Major Hazard Facilities

1. Major Hazard Facilities Preparing and Managing a Safety Report

2. Overview The seminar has been developed to provide: • Context with the MHF Regulations • An overview of what is required by an employer who needs to prepare and maintain a safety report.

3. Some Abbreviations and Terms • AFAP - So far as practicable • ER or ERP - Emergency response or Emergency response plan • HAZID – Hazard Identification • HSR - Health and safety representative • MHF - Major hazard facility – as defined in the Regulations • MA - Major accident • OHS -Occupational health & safety • Employer - Employer who has management control of the facility • SMS - Safety management system • SRO – Safety report outline

4. Topics Covered In This Presentation • Introduction • Preparing a safety report • What makes a good safety report • Safety report outline - Core components • Potential pitfalls • Key success factors • Managing and maintaining a safety report • Review and revision • Safety report for a new project

5. Planning Resources, Tools and Systems Preparing a Safety Report Management Commitment and Support So this is what’s required Project Management Consultation & Communication Understand Requirements

6. Management Commitment and Support • The safety report should feature in, and be consistent with, business goals and objectives • The process is resource and time intensive so commitment for significant funding and employee time is required • Consistency with company policy, philosophy and objectives is necessary to maintain and sustain a compliant safety report • Essential that upper management show strong commitment, drive the process and provide the environment for the facility to develop, implement and maintain the safety report

7. Know The Regulatory Requirements • Read the Regulations !!! • Be sure to interpret the Regulations in the context of your facility • Define the relationships between the safety report / MHF requirements and other OH&S management activities • Clarify any points of the Regulations that are not understood. Do this early as several matters require compliant practice from the very beginning of the activity (eg consultation) • The MHF Regulations are relatively simple to grasp albeit difficult to comply with

8. Safety Report Planning • Proper planning is an essential element in preparing a safety report • An effective plan will cover all aspects of safety report development (or review and revision) including important aspects such as consultation

9. Safety Report Planning • Definition of tasks to be completed • What do you need to do ? • Definition of constraints in place • What resources do you have access to, funding available, regulatory timeframes etc • Definition of task inter-relationships • What has to come first, which tasks rely on information from another task, what are the constraints on availability of resources? etc • Identification and allocation of resources to each task • Who is needed to complete each task? • What other projects/tasks are competing for the same resource? • What tools, equipment or systems will you require? • What data will you generate and how will you store, use and manipulate this data? • What resources will you use to monitor progress?

10. Safety Report Planning Other elements in the safety report plan: • Estimation of task completion times and definition of task milestones in overall project schedule • Consultation and reporting plan for the project – who needs to be involved, who needs to be informed? • A clear project organisation structure detailing roles, responsibilities & reporting lines for project activities

11. Safety Report Planning • Safety report outline for new safety reports • Review/revision plan for update of an existing safety report • Employees and HSRs should be briefed on the proposed plan to achieve a common understanding and agreement of what is required • Acceptance by upper management of the resource requirements, process, and commitment is essential

12. Resources, Tools and Systems • Safety report development is a resource intensive process • Expect that high levels of employee participation are needed • Plant operators, maintenance personnel, plant managers, engineers, OH&S personnel, consultants, support personnel, administrative personnel, HSRs, contractors and corporate managers are all likely to be involved to a significant extent • Often spin-off projects are identified to address deficiencies in related support systems (e.g. training systems, document management systems, IT systems) • Core safety report development roles are not always best served by part time roles

13. Resources, Tools and Systems • Attempt to identify early any important tools which may be required. For example, are CAD drafting facilities required to update drawings? Will access to certain database information be required? What reference materials must be sourced? • Early consideration on how to record, store, manipulate and use the vast quantity of data generated from the safety report development process is recommended • Where existing systems, tools etc are to be used for the safety report tasks, it is prudent to verify early that those systems and tools will provide compliant outcomes • If the systems and tools of third parties (e.g. consultants) are to be utilised, the employer should include tasks to test and verify the adequacy of these for achieving a compliant safety report

14. Availability of Resources • The significant effort and time commitment required to complete activities such as hazard identification and risk assessment can be wasted if all relevant facts and knowledge are not available • Early consideration and coordination with many people is generally required • An objective evaluation of available skills is necessary to ensure additional expertise can be sourced where necessary • A low tolerance approach to workshop non-attendance is often required from senior management level. Workshops may be arduous, time consuming and often repetitive. Management and HSR support is required to overcome this • Plant and corporate managers need to agree and commit to the safety report program, and manage conflicting demands on resources accordingly

