Reorganisation measures and management continuity during the pandemic

Author : Romualdo Marrazzo, ISPRA

11 April 2023

This article aims to highlight the enforcement and monitoring activities carried out at industrial sites in Italy during the COVID pandemic, with particular reference to SMS (Safety Management System) inspections in process industry sites subject to the obligations of Directive 2012/18 / EU (so-called Seveso III), showing the strengths and benefits of a new inspection method.

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The health emergency from COVID-19 resulted in limitations in carrying out on-site inspections around the world. Starting from this problem, the Italian Competent Authorities, in compliance with the standard procedure given in the D.Lgs. 105/2015 (Italian implementation of the Seveso III Directive), introduced an alternative method for ensuring the continuity of SMS inspection activities, with the possibility of performing some phases remotely.^{[1], [2], [3]}

The new SMS inspection procedure

In Italy, the SMS inspections of Seveso establishments are carried out by a Commission consisting of three members belonging to the following authorities: ISPRA (National Institute for Environmental Protection and Research), CNVVF (National Fire Brigade), INAIL (Safety at Work Institute). The new procedure for carrying out Seveso inspections, as shown in Figure 1, consists of three phases: Phase I – Preparing the inspection; Phase II – Starting the inspection; Phase III - Conclusion of the control activity.

Figure 1

The first phase of the inspection is preparatory. The information necessary for carrying out the inspection is acquired by the Commission through:

(i) Documentation relating to the state of the site, collected from the assessments of the Competent Authorities (CA).

(ii) The acquisition of the format provided by the D.Lgs. 105/2015 for the Seveso inspection (check list for carrying out audit, operational experience analysis sheets, events-measures table for critical systems analysis).

(iii) Any further documentation relating to the site relevant to the activities to be carried out (i.e., the status of the site in pandemic conditions and, in particular, indications of any changes or additions to the procedures of the SMS).

It is important to remark that the elements present in the SMS audit checklists are the following: Major accidents prevention policy; Personnel/Training; Hazards evaluation; Operational control; Management of changes; Emergency planning; Performance control and Operational experience; Safety audit and Review.

The second phase, via video conference (VdC), consists of document review and analysis activities on the format of the operational experience and the audit checklist. It is an important moment of comparison with the operator and is also carried out through the sharing of documents remotely. This is for the necessary clarifications/insights on the data acquired; for joint analysis of operational experience sheets, audit checklist and events-measures table; identification and planned examination of the technical, organisational and management systems applied at the site.

After this, the inspection proceeds with the on-site visit and collection of all the evidence to complete the document verification. It is possible to summarise this last phase through:

(i) Clarifications and additions through in-person meeting with the Operator (a/o its representatives).

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(ii) Interviews with workers’ representatives, occupational physician, internal staff and subcontractors.

(iii) Inspection on plants and equipment and relative state of places, preparation of emergency simulations and drills, functional tests of the technical systems, feedback on technical-plant-management systems.

The time spent at sites is kept to the minimum and through a sufficiently detailed preventive plan, the site operator ensures the adoption of specific measures for the prevention of spreading COVID during this time.

Once the documentary examination and on-site inspection activities have been completed, in the third phase the drafting of the final inspection report is completed, after which the results and non-compliances found are communicated to the site operator in a final remote VdC, ensuring everything is clearly understood by the operator.

Case studies from process industries

Information on the status of the sites during the pandemic

Based on experiences taken from inspection activities conducted at several process industry sites (crude oil extraction/process centres, oil refineries and chemical/petrochemical sites) during the pandemic, data and information have been provided.

In these cases, there were no interruptions to production processes or work activities through a general continuation of operational activities of the plants. There were also no consequences on the accident scenarios hypothesised in the Safety Report with the subsequent confirmation of the implementation of the measures provided for in the Internal Emergency Plan. In fact, the presence of individuals with roles in the Internal Emergency Plan is constantly guaranteed according to the responsibilities identified. This therefore guarantees the daily composition of the emergency teams on the site, according to the scenarios taken from the Safety Report.

