Process safety leadership – what have we learnt?
13 June 2023
When considering process safety incidents, including many of the most high-profile safety occurrences, it is clear that leadership failures are a significant causal factor irrespective of industry or sector. Therefore, an active and continuous focus on leadership is essential to ensure that risks are not only properly managed but also understood.
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Following the Buncefield explosions and fires of 2005, industry, trade unions and the COMAH Competent Authority (CA) established the Process Safety Leadership Group (PSLG) to carry out a dialogue to jointly develop, progress and implement meaningful, effective recommendations and practices that improve safety. In 2009, the PSLG published its Principles of Process Safety Leadership, which are aimed at providing the foundation to ensure high reliability organisations. These are eight principles for senior industry leaders to follow and include board level active engagement and competence in safety management, engagement and involvement of the workforce in managing safety, as well as sharing best practice across industry sectors, and learning and implementing lessons from relevant incidents in other organisations in order to maintain the currency of corporate knowledge and competence.
These principles have now been widely adopted across the chemical and downstream oil industries. Furthermore, the COMAH Competent Authority in the UK has developed an operational delivery guide based on the principles, which is used to carry out site-based interventions.
What is Major Hazard Leadership and why is it so important?
High standards of leadership are essential to ensure effective control of major hazard risks. And it is essential to understand the implications of business decisions on major hazard management, both in the short term and in the long term, with this last point also representing one of the principles developed by the PSLG. Good Major Hazard Leadership helps organisations to ensure that risks are given the resource, priority and attention required to reduce the likelihood of a major accident. It is also critical to the sustained management of risks. In this context, senior leaders need to not only understand what can go wrong that could cause a major accident, but also what systems are in place to stop this from happening and have access to the right information to provide assurance that those systems are working effectively.
The Tank Storage Association is a founding member of the UK COMAH Strategic Forum, a high-level joint industry and regulator forum established in 2013 to improve major accident hazard leadership, management and raise standards across the industry.
In 2019, the COMAH Strategic Forum launched the ‘Year of Major Hazard Leadership’. To coincide with this important initiative, the COMAH Competent Authority (CA) published its Operational Delivery Guide ‘Inspecting Major Hazard Leadership and Investigating Leadership Failures in Major Accidents and the supporting Major Hazard Leadership Intervention Tool’. The Operational Delivery Guide is part of the COMAH CA strategy aimed at encouraging strong leadership and preventing major accidents. It underpins the CA’s programme for ensuring effective leadership in preventing, controlling and mitigating major accidents and covers the background and arrangements for inspection and investigation of leadership. The separate Major Hazard Leadership Intervention Tool provides the principles to use when engaging with senior leaders.
Inspections by CA partners began in 2021. The expectation of the COMAH CA when carrying out a Major Hazard Leadership intervention is to seek to ensure that leadership and process safety competency are demonstrated at all levels within the business, that the risk profile of the site is understood, and sound risk assessment has been carried out. In addition, Major Hazard Leadership intervention is aimed at ensuring that there is effective communications, a robust management of change procedure in place and that the integrity of operations is maintained and not compromised for short term gain. Intervention further seeks to ensure that the business is a learning organisation – in that there are effective arrangements in place to share and learn from best practice and knowledge both internally and externally from the business – and process safety performance is reported to, and understood by, senior leaders.
Each COMAH operator visited as part of the Major Hazard Leadership interventions is scored using the performance rating table contained in the Operational Delivery Guide. This rates the operator between 10 (strong assurance that the site meets the requirements of the process safety leadership principles) and 60 (there is no assurance that the site meets the requirements of the process safety leadership principles).
