safety management system rel02
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Major Hazard Facilities
Safety Management Systems
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Overview
The seminar has been developed to provide:
• onte!t with MHF "eg#lations
• $n overview of what is re%#ired
• $n #nderstanding of the SMS and why it is important
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• $F$& ' $s far as (reasonably) practicable
• *mployer ' *mployer who has management control of the facility• *" or *"& ' *mergency response or *mergency response plan
• Facility ' any b#ilding or str#ct#re at which Sched#le + materials arepresent or li,ely to be present for any p#rpose
• H$-./ ' Hazard identification
• HS" ' Health and safety representative
• 0O ' 0oss of containment
• 0O&$ 1 0ayers of protection analysis
• M$ ' Major accident
• MHF ' Major hazard facility
• MO 1 Management of change
• OHS ' Occ#pational health 2 safety• S" ' Safety report
• SMS ' Safety management system
Some $bbreviations 2 Terms
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Topics covered in This &resentation
• .ntrod#ction• "eg#lations
• 3hat is a safety management system4
• SMS models and standards
• 5ey elements of the SMS
• The importance of SMS
• 3hat sho#ld the SMS do4
• Meas#rement of performance
• *!amples of SMS performance standards
• *mergency planning
• SMS testing
• .tems to note
• ritical s#ccess factors
• So#rces of additional information
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"eg#lations
Occupational Health and Safety (Safety Standards) Regulations 1994
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3hat is a Safety Management System4
• $n SMS is a comprehensive and integrated system thatens#res that all wor, at the facility is cond#cted safely
• .t sho#ld be f#lly doc#mented6 accessible and comprehensible
to those that need to #se it
• .t recognises the potential for errors and establishes rob#stdefences (control meas#res) which are f#lly implemented6 to
ens#re that errors do not res#lt in accidents or near misses
• .t is comprises a set of wor, practices and proced#res for
monitoring and improving the safety and health of all aspects
of the operation
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5ey Terms 7sed in /escribing the SMS
Comprehensive
• /escribes the way that all safety iss#es incl#ding controlmeas#res are managed
• lear lin, between controls management and the SMS
Integrated
• The str#ct#re is logical6 systematic
• 0ogically ties in to other management systems
• orporate systems do not contradict onsite systems
Comprehensile
• $bbreviations and terms #sed mean something to employees
• onsideration of lang#age iss#es
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5ey Terms 7sed in /escribing the SMS
Implemented
• &roced#res are approved and in circ#lation
• *vidence is available 1 completed forms and8or chec,lists
• *mployees are trained and ,nowledgeable
!ccessile
• *mployees are aware of how to obtain the most #p to date orrelevant proced#res
• *mployees can obtain the SMS information needed to s#pportcontrol meas#res
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SMS Models 2 Standards
• So#nd management systems are all similar in f#ndamentalterms
• ompliance with the MHF "eg#lations does not re%#ire anypartic#lar standard to be #sed6 nor will compliance with ane!isting management standard ens#re compliance with the SMSre%#irements of the MHF "eg#lations
• There are a variety of ways in which the SMS can be str#ct#red9Most large organisations will have their own str#ct#re already
• However6 adoption of a proven standard may assist an MHFemployer
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*!amples of SMS
OH"S #anagement Systems #odel $ !S 4%&1
gg
Safety PolicySafety Policy
PlanningPlanning
Implementation
& Operation
ImplementationChecking
&CorrectivActio
Measurement
& Evaluation
Continual
Improvement
Continual
Improvement
ManagementRevie
ManagementReview
Overall
vision, goals
and
commitment
to improve
• Legal compliance• Obectives and targets• !mplementation plans
• "eso#rces• Leaders$ip responsibilit%• &raining and competenc%• 'ons#ltation and comm#nication• (oc#mentation• )a*ard identi+ication, ris assessment
and controls• -mergenc% response
• .onitoring and
meas#rement• !ncident investigation• "ecords management• /#dits
#itable, ade#ate,
e++ective '$anges needed Opport#nities to
improve
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ISO 14&&1 'nvironmental #anagement Systems
Environmental
Policy
Management
Review
Planning
Implementation
& Operation
Checking &Corrective Actions
*!amples of SMS
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5ey *lements of the SMS
From the previo#se!amples6 there arecommon elements
&olicy
&lanning
.mplementing
$ssessing
Management "eview
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5ey *lements of the SMS
&olicy
&lanning
.mplementing
$ssessing
Management "eview
*ffective health andsafety policies set aclear direction for theorganisation to follow
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5ey *lements of the SMS
$n effective managementstr#ct#re and arrangementsare in place for deliveringthe policy9
There is a planned andsystematic approach toimplementing the healthand safety policy
&olicy
&lanning
.mplementing
$ssessing
Management "eview
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5ey *lements of the SMS
The policies andproced#res are p#t inplace to manage allaspects of the control
meas#res that ens#re safeoperation of the facility
&olicy
&lanning
.mplementing
$ssessing
Management "eview
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5ey *lements of the SMS
&erformance ismeas#red against
agreed standards to
reveal when and whereimprovement is needed9
&olicy
&lanning
.mplementing
$ssessing
Management "eview
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5ey *lements of the SMS
The organisation learnsfrom all relevante!perience and appliesthe lessons9
&olicy
&lanning
.mplementing
$ssessing
Management "eview
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The .mportance of SMS
• .n reviews of accidents6 a common thread thro#gho#t is theinade%#acy of management systems that might haveprevented the accident from occ#rring
• *!amples of some iss#es identified are
1 0ac, of hazard review and ris, assessment to predict andprevent incidents
1 .ns#fficient investigation and follow #p after previo#s incidents
1 .nade%#ate training of staff
1 Fail#re to implement effective mechanical integrity programs
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The .mportance of SMS
The following information provides broad details on some 7Sincidents and contrib#ting ca#ses
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The .mportance of SMS
Management System Categories Contriuting Causes
0
2
4
6
8
10
12
Management System
C a u
s e
rea,down of management system categories identified as
contrib#ting ca#ses in incident investigations
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The .mportance of SMS
• liorough 19*4
1 Management ofmodification fail#re
1 .nade%#ate e!perience
1 Overstretched reso#rces
• +iper !lpha 19%%
1 Fail#res in shift handover
1 &ermit to wor,
1 Training1 omm#nications
1 $#diting
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The .mportance of SMS
• +asadena 19%9
1 Maintenance
1 &ermit to wor, errors
1 Fail#re to follow'#p ona#dits
• ,ongford 199%
1 .nade%#ate ,nowledge ofhazards
1 $bsent personnel
1 &oor proced#res
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The .mportance of SMS
• orporate safety oversight6incl#ding the safe managementof sites obtained thro#ghmergers and ac%#isitions
• orporate safety c#lt#re
• orporate and site SMS• ;ear miss reporting and
investigation programs
• Mechanical integrity programs
• Hazard analysis programs
• hange management
-+ !merica Refinery 'plosion .eas City/ 0 #arch 0&&2
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The .mportance of SMS ' *!ercise
-uncefield 'plosion/ 3/ 11 5ecemer 0&&2
• .n the early ho#rs onS#nday a n#mber ofe!plosions occ#rred at#ncefield Oil Storage/epot6 Hemel Hempstead6Hertfordshire
• $t least one of the initiale!plosions was of massiveproportions and there was alarge fire6 which eng#lfed ahigh proportion of the site
• Over fort#nately therewere no fatalities
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The .mportance of SMS ' *!ercise
6hat control measures
• 3ere in place4
• o#ld have been in place4
• 3ere they effective4
-uncefield 'plosion/ 3/ 11 5ecemer 0&&2
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The .mportance of SMS ' *!ercise
-uncefield 'plosion/ 3/ 11 5ecemer 0&&2
Control #easure 'ffectiveness7
0evel meter 2 alarm Failed before alarm
.ndependent H0$ 2 Trip Flow contin#ed
$#to tan, ga#ge system /id not prevent overflow & r e v
e n t i v e
Operator s#rveillance /id not prevent overflow
.gnition so#rce control ?apo#r clo#d went off site
Fire water system mp ho#se destroyed
M i t i g a t i v e
:#nding &enetrations 8 joints failed
Common theme – failure to manage the control measures
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The .mportance of SMS ' *!ercise
• 3hat SMS elements were needed to ens#re that the controlmeas#res wor,ed when re%#ired4
-uncefield 'plosion/ 3/ 11 5ecemer 0&&2
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The .mportance of SMS ' *!ercise
-uncefield 'plosion/ 3/ 11 5ecemer 0&&2
Control #easure Supporting S#S
0evel meter 2 alarm Testing and inspection
.ndependent H0$ 2 Trip ritical safety f#nction testing
$#to tan, ga#ging system &reventative maintenance program & r e v
e n t i v e
Operator s#rveillance Operating proced#res and training
.gnition so#rce control /esign standards6 p#rchasing specs
Fire water system /esign standards
M i t i g a t i v e
#nding Maintenance and integrity inspection
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The .mportance of SMS 1 $#stralian *!perience
• Feedbac, from reg#lator site visits to $#stralian MHFs6together with e!amination of incident data has revealed thefollowing iss#es are li,ely to be the wea,est lin,s within anSMS
1 Management of @rd parties
1 Maintenance proced#res and systems
1 Hazard identification and analysis
1 *ngineering design and review
1 Operating proced#res
1 Management of change
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The .mportance of SMS 1 $#stralian *!perience
Other issues to note8• There are always f#ndamental failings in the AsystemB
• omplacency and safety vers#s prod#ction conflicts
• /eficiencies in practice with adherence to application of theSMS rather than system standards
• Fail#re to accept and prepare for emergencies
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3hat Sho#ld the SMS /o4
• The SMS is the tool with which the *mployer meets the overall goalof the "eg#lations
• The SMS sho#ld cover the following
1 /efine safety roles and responsibilities
1 *ns#re ade%#ate s,ills6 information6 tools and decision'ma,ing arepresent in day to day and abnormal operations
1 Maintain awareness of hazards and ris,s
1 &lan6 implement6 meas#re and eval#ate M$ controls and the SMS
1 /evelop performance re%#irements
1 Set targets for improvement of safety at the facility
1 Manage change
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3hat Sho#ld the SMS /o4
• Manage and maintain ,nowledge• .nstigate H$-./ and ris, assessments
• Manage ade%#ate h#man reso#rces
• &rovide performance information to all levels oforganisation
• "eview and improve the SMS itself
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3hat Sho#ld the SMS /o4
• Manage safe operation at the facility6 incl#ding M$s6specifically foc#sing on:
1 &revention
1 "ed#ction
1 Mitigation
• .t is not j#st doc#mentation ' it is the act#al implementationof processes6 proced#res and practices at the facility
• .ncl#de and reflect the safety c#lt#re at the wor,place
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3hat Sho#ld the SMS /o4
• Some companies6 in partic#lar employers of m#ltiple sites6 mayapply corporate standards for an SMS
• These may prescribe the entire SMS6 or only common high'levelcomponents s#ch as the overall policies and proced#res
• .n other cases corporate SMS re%#irements may be very limited6and the site will then need to develop its own systems
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3hat Sho#ld the SMS /o4
• Many corporate systems specify that local reg#lations overridecorporate re%#irements if they are more stringent
• Other companies may employ integrated managementsystems for the b#siness as a whole
• .t is entirely #p to the *mployer to choose how the SMS isstr#ct#red and developed
• However6 in all cases the SMS must provide a managementfoc#s on the specific control meas#res re%#ired for safeoperation of the partic#lar facility
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3hat Sho#ld the SMS /o4
Accidents
H
a z a r d s
C a u s e s
C o n s e q u e n c e s
Local proced#res and practices design, maintenance operation
Prevention
Controls
Mitigatio
n
Controls
'orporate a+et% .anagement %stem
MA Potential
Level 1
Level 2
Level 3
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3hat Sho#ld the SMS /o4
• The SMS sho#ld not j#st be seen as satisfying MHFre%#irements
• .t sho#ld be #sed as a performance management tool to assistin managing the entire operation6 incl#ding other performancebased reg#latory re%#irements
• Most modern management system AstandardsB or CmodelsCfeat#re a set of generic elements6 forming a contin#alimprovement cycle
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Meas#rement of &erformance
• &erformance standards8indicators m#st be developed andimplemented as part of the SMS (e9g9 meas#re theeffectiveness of SMS) to s#pport the MHF safety objectives
• The following principles apply in defining performancestandards: Ma,e them S#!R.
• Specific
• #eas#rable• !chievable
• R ealistic
• .argeted
• The p#rpose of performance standards8indicators for the SMSis to enable the objective meas#rement of its target and
(s#bse%#ently) effective maintenance and improvement ofperformance
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Meas#rement of &erformance
• Standards and systems need to be practical• Sho#ld not place an #nwor,able b#rden on employees
• *ns#re open6 comprehensive and acc#rate reporting of errors orproblems
Is an absence of evidence of problems really indicatinghigh performance?
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Meas#rement of &erformance
• &erformance indicators need to be meaningf#l and contrib#te tothe overall eval#ation of the SMS effectiveness
• .f a control is stated to be in place for prevention of an M$6then:
1 .s it implemented4
1 .s it effective4
1 .s it a#dited4
1 $re the res#lts #sed for improving the effectiveness of controlsmanagement4
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Meas#rement of &erformance
• &erformance indicators sho#ld be established covering (as aminim#m):
1 How often a#dits are to be #nderta,en
1 Scope of the a#dits
1 $re the controls implemented4
1 $re the controls f#nctional4
1 D compliance6 partial compliance and non compliance
• &erformance indicators sho#ld be s#fficiently detailed andtransparent to enable the effectiveness of the SMS to beapparent from the doc#mentation
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Meas#rement of &erformance
• The a#dits need to be eval#ated against criteria developed bythe MHF
• They sho#ld incl#de steps to contin#ally improve the SMS6 sothere needs to be processes and meas#res designed toidentify and implement improvements to the system itself
• Three main types of a#dits
1 First a#dit: Self a#dit1 Second party: a#dit of s#ppliers
1 @rd party: e!ternal agencies e9g9 reg#lator6 certification bodies9
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Meas#rement of &erformance
• 0i,ewise6 E==D compliance is a desirable objective ' b#t realistically
not practical• Setting a tiered acceptability criteria co#ld be an option
Item Compliance +artialCompliance
on:compliance
$#dit fre%#encyfor controls met
+=D E=D =D
$#dit time frameachieved
+=D E=D =D
ontrolsimplemented
E==D =D =D
ontrolsf#nctional
+D D =D
'ample only8
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*!amples of SMS &erformance .ndicators
&ermit to wor,
Management of change
Operating proced#res
$#diting
;#mber of accidents or near misses ca#sed by afail#re of this systemD permits a#dited compliant with proced#re
;#mber of accidents or near misses ca#sed by afail#re of this systemD of Mo forms completed in compliance withproced#resD temporary changes beyond their time limit
D of new proced#res completedD of proced#res reviewed
D a#dits completed to sched#le;#mber of non conformances closed o#t8month
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.tems to ;ote ' *mergency &lanning
• The MHF m#st prepare an emergency plan addressing the on'site8off'site conse%#ences
• M#st cons#lt with employees and emergency services
• &lan sho#ld consider
1 $ccident type (e9g9 major8minor6 environmental6 personal safety6on'site6 off'site6 property damage)
1 ommand hierarchy and contact information
1 *%#ipment re%#ired
1 ontingency plans
• &lan sho#ld be tested6 reviewed6 #pdated
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.tems to ;ote ' Management of hange
• Management of change needs to be considered very caref#llywithin the safety report
• $n iss#e often disc#ssed is:
1 3hen is a change really a change4
1 3hen is a change not a change4
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.tems to ;ote ' 3hen is a change really a change4