15. Project Management • The safety report plan needs to not only be defined, but also tracked and monitored to ensure successful completion by the due date and within all constraints • Good project management is required to ensure tasks are completed on schedule, over-runs are identified early and rectified, barriers to achieving compliance are identified and overcome • Consider the need for dedicated project resources (e.g. Safety Report Manager) to ensure process is not derailed by conflicting responsibilities

16. Quality Assurance • A great deal of effort and resource is expended by facilities in developing and documenting safety report components. It is important that this effort is accurately reflected in the final documentation • Facilities should be careful to ensure data presented in their submitted safety report is: • Accurate • Consistent • Unambiguous • Complete

17. Safety Report Outline (SRO) – Core Components • Safety report philosophy • Scope of work to be undertaken • Resources, timetable, milestones • Key definitions and criteria (risk, property damage) • Methodology statements (HAZID, risk assessment etc.) • Details of the scope of consultation that will be undertaken • The emergency plan

18. SRO Core Components - Safety Report Philosophy • Inherent risks within the facility • Chief methods of ensuring safe operation at the facility • Description of safety management system • Safety culture within the organisation

19. SRO Core Components – Description of Methods • The methods chosen for hazard identification and risk assessment are likely to have a major impact on resource requirements and timeline • Identify these early in the safety report planning • The methods used should align with the approach to safety adopted at the facility

20. SRO Core Components - Consultation • The MHF Regulations require you to consult with employees and external stakeholders during the development of the safety report • The safety report outline should describe: • Who will be consulted • How the consultation will occur • How the information from the consultation will be included in the safety report

21. SRO Core Components - Consultation • Who do you have to consult? • 7 main groups of people • HSRs • Employees • Emergency Services • Municipal Council(s) • Non-employees who enter the facility (e.g. contractors) • Local Community • Other persons who may reasonably suspect risk to their health and safety

22. SRO Core Components - Emergency Plan • Emergency Plans exist because things can go wrong and preparation is needed for such an event • Emergency Plans are more than response procedures; they also include the supporting framework of training, resources, performance measures and drills etc • Consultation with all emergency services is necessary (because they have a role to play in combating incidents and provision of resources) • Emergency Plan must be adopted as a control measure and as such the development of meaningful performance measures and indicators is required

23. What Makes a Good Safety Report? • All parts of the Regulations are systematically addressed • Early momentum is established • High levels of employee involvement • Wide and varied expertise has been made available • Thinking outside the established norms • Challenging the status quo • The safety report process is integrated into facility improvement plans and business processes • Safety report is owned, understood and managed by the MHF • The safety report process provides clear benefits to stakeholders

24. What Makes a Good Safety Report cont… • Clear and consistent links between MAs, Hazards, Risk, Controls, Emergency Plan, SMS and Performance Monitoring Regimes • Implemented control measures, SMS, performance monitoring regimes etc are sustainable given the size and complexity of the facility • Documentation captures corporate memory • The process is logical and simple – don’t over complicate

25. What Makes a Good Safety Report cont… The safety report demonstrates that: • The employer fully understands the facility’s processes/systems • The employer understands the facility’s risks • Appropriate control measures have been selected and implemented to reduce risks AFAP at the facility • Systems are in place to manage each MA to ensure risks continue to be reduced AFAP • The employer has systems to keep the control measures working to their stated performance level • The employer has in place processes for reviewing and revising, as needed

26. Some Potential Pitfalls and Mistakes • Not taking time to understand the Regulations properly • Inadequate planning • Wasting time and resources redoing work unnecessarily • Over committing to controls and systems which cannot be reasonably sustained • Do things to “look impressive” but which don’t add real value to the business • Not using valuable information already available (e.g. independent audits etc) • Overlooking mitigative controls and the need to maintain them

27. Some Potential Pitfalls and Mistakes • Failing to carry forward changes into all relevant parts of the safety report (e.g. Emergency Plan) • Inconsistencies between different parts of safety report or between different sources of information • Losing sight of the big picture – unbalanced focus on certain aspects • Losing sight of the overall objective of the regime • Failing to make safety report compliment overall business objectives

28. In Conclusion - Keys to a Successful Outcome Adequate Planning and Education • Understand the requirements in the Regulations and know what compliance looks like • Don’t over complicate at the start • Test processes and methods of documentation before starting • Identify resource needs early and consider how on-going maintenance of the safety report will be managed

