Process Safety Performance Indicators:

The UK Experience in Major Hazard Industries

Seveso Conference 2010
Stockholm
19 May 2010
Peter Dawson
Principal Process Safety Specialist Inspector
Hazardous Installations Directorate
UK Health and Safety Executive
peter.hid.dawson@hse.gsi.gov.uk

Presentation outline

Terminology and definitions

Where we started and why, in the UK.
Wider perspective - world incident learnings.
How PSPIs can help prevent major incidents.
How PSPIs can be developed and used.
UK approach to PSPI implementation.
PSPI example

Terminology & definitions

Process Safety (PS) prevention, control and

mitigation of incidents and events with potential to
cause death, major injuries and/or significant
damage. Clear distinction from personal safety.
Key Performance Indicator (KPI) includes wide
range of metrics used to measure business,
operational and safety performance.
Process Safety Performance Indicator (PSPI) HSE uses PSPI to mean a small number of selected
site specific indicators for monitoring the
performance of key risk controls. Specific type of
safety KPI.

Where we started and why in the UK

BP Refinery, Grangemouth, Scotland 2000:

A series of loss of containment incidents
prosecution and a record fine.
http://www.hse.gov.uk/comah/bpgrange/

A good safety record when viewed by lost

time incident rate but BP did not know how
well it was managing major hazard risks

Management system discouraged reporting

of bad news senior managers assumption
no news is good news

Where we started and why in the UK

Subsequent enquiries showed that senior managers
of similar sites had:
An overwhelming belief in system design and
integrity and in the regulatory controls
CoMAH/Seveso
No means of discovering deterioration in the risk
controls in place, short of catastrophic failure
Little or no use of KPIs for major hazard risk and
where process safety KPIs were used they were
exclusively lagging.
An over reliance on auditing that focused on
compliance not safety and environmental
outcomes.

World incident learnings

Investigation of chemical and process industry major

incidents worldwide continue to reveal similar failings.

Despite widespread communication of the lessons

incidents keep occurring in the same ways.

Andrew Hopkins book Failure to learn, about the BP

Texas City disaster provides a detailed analysis of
why the company had failed to learn the lessons from
earlier incidents, including BP Grangemouth and Exxon
Longford.

Concludes that a major factor was catastrophic risk

blindness

World incident learnings

Catastrophic risk blindness can arise from;

focusing too much on personal safety using

lost-time accident rates to measