Sharing lessons in process safety across the European Union
25 October 2017
The UK chemical and downstream oil sectors experience of learning from safety related events has been shaped by the recommendations following the Buncefield explosions and fires in 2005. These have largely been driven by the Process Safety Leadership Groups (PSLG) Principles of Process Safety Leadership.
This recommends that: “Sharing best practice across industry sectors, and learning and implementing lessons from relevant incidents in other organisations, are important to maintain the currency of corporate knowledge and competence”
The Process Safety Forum established in the UK to share knowledge and best practice between different industry sectors is one example of how this is achieved, and was the subject of an article for the July edition of HazardEx.
All businesses that have the potential to cause a major accident are now being encouraged through various cross industry-regulator groups to look at leadership in process safety and determine what more they can do, including sharing and learning. A recent UK publication by the Control of Major Accident Hazards (COMAH) Strategic Forum Managing Risk: The hazards that can destroy your business aims to make the principles of good safety leadership more accessible. Search for “COMAH Strategic Forum Managing Risk” for more information.
However, should we stop within our local borders? With new technologies, social media and cloud based sharing platforms we have access to a wealth of knowledge and tools that can help us to further improve our performance in process safety.
How good is industry at exchanging knowledge?
Businesses are generally good at sharing information amongst their own people, including where those people are working on many different sites across several different countries. Learning lessons from incidents, near misses and communicating good practice about how to tackle common problems is clearly advantageous, and can be achieved relatively easily without the legislative barriers that may impede external sharing.
The nuclear industry is an exemplar of how information within one sector can be shared more widely on an international basis, in this instance through the World Association of Nuclear Operators (WANO). Other sectors, such as the chemical and downstream oil industries in the UK, have become better at sharing externally because of their commitment to implement the PSLG principles. There are also many international bodies and publications that share information on incidents, such as the Centre for Chemical Process Safety (CCPS).
However, the more widely we try to communicate the more difficult it becomes to stimulate and maintain engagement and commitment.
A model for greater communication
The Tank Storage Association (TSA) is actively engaged with its member companies to promote the adoption of the PSLG principles, and to share and learn from incidents, near misses and good practice. It actively promotes this within the bulk liquid storage sector in the UK through its leading role in key groups such as the Process Safety Forum, COMAH Strategic Forum and Chemical and Downstream Oil Industries Forum.
The TSA works with its European counterparts through the Federation of European Tank Storage Associations (FETSA). Traditionally this relationship has been in place to ensure collaboration in lobbying activities and provide advocacy to the European Commission (EC) on relevant Directives, for example the Integrated Pollution Prevention and Control Reference Document on Best Available Techniques on Emissions from Storage (known as the Storage BREF).
Although limited to European countries, FETSA provides an existing forum of like-minded trade associations with links to a wide network of bulk liquid storage operators. Countries within the European Union (EU) also share many common legislative instruments derived from European Directives, including Seveso III (implemented in the UK as COMAH).
With common legislation and challenges, FETSA provides the ideal platform for members from participating countries to gain access to a wide range of process safety knowledge and experience – as well as influence process safety regulation under Seveso III as part of the traditional lobbying and advocacy role. With regard process safety, the aim of greater collaboration is to:
* become more open in sharing information on recent incidents and near misses, where this is permitted under individual member governance and agreed with the originator.
* actively share information on good practice and new and emerging guidance and standards.
* use the networks within FETSA to ask relevant technical questions originated from the trade association members to assist them in clarifying any issues they may have.
* use the networks within FETSA to understand the approach taken by the regulator on relevant topics providing the sector with a Europe wide overview.
* use collective experience to greater influence responses to consultations on relevant safety-related directives or standards originating from the European Union.
* investigate the development of common process safety performance indicators which can be collated and anonymised through the FETSA secretariat. The data may then be used as a reference point for individual member countries.
Implementing the model
The model described above is a simple one – it facilitates the sharing of information relevant to process safety amongst participating organisations. For FETSA, this already exists as a network to collaborate on lobbying and advocacy for relevant EC topics.
To facilitate the exchange of information a cloud based SharePoint has been established where guidance, safety alerts, performance data and other relevant publications can be posted. Having a central repository is an important facility as it allows FETSA members to screen information before onward transmission to their member companies – ensuring only relevant information is distributed further. As the SharePoint becomes more populated it should also provide a useful library of process safety information.
From a UK perspective, the TSA shares information it receives from:
* the Process Safety Forum – Safety Alerts and Learning Briefs
* the COMAH Strategic Forum – Seveso III policy approaches and strategic topics
* the Chemical and Downstream Oil Industries Forum – Guidance on process safety, environmental and occupational health and safety topics
* the Process Safety Management Competence Board – Process safety training initiatives
* TSA initiatives – member safety alerts (where agreed with the originator), quarterly and annual safety statistics
Information received from European partners will be reviewed for onward dissemination through TSA member companies or where relevant the wider major hazards sector through the PSF.
The most immediate benefit to participants is access to many terminal operating companies which can bring a wealth of knowledge to any technical questions raised, for example:
* What is your regulators approach to bund capacity?
* Are terminals operating in your region obliged to investigate the contamination of sediment at the point of the wastewater-discharge?
* What level of risk assessment do you carry out for ignition risk from radio frequencies?
Having a large evidence base from responses to questions raised can benefit an operator in determining an appropriate course of action or assisting in dialogue between the terminal, its trade association and regulator.
In the UK, the stimulus for establishing closer collaboration and sharing of knowledge and good practice was Buncefield. This brought about a fundamental change in the relationship between industry and regulator, and highlighted the benefits that could be gained by working together to identify common issues and the solutions to mitigate them. We are still working on these relationships in 2017, fine-tuning and improving.
When considering collaboration at a European level there is perhaps not the same drive and determination. Regulators do behave differently and interpret safety and environmental directives in different ways. Cultural, business and legal influences may also impact on what can be shared, and there will be language barriers in some instances.
There should be no expectation of an instant and seamless solution. What is critical as that the right information is shared with the right people – key pieces of information that can be demonstrated to have had a positive impact will drive forward changes in attitude and highlight the importance sharing.
For the TSA and FETSA, process safety is an agenda item at quarterly meetings with participating trade associations to maintain visibility of the process. Any topic or document posted on the SharePoint that warrants further discussion and action will also be discussed at these meetings.
Many different sectors will have the networks in place to collaborate with their European (or worldwide) peers on legislation and standards. These same networks can be adapted to share knowledge on process safety. Virtual networks can be formed and participants encouraged to contribute and ask questions - sharing of information requires a cultural change, a commitment from all involved to think about what may be useful and to take a genuine interest in what is put forward by others.
The TSA and FETSA are very much at the start of this process. There is a great deal of effort required to maintain interest and to encourage people to contribute, but there is an acceptance that ensuring safe and profitable operations is our main priority. Exchanging the knowledge that we have is a valuable tool in helping to achieve this.
About the author
Peter Davidson is Executive Director of the Tank Storage Association and sits on the Executive Committee of the Federation of European Tank Storage Associations (FETSA).
The Tank Storage Association (TSA) represents the interests of twenty-two-member companies engaged in the storage of bulk liquids. Collectively members operate over 280 terminals and distribution hubs in the UK and have over 8 million cubic metres of storage capacity. More than 60% of the products stored and distributed are refined petroleum, however members also store many other substances including a wide variety of chemicals, molasses, fats & oils, ethanol and glycerine.