Improving Process Safety in the Downstream Oil Industry a report by Peter Davidson Director – Safety, Commercial and Projects, United Kingdom Petroleum Industry Association
The explosions and fires at the Buncefield oil storage depot near Hemel Hempstead in the early hours of Sunday 11 December 2005 highlighted a new area of potential risk that had not previously been thought probable. The incident triggered a fundamental review, by the oil industry and regulators, of large-scale gasoline storage.
In January 2006, work began by the Buncefield Major Incident Investigation Board (MIIB) to determine the causes of the Buncefield incident. The MIIB developed a series of recommendations for industry and the Competent Authority (CA – Health and Safety Executive, Environment Agency and Scottish Environment Protection Agency), which, once implemented, would greatly reduce the risk of a similar incident in the future.
A New Way of Working
Dealing with the Response to Buncefield In spring 2006, the MIIB published three progress reports on the Buncefield investigation describing the probable causes of the incident. Rather than wait for the MIIB to develop and complete its recommendations, industry and the CA decided to work in parallel with the MIIB to produce a quicker response and earlier implementation of key recommendations. Industry and the CA formed the Buncefield Standards Task Group (BSTG) in summer 2006 to complete this work, producing a final report in summer 2007.1
Meanwhile the MIIB produced a report,
Recommendations on the Design and Operations of Fuel Storage Sites, in spring 2007.2
The Process Safety Leadership Group (PSLG) was then formed to take forward the work of the BSTG and to ensure all 25 recommendations of the MIIB’s report were comprehensively addressed, most notably in the areas of high-reliability organisations, culture and leadership.3
Working Methodology
The PSLG (and the BSTG before it) took a radical approach to the development of the guidance necessary to tackle the MIIB’s recommendations. In the past, such a response was developed in isolation by the CA, industry or through specialist consultants. The PSLG took a holistic approach, forming working groups consisting of the CA, industry, trade unions and other expert organisations, ensuring the development of effective, practical guidance supported by all involved parties.
Sector-level Initiatives
Three of these recommendations related directly to delivering high performance in process safety through culture and leadership, recommendations echoed by the US Chemical Safety Board following the Texas City disaster in 2005. In a major step forward for the downstream oil sector, and in response to these three recommendations, the UK Petroleum Industry Association (UKPIA) developed a Commitment to Process Safety, aimed at promoting and
© TOUCH BRIEFINGS 2011
Answering these questions and putting in place practical measures to address them can make a significant contribution to improving process safety.
Learning from Others
Improvements in process safety not only come from within a single organisation, but can also be influenced by best practices and learning from incidents or near misses from other companies in the same business, or more widely from other sectors. How we fundamentally manage risk does not change among different industries; the analysis of an incident in one industry has the potential to deliver important lessons for others.
Peter Davidson is the Director of Safety, Commercial and Projects for the UK Petroleum Industry Association (UKPIA). In this role, he is tasked with promoting process safety through the development and implementation of sector-level initiatives. Mr Davidson works in close collaboration with the Competent Authority in the UK and is an active member of the Process Safety Leadership Group and the Chemical and Downstream Oil Industry Forum, leading its process safety work stream. He also contributes
towards many other safety committees – including the Process Safety Forum, the Institute of Measurement and Control Safety Panel, the COGENT Downstream Advisory Committee, and the Energy Institute Process Safety and Downstream & Marketing Committees – where he represents UKPIA. Prior to joining UKPIA in January 2009, he worked as the Regulatory Compliance Manager for ABB Automation in the UK, specialising in the delivery of automation systems to highly regulated industries, including petrochemical, pharmaceutical and nuclear.
E:
peter.davidson@ukpia.com
• How can we learn from others both within and outside of our sector and also share our experiences with them?
• •
How can we build on the work of the PSLG and continue to work collectively to identify and achieve improvements in process safety?
How can we improve our procedures and practices to exceed what good practice tells us to do?
• How can we monitor our performance as a sector and identify signs of early weakness?
delivering excellence within its membership – refreshing and improving the approach to process safety within the UK downstream oil sector.
A Commitment to Process Safety
In the UK, industrial sites that have the potential to cause a major accident are regulated under the Control of Major Accident Hazards (COMAH) regulations, which implement the EU Seveso Directive in the UK.
COMAH requires operators of major accident hazard facilities to have an effective process safety management system in place in order to control these hazards, and this is a condition of the ‘licence to operate’ system adopted in the UK. When looking at how process safety improvements can be made at a sector level, it is therefore necessary to think outside of these site or company level boundaries. Several questions can be asked:
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