the
Chemical Industries Association and also took on the task of progressing the implementation
of the Buncefield Major Incident Investigation Board (MIIB) recommendations. PSLG also saw a
need to raise the profile of process safety leadership throughout the petrochemical and chemical
industries in response to criticisms by both the Baker Panel (Texas City) and MIIB (Buncefield) that
leadership in this area was lacking and a contributory factor to these events.
PSLG has sought to continue the BSTG model of working through the trade associations to
measure and encourage progress against the various recommendations. In particular the use of
work groups involving the regulator, industry and the trade unions has been key to developing
effective, practical guidance and recommendations with buy-in from all involved. To support
this work, PSLG developed its Principles of Process Safety Leadership, signed by the trade
associations, CA and trade unions, which set out the commitment to the enhancement of process
safety. The trade associations will reflect the principles of process safety through their own
initiatives and actively share progress as programmes roll out.
The model of industry and the regulator working together on improving our capability to operate
safely is, I am convinced, a very effective one. Taking the path chosen by BSTG and PSLG is not
an easy option – it requires trust from all parties and a willingness to voluntarily accept measures
that require significant investment, both in financial and human terms. The regulator will always,
and should always, have the power to act independently to impose change – ‘aligned, but not
joined’ was the phrase coined when BSTG set off. However, I am sure we will get better, faster,
by jointly finding solutions rather than adopting a prescriptive approach.
Foreword