The management continuity of the site’s activities was ensured, with no interruptions to processes and no changes or additions to significant SMS procedures have been adopted. On the other hand, the documentation in compliance with the “safety at work” legislation has been updated, due to the new mode of staff presence on site. The only reduction of presence of personnel and activities carried out was that of third-party companies. However, it is possible to state that the safe operation of plants was ensured, because the activities on the control operation of the plants was carried out by the internal personnel on shift.

Company measures for the prevention and containment of COVID

The case study companies reorganised certain measures for operational staff and non-operating personnel on site as a result of COVID. The operational staff, operating on three shifts of 12 hours, were reorganised onto single shifts of 12 hours, with the reduction of daily alternation in the plants and minimisation of daily shift changes. The site operators identified similar groups of shift workers (organised in teams), isolated at home, as reserves in the event of members of teams on shift getting infected. For non-operating personnel, the implementation of remote methods was also extended to management, executives, and day workers (60% of the workforce).

The companies implemented new access procedures to the site with dedicated entrance and exit routes, maintaining a distance of one metre for personnel after going through a thermal scanner (no entry if temperature > 37.5 °C). Measures were also put in place at the plants such as the separation of the changing area in the locker rooms and the diversification of access times to company canteens. Regarding closed environments, sanitisation was carried out and surgical masks were distributed. Workers were tasked with ensuring these measures were followed by everyone. Last but not least, face-to-face meetings were avoided by using VdC.

Romualdo Marrazzo, ISPRA

The site operators finally issued measures, in agreement with the workers’ unions, for the containment of COVID cases should there be any infections. A “Contingency Plan” was also introduced consisting of: Management of potential asymptomatic positive cases; Tracking close contacts in the company site; Carrying out screening for detection of potential cases of positive infection and prevention of possible infections; Possibility of “quick COVID test” for entry into the plant a/o for personnel from abroad (in case of multinational companies); Ability to house staff in quarantine for the entire duration of the shift rotation or at accommodation facilities in the nearby area (in case of multinational companies).

Conclusions

It is possible to highlight some lessons learned as a result of the SMS inspection activities carried out during COVID. Some of the non-compliances issued from the inspections concerning management continuity during the pandemic include: respect of time frequencies for training and update sessions; explanation of the contents of training activities carried out remotely, with a final verification session in-person; consultation with worker representatives on mandatory documentation required by the D.Lgs. 105/2015 (MAPP – Major Accidents Prevention Policy, training program, IEP); compliance with the timing and frequency of inspections on some critical technical systems, performed by staff of third-party companies; and checks and controls subject only to actual exercise.

The new method for SMS inspections ensured the continuation of the control activity on Seveso sites during the COVID-19 pandemic. It is important to note the strengths and benefits of the new procedure, including how it allows for a complete preliminary document check while using fewer resources.

In addition, the increase in the number of remote meetings with manager and company representatives compared to the previous activities carried out on-site has made more time available for drafting the final inspection report.

Furthermore, the reduction in site visits and face-to-face meetings has helped guarantee safety and health protection in compliance with COVID-19 protocols.

Finally, it is useful to specify that, based on the strengths that emerged from the inspection activities conducted in the pandemic, it is possible to maintain the new inspection procedure even beyond the pandemic.

References

[1] Center for Chemical Process Safety (CCPS), “Monograph: risk-based process safety during disruptive times”, American Institute of Chemical Engineers, New York, NY, 2020

[2] Occupational Safety and Health Administration (OSHA), “Guidance on Preparing Workplaces for COVID-19”, OSHA 3990-03 2020

[3] Scottish Environment Protection Agency (SEPA), “Control of major accident hazards (COMAH). Temporary Regulatory Guidance Response to COVID-19. Position Statement Withdrawn”, SEPA 2020

About the author:

Romualdo Marrazzo works at ISPRA (Italian National Institute for Environmental Protection and Research) in the Service for Risks and Environmental Sustainability of Technologies, Chemical Substances, Production Processes and Water Services and for Inspections. He holds a Master's degree in environmental engineering and is a national expert qualified as a Health, Safety, and Environment (HSE) Specialist. Romualdo provides technical and scientific support to the Environmental Ministry for the Seveso directives, and he is concerned with international implementation of Seveso directives on behalf of the European Commission Committee of Competent Authorities (EC-CCA). He also conducts inspections on various national industrial installations concerning Seveso and IPPC-IED directives, on a regular basis and after accidents.