Seminar One Introduction to Safety Case. Date 11 April 2006. Seminar One is a basic introduction to Safety Case and the MHF Regulations 2000. Its timing has been triggered by the commencement of Round 2 Licencing activity It has been developed for the following purposes:
Date 11 April 2006
It has been developed for the following purposes:
To provide a brief and simple overview of the main parts of a safety case
To be suitable for new MHF Operators
Examples of incidents
Context of MHF Regulations
Outlines the reason for a safety caseIntroduction
Coode Island, Australia – storage terminal fire, August 1991, no injury.
Longford, Australia – explosion and fire, September 1998, 2 dead, led to the development of Victorian MHF legislation
Texas City, USA – fire and explosion, March 2005, 15 dead, over 170 injured
Crude Unit, Tosco Corporation’s Avon oil refinery, Martinez, California.
Workers were attempting to replace piping attached to an online 150-foot-tall distillation column
Piping released naphtha which ignited. The flames engulfed fire workers who were located at different heights on the column
Four men were killed and one seriously injured.Why is a Safety Case Needed?
1. Tosco Avon refinery management did not conduct an MOC review of operational changes that led to excessive corrosion rates in the naphtha piping.
Above design rates
Feed contained high water levels
Prolonged operation on LV bypass valve caused ineffective line isolation
2. The crude unit corrosion control program was inadequate.Why is a Safety Case Needed?
Bhopal, India – Dec 1984
Toxic release – methyl isocyanate
3000 to 8000 deaths, $0.3b to $3b
Buncefield Incident – 11th December 2005
(Currently under investigation by UK HSE)
40 injured, no fatalities
Changing scale and complexity of specific facilities
Housing encroachment into MHF buffer zones
Changing community perceptions
Loss of Corporate Knowledge associated with ageing plant and mobile workforce
Range of major accidents that have occurred
Prescriptive approach has proven inappropriateWhy is a Safety Case Needed?
the Operator is expected to know what technical and human activities occur
The Operator decides on the appropriate means of major hazard control for the facility, and prepares a SC explaining this
The Regulator assesses and audits performance adequacy against the SCWhy do we need a Safety Case?
Safety Case Submissions Rd 1 2002
Introduction of MHF Regulations Jul 00
Longford Royal Commission Report Jul 99
Longford Explosion Sep 98
Australian National Standard for Control of MHFs 96
Coode Island Fire 91Background - The MHF Regulations
Flixborough 74, Seveso 76, Bhopal 84, Piper Alpha 88
Proactive risk based approach
Places the responsibility on the facility Operator
Facility Operator actively has to demonstrate safe operationOverview - Key Principles of MHF Regs
Consultation with different parties required at all critical stages
Addresses both on-site and off-site safety
Regulator ‘ review’ of this, tied to a licence
Very high risks
Relative Frequency of Occurrence
Focus of MHF Regulations is
high consequence (catastrophic)
but low frequency incidents
Consequence - Severity
Confined Spaces Regulations
Haz Substances Regulations
Dangerous Goods (S&H) Regulations
Safety management system (R301)
Hazard identification (R302)
Safety assessment (R303)
Control measures (R304)
Emergency planning (R305)
Review of risk controls (R306, R404)
Consultation - HSRs, employees, community (R501, R505, OHS Act)Overview – MHF Regulations
An uncontrolled incident that involves schedule 1 materials; and
Poses a serious and immediate risk to health and safetyWhat is the Safety Case?
hazard identification and control mechanisms in place to prevent and mitigate all MIs for the facility
the types of safety studies undertaken
the results obtained from such studies
the management arrangements in place
to ensure the continued safety of the facility, its
people and the surrounding communityWhat is the Safety Case?
Demonstrate to the satisfaction of WorkSafe, through content and supporting material, that:
the operator knows what technical and human activities occur
how hazards are managed
how safety will be managed in the event of an emergencyWhat must the Safety Case do?
Identify methods to be used for monitoring and reviewing all activities for continuous improvement of the safety arrangements of the facility over its lifetime.
The Safety Case must contain a summary of the SMS elements including:
Safety policy and objectives
Organisation and structure
Means to achieve Part 3 (Safety Duties) and 5 (Consulting, Informing) compliance
Management of change
Principles and standards
Ref Sched 2Main Components of a Safety Case
Identification of all the major incidents which could occur.
Identification of all the hazards that could cause or contribute to causing a major incident.
Methods and criteria for identifying and assessing the above.Main Components of a Safety Case
More on Safety Assessment follows…..
Hazard identification – for determining MIs
Risk reduction studies – for determining controls
Emergency scenarios– for training and controls
Risk evaluation - for determining risk acceptability
Recommendations and review – for continuous improvement
Main Components of Safety Assessment
Process Hazard Identification
Risk Assessment (RA)
Unit Technical Review Input
Major Incident Event
Analysis and Assessment of the hazards and potential MIs on site using
LOPA Risk matrix
Provides a more detailed analysis of causes/frequency/outcomes/controls for each identified MI
Can enable risk offsite to be assessed
Enables comparison of risk reduction optionsSafety Assessment
PLANT EMERGENCY RESPONSE
PHYSICAL PROTECTION &
CRITICAL ALARMS AND
DESIGNLayer of Protection Analysis
Determination of the fire water and foam requirements for extinguishing the fire and/or protecting affected equipment
Available as a resource for training in specific scenariosEmergency Incident Scenario Plans
Analysis of the impact of MIs on occupied buildings
Mainly risks (due to flame impingement, explosions, toxic gas) from other buildings/operations
What Else is in a Safety Case Report?
Opportunities to reduce risk are identified
Recommendations are assessed and prioritised
An action plan is developed and implemented SFARP
What Else is in a Safety Case Report?
at the direction of the Authority
prior to modification
after a major incident
when a control measure is found to be deficient
Upon licence renewal or at least every 5 years
New information becomes available regarding possible MI hazards previously unknownSC Review & Revise
Safety Duties are ongoing requirements
An Operator of a major hazard facility who fails to comply with the MHF regulations could jeopardise the continuation of their licence.Summary
Major Hazard Facilities Regulations – Guidance Notes, WorkSafe
WorkSafe Victoria www.workcover.vic.gov.au
NSW Major Industry Hazard Advisory Papers 1 to 9
Centre for Chemical Process Safety
UK Health and Safety Executive, www.hse.gov/comahSources of Additional Information