At the time of writing, operators that have been subjected to an intervention were allocated the scores shown in Figure 1 below:
Lessons learned from interventions
To encourage best practice, it is important to understand and share common themes and recommendations arising from these leadership interventions. This gives operators the opportunity to learn from common mistakes and strengthen their own processes. Common themes and trends emerging from the Major Hazard Leadership inspections carried out to date include:
1. Safety leadership is at the core of managing a major hazard business
- Major Hazard Leadership should be clearly defined and written into every senior leader’s job description
- Change management is critically important and there should be a robust system in place
The PSLG was established following the Buncefield fire in 2005 – Image: Wikimedia
- The environment is also part of COMAH compliance and must be considered when effectively managing the business
2. Major hazard leadership requires board level involvement and competence
- Competence on Major Hazard Leadership is required at Board level – it should not be left to one individual
- Read and understand the key elements of the Safety Report
- Senior leaders headquartered outside of the UK may not have a clear understanding of the UK COMAH regulations and the risk-based approach to safety
3. Good major hazard management does not happen by chance and requires constant active engagement
- There is no one-size-fits all solution to Major Hazard Leadership, each business and each site is unique and has unique challenges
- Plan changes appropriately and with plenty of time. If there are known delays (for example in updating Safety Report) advise the COMAH CA as required
4. Board-level visibility and promotion of major hazard leadership is essential to set a positive safety culture throughout the organisation
5. Engagement of the workforce is needed in the promotion and achievement of good major hazard control leadership
- Communication within the business is key, both upwards and downwards
6. Monitoring major hazard performance is central to ensuring business risks are being effectively managed
- Be aware of your Safety Management System and monitor how effective and efficient it is
7. Publication of major hazard performance information provides important assurance about the management of risks by an organisation
- Key Performance Indicators (KPI’s) for process safety should be understood, reviewed and refreshed to avoid complacency
8. Sharing best practice across industry sectors, and learning & implementing lessons from relevant incidents in other organisations, are important to maintain the currency of corporate knowledge and competence
Peter Davidson, TSA
- The COMAH CA is open to working together with COMAH Operators to improve Major Hazard Leadership. If there are concerns or queries, these should be discussed in the first instance with the COMAH Intervention Manager. Relevant Trade Associations may also be able to assist sharing best practice and lessons.
What more can be done?
It is important that operators do not focus solely on the lessons from interventions already carried out, but also consider what more can be done.
Communication is key, and senior leaders should strive to ensure staff at all levels within the business, including operators, supervisors, health and safety professionals and managers, are actively engaged in order to determine if there are any issues that are concerning them. They should also ensure that they are exposed to all relevant information that demonstrates to them how well their systems and processes are working – for example, are actions legal raised by regulators communicated and understood by senior management teams?
One emerging trend from the leadership interventions is that those senior leaders who were exposed to and are aware of the Process Safety Leadership Group (PSLG) Principles of Process Safety Leadership, and who had attended relevant Safety Leadership training, were able to better understand the challenges to their business and respond more effectively to the questions raised as part of the Major Hazard Leadership inspection.
Businesses should seek to ensure that all senior leaders have the appropriate training to give them a clear insight into how to embed process safety management and promote a positive safety culture throughout their organisation, as well as ensure that suitable and sufficient resources are in place to continually develop staff competency.
Key Performance Indicators (KPIs)
KPIs for process safety, sometimes referred to as Process Safety Performance Indicators (PSPIs), are an essential tool to understand the safety performance of a business.
Senior leaders should work with their teams to ensure that KPIs are meaningful, useful and give the correct information. They should understand and be prepared to challenge the information that they are given, and most importantly they must be prepared to act on any warning signs that those indicators present.
The themes and learnings from recent Process Safety Leadership interventions can be summarised into three areas. Firstly, the essential need for leaders to ensure effective communication to improve process safety across the entire organisation. Secondly, leaders, regardless of their role or responsibilities, should be able to demonstrate an appropriate level of process safety competency.
Finally, leaders should understand the importance of having an effective set of process safety performance indicators and be prepared to challenge what those indicators report to seek to continuously improve process safety performance.
All senior leaders in major accident hazard businesses, including those regulated by COMAH and those who manage major hazards that come under different regulatory regimes, should consider how effective process safety leadership really is across their organisation, and use the resources available to them (including information published by the UK’s COMAH Strategic Forum) to develop an informed and achievable improvement plan.
About the author:
Peter Davidson is Executive Director of the Tank Storage Association (TSA) which represents the interests of over 45 companies who operate around 300 terminals in the UK or provide equipment and services to the sector. Peter joined TSA following 10 years as the director of Safety, Commercial & Projects at the UK Petroleum Industry Association. Previous to this, Peter managed the Safety Automation Group for ABB in the UK. Peter has responsibility for the day-to-day management of the association, leading on lobbying & advocacy activities and working with the Federation of European Tank Storage Associations (FETSA).
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