• $ny change to an MHF needs to be eval#ated in the conte!t ofthe safety report
• *!amples of this incl#de b#t are not limited to:
1 Organisational change
1 $ddition of a new #nit
1 los#re of a #nit
1 $ny modification to a potential M$
• 5esired Outcome8 /emonstrate that at least the same level ofris, or lower is achieved after the change and that all theprocesses within the safety report are followed and transparent
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.tems to ;ote ' 3hen is a change not a change4
• $ny change to an MHF that involves swapping li,e for li,e isnot considered to be a change
• This ass#mes the e%#ipment or systems being changed are fitfor p#rpose
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.tems to ;ote ' .ncident .nvestigations
• .ncidents that occ#r or co#ld have occ#rred at an MHF are aval#able so#rce of information
• $s with good practice6 all incidents at a facility sho#ld bereviewed for lessons learned and their findings implementedfor prevention in the f#t#re
• For an MHF6 investigation of M$s is of partic#lar importance as
it will provide insight into the mechanism of occ#rrence
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SMS ' ritical S#ccess Factors
• $de%#ate reso#rces for both development and improvement• &ersonnel are aware of their responsibility and acco#ntability
• &ersonnel are trained8competent
• onsistent with the #nderstanding of ris, gained from the ris,assessment
• There sho#ld be s#fficient foc#s on M$s6 from planningthro#gh to operations
• The *mployer m#st doc#ment the basis for the facilityGs SMS6and the SMS itself
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SMS 1 ritical S#ccess Factors
• $de%#ate reso#rces for both development and improvement
• "esponsibilities 2 acco#ntabilities defined
• $de%#ate ed#cation and training is provided for employees
• overs the whole facility as defined in the safety report
• *mployees ,now how to access it and #nderstand it
• &erformance indicators 2 standards for the control meas#res andthe SMS as a whole are defined
• &lanning6 implementation and monitoring processes are providedfor control meas#res and the system as a whole and fail#res areaddressed
• &rocesses are provided for review and revision of controlmeas#res and the SMS
More information is available in Booklet 3 on the SMS
Comprehensive and Integrated
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"eview and "evision
• The SMS needs to be reviewed on a reg#lar basis to ens#re itis fit for p#rpose for management of an MHF
• Over a period of time the lessons learned together with res#ltsof performance reviews sho#ld enable improvements to bedoc#mented
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So#rces of $dditional .nformation
• Safety Management6 Hazardo#s .nd#stry &lanning $dvisory&aper ;o9 +6 #idelines for the /evelopment of SafetyManagement Systems6 /epartment of 7rban $ffairs and&lanning6 E++
• $S8;-S
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• $S8;- .SO +==E:J===6 K#ality Management Systems• $S8;- .SO E
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• 75 Health and Safety *!ec#tive HS6 S#ccessf#l Health andSafety Management
• 7S /epartment of 0abo#r9 OSH$ Standard F" J+ E+E=9EE+6&rocess Safety Management
• $.h*6 &S6 #idelines for .mplementing &rocess SafetyManagement Systems
• Management System Fail#res .dentified in .ncidents.nvestigated by the 79S9 hemical Safety and Hazard.nvestigation oard6 $ngela S lair &* hemical .ncident.nvestigator6 &rocess Safety &rogress6 /ecember J==
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K#estions4
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