HSE chair's speech

I congratulate those of you who have been directly involved in establishing the Forum. I am already aware of some of the progress that has been made over the intervening three year period. Including:

• The launch and sign-up to the principles of process safety leadership;
• The follow-up work arising out of the specific lessons of Buncefield such as the shift to higher standards of primary and secondary containment for large fuel storage sites and in electing for high integrity automatic shutdown systems for gasoline tanks;
• The decision to extend your work into other areas through collaborative working within the Chemicals and Downstream Industries Forum to tackle issues such as overfilling of gasoline road tankers; and
• Seeing PSF members joining forces with others including COGENT, the National Skills Academy and the IChemE to develop process safety Management and Leadership standards.

Many of you in this room today will know my views about the unfortunate propensity of the process industries to emphasise differences as a reason for travelling on parallel or different tracks rather than recognising what they have in common and working together. Process safety management and leadership is an area where this makes absolutely no sense and indeed where we need to maximise the sharing of knowledge and learning. I know that some progress has been made in sharing lessons learned through the issuing of safety alerts and so on. But this is one area where there is a real need to break through some of the perceived barriers.

I have listened to some of the arguments - often presented as legal concerns - that companies give for not sharing details with others of their mistakes and lessons learned. Given my background and my experience in the industry I would be the last one to dismiss those arguments in any way. But I still do feel very strongly that they are obstacles to be addressed and overcome so that learning and sharing can take place - they cannot and should not be allowed to be insurmountable obstacles that stop the show.

At the very least, the moral imperative has to be weighed against the legal one. I for one cannot imagine sitting in one company knowing that I had learned an important lesson and then watching the same mistake being made somewhere else with possibly disastrous consequences – because that would mean living with the knowledge that I could have done something to prevent the same tragedy happening twice over. I do not stand before you today knowing the answer to this challenge. But I do know it is one that needs to be tackled as part of this drive to improve process safety performance throughout all of your industries.

Since I spoke at the Leading from the Top conference, it has become increasingly clear that the issues associated with process safety are international. I've addressed packed audiences on the subject in Australia and elsewhere and sadly, the events last year in the Gulf of Mexico on Deepwater Horizon have shown the tendency for large multinational organisations in the petrochemical sector to readily ignore some of the basic principles and control measures which are so necessary to prevent catastrophic events. Closer to home it is sad to see that the commitment which is undoubtedly being shown by people in this room is not yet being translated into measurable improvement in performance.

Looking at lagging indicators first, it's sobering to reflect that HSE's analysis of the industry shows that this year alone there have been around 105 loss of containment incidents categorised as Dangerous Occurrences under RIDDOR, and over half of which were considered to be precursor events for a potential major accident. That equates to over two loss of containment incidents a week, one of which had the clear potential to develop into a major catastrophe.

That's a statistic which should concern us all and in my view needs to turn this debate from one that is about a topic that everyone now recognises is important to one which is both important and urgent that we actually address.

You will be aware that HSE has called upon all COMAH operators to adopt leading and lagging performance indicators by 2015. That means by 2015 at the very latest. It's with regret that I have to report that so far the progress that has been made is less than impressive. It's not clear why this work is problematic and yet there still remains a degree of reticence on the part of many to start with it. The reason cannot be a lack of know-how to develop the indicators as there is plenty of very good guidance available and there have been numerous seminars and events to share knowledge and good experience.

We know it can be done where there is a will to do it. We have been particularly impressed by companies such as Scottish Power, outside of the normal major hazard community, in how they have taken the concepts of process safety management and the use of leading and lagging indicators to drive real improvements in their performance and benefits to the business’ bottom line.

I would urge you all to pick up a copy of their case study to find out more about what they did and how they did it. And when you’ve read it, resist the urge to rationalise it away as being a different industry from yours. Instead, you should think about how you can accelerate the rate or progress in individual businesses and throughout the whole of the sectors you are part of. Scottish Power are not alone within the Power generating industries in embracing the principles of process safety and taking them forward at a faster pace than some of the major hazard process industries. We are seeing leadership and the principles being applied in the industry's approach to emerging energy technologies such as carbon capture and storage and offshore wind generation.

 Admittedly, I suspect that their enthusiasm and their rate of progress has at least something to do with this being a relatively new approach for some of them. I believe that a number of industries here today face a particular challenge in going back and taking a fresh look at some things which have been or should have been addressed long ago - because process safety is not new to the industries here today.

But there are some compelling reasons to come at this subject with a fresh pair of eyes:

• Many of you run facilities today that were owned and designed by others from whom you may or may not have acquired the detailed process design considerations;
• The processes you run today are unlikely to be exactly the same as when the plant was originally commissioned - has every process change been managed and reviewed properly, for instance? Is there a cumulative effect of multiple changes that may have gone undetected?; and
• Much of the process design thinking and training which took place in earlier decades was focused on high volume continuously operating processes. How should these principles be applied to plants which operate batch processes – where the design criteria and the operating parameters may change from batch to batch - not to mention the process safety issues associated with cross contamination and interaction between different processes taking place sequentially in the same operating equipment?

I wanted to use my speech today to throw down some challenges - I'd be surprised if you expected me to do anything else.
But I do want to re-state that I think the progress you have made since 2008 is very encouraging. I am convinced that you are committed to taking this forward for the long term - but that does not mean that you can afford to take too long to get there. Good intentions don’t count for much when disasters happen as some have discovered to their cost.

It is time to treat this work on process safety as not just important but also urgent. We need obstacles to progress to be removed or overcome. We need to see results demonstrated through performance measurement and performance improvement and soon.

Item sourced from http://www.hse.gov.uk/news/index.htm