29. In Conclusion - Keys to a Successful Outcome Involve the right people • Commitment from senior management • Appropriate depth & range of experience • Suitably qualified people • Operations staff, those who; • are exposed to the hazard • are the ones most likely to be impacted by, or contribute to an incident • understand the true variance in operating conditions and environments

30. In Conclusion - Keys to a Successful Outcome Clarity and Consultation • People understand what they are doing and why. • It is essential to included ongoing consultation with employees • Everyone exposed to hazards or involved in management of the risk needs to understand; • The hazards • The risk • The controls • The relationship between them • The safety report should form the basis of training and operating procedures • Key documents are updated and available

31. In Conclusion - Keys to a Successful Outcome Cultural Match • It is important that the process and methods used will work successfully within the organisation and the way it functions • E.g. • Don’t use highly technical approaches if that is not what you usually do • Ensure that controls are appropriate to the capability of the facility to manage them

32. In Conclusion - Keys to a Successful Outcome Sustainability • Need to remain focused on the facilities ability to sustain both: • The processes introduced • The outcomes from the process (new controls) • Ongoing resource requirements need to be considered before starting

33. In Conclusion - Keys to a Successful Outcome Belief in the Outcomes • Focus on improving safety, not simply compliance (regulatory or internal) • Effective real consultation & stakeholder ownership • Preparedness to challenge established “norms” • Process and procedure for resolving issues and agreeing assumptions • Transparency of the process

34. In Conclusion - Keys to a Successful Outcome Continuous Improvement • Focussed effort for continuous improvement in all aspects of the safety report and its supporting systems

35. Managing A Safety Report

36. Managing a Safety Report • The facility has been given a licence for 5 years • Management congratulates all • Everyone breathes a sigh of relief • Onto the next project • Let the safety report sit in the draw until the next investigators visit or licence renewal period

37. Managing a Safety Report • After all, the licence confirms: • Risks are in control and • There are management systems in place to deal with all of the required issues covered by the Regulations • Tempting –yes • ButWRONG!

38. What are the key things to be addressed on an ongoing basis Managing a Safety Report

39. Managing a Safety Report • The safety report should become integrated into the daily management activities of an MHF • The safety report process will have identified all of the performance parameters required for managing the risk from each MA How to use the information to keep the risk from each MA as low as practicable?

40. Managing a Safety Report • How to validate that controls identified in the safety report are: • Implemented? • Functional? • Meeting the performance standards nominated • Changes to circumstances are handled in accordance with the safety report process requirements • A system must be in place to verify all of these issues in an explicit and transparent manner

41. Managing a Safety Report • The control measures need to be managed through an audit system by the employer and documented in such a manner that allows the performance of every control to be verified • The overall performance of every control managing an MA should therefore be audited

42. Hazard Identification Risk Analysis Non-MAs (ie OH&S) Major Accidents Demonstration of Adequacy Safety Management System Define Control Activities Performance Requirements Implementation Managing a Safety Report

43. Managing a Safety Report • The SMS becomes the primary means of managing safety • As with the concept of management systems, if it is stated to do something, then it should be verified • Performance indicators should be developed to measure the success or otherwise

44. Safety management system Audit and verification process Control activities performance standard Demonstration of adequacy Reviewing and Revising • The effectiveness of the SMS can be measured through a specifically developed auditing process

45. Reviewing and Revising • The auditing process is considered essential to demonstrate • Continuing compliance with the safety report • Effectiveness of all the processes and systems • For the facility • The employer can develop a schedule for auditing the SMS elements and each of the MA controls identified in the safety report throughout the year • Undertake the audit and report on outcomes

46. Reviewing and Revising

47. Reviewing and Revising • It is natural that with any system there will be opportunities for improvements to be made to the safety report process • Such improvements could relate to: • Feedback from employees regarding training • Performance of controls (positive or negative) • Management of change • Emergency response exercises • Training • Incidents that occur • Communications with Regulator

48. Reviewing and Revising • Feedback from various sources will enable the safety report to be continually used as a key management business platform for the MHF • It will provide demonstration to all stakeholders of how the process is working • It will aid transparency and continued demonstration of adequacy that the safety report is fit for purpose

49. New Projects

50. Safety Report Requirements New Project How do we achieve the right outcome? Project Lifecycle New Project!