Process safety benchmarking is a first

Process Safety Management (PSM) is one of the Health and Safety Executive’s (HSE’s) foremost ’hot topics’ for high-hazard sites. Guidelines, such as the PSLG Guidance document, exist to assist companies in which factors they should be addressing, but, in general, industry’s approach to PSM has been very disjointed until now.

HFL Risk Services, together with the Chemical Industries Association (CIA) and National Skills Academy for Process Industries (NSAPI) recently undertook what is considered to be an industry first: a PSM benchmarking programme for the chemical industry.

The exercise had the support of the HSE and brought together representatives from 12 complex manufacturing sites, from multinational plcs to specialist SMEs. All companies were Control of Major Accident Hazards (COMAH) regulated and all bar one were designated top-tier sites. This gave a broad range in terms of organisation and complexity in our opinion a fair representation of the chemical industry as a whole.

The programme commenced with a seminar in October, held at the Catalyst Museum in Widnes, where speakers included Phil Scott of the CIA and representatives from the HSE, NSAPI and HFL Risk Services. This was then followed by assessment exercises undertaken at each of the participating sites, which were facilitated by HFL Risk Services between November 2010 and February of this year.

The PSM benchmarking centred on asset integrity management, this being a key aspect a critical risk control system in the prevention of major accidents.

Information from 206 data points at each site was collated and analysed, giving almost 2,500 data points in total on which to base the results of the assessment. At each site a cross-functional team of managers, supervisors and operatives were involved, and the information generated was supported by observations and documentation as appropriate.

Process safety management benchmarking centred on asset integrity – a critical risk control system in the prevention of major accidents

The auditing process was based around US Center for Chemical Process Safety (CCPS) guidance and prepared independently of, but mapped to, COMAH guidelines. Scorings were allocated according to the POPMAR model set out in HSE’s guidance document HSG65 (i.e. against policy, organisation, planning and implementation, monitoring, audit and review), taking into consideration the four Ps of process safety process, plant, procedures and people.

In terms of the results, what we found, encouragingly, was some world-class performance in terms of PSM in many instances. It was also clear from the research that it was the technical aspects that scored most highly. The organisation, planning and implementation, and monitoring aspects of POPMAR were relatively strong, indicating that operators are doing what needs to be done in practice and, in many cases, doing it very well.

However, the policy, audit and review aspects relating to leadership and administration were not so strong, emphasising a reliance on engineers at the coal face knowing what needs to be done and getting on with it.

In terms of the results from the benchmarking process, what we found, encouragingly, was some world-class performance in terms of process safety management in many instances

Interestingly, but perhaps not surprisingly, the scores across all companies were higher in those areas where more prescriptive legislation exists, such as compliance with the Pressure Systems Safety Regulations (PSSR). Safety Instrumented Systems (SIS) also faired well; no doubt because of the existence of clear and structured guidance, and a continued push from the regulator.

Performance tailed off, however, to differing degrees, for lower-risk non-codal systems. For example, it transpired that greater opportunities for improvement were to be found in the inspection and testing of secondary and tertiary systems, and mediumand lower-risk process systems. The control of maintenance spares in relation to critical systems was also highlighted.

Inspection of structures was another topic for some discussion, specifically the way that items such as railings, handrails, hangers, drains and flooring should be evaluated as part of a structural survey. Redundant structures should also form part of the same survey, especially where failure could be a precursor to a major accident.

As far as actual procedures were concerned, companies generally scored more highly in design, inspection, mechanical and C&I maintenance, and maintenance planning, with management of change and failure reporting scoring well in most cases. Policy, specifically in regard to asset integrity, identification of critical equipment and assessment of degradation mechanisms, on the other hand, could be improved upon against the guidance.

The overarching theme that emerged as a result of the benchmarking process is that there is generally a lack of detail in high-level policies covering asset integrity. The issues around PSSR and SIS are well understood and, in the main, well managed. But by not having clear polices in place for other aspects, companies can allow themselves to be regulated into rather than setting out their own programmes of testing and inspection.

A theme that emerged as a result of the process is that there is generally a lack of detail in high-level policies covering asset integrity

Structured operation
Policy deployment is therefore essential in any effective asset integrity/PSM operation because it provides a structure or framework, which eliminates any reliance on people’s experience. It also formalises the way in which things are done and ensures that progress towards goals are formally monitored in a visual environment. Additionally, it aids sustainability and helps demonstrate compliance to the relevant authorities.

Where companies scored highly this was consistent with HSE ’hot topics’. But the impetus to improve performance in non-codal areas must come through leadership in individual companies if they are to avoid falling into the reactive compliance trap. Self-regulation, led from the top, gives sites greater clarity on what needs to be done, where and when, in accordance with budgets.

Feedback from the companies involved has shown this first PSM benchmarking programme to be highly beneficial. It has given different chemical companies the opportunity to learn from experts within the sector, share experiences and work together for a common cause improved process safety within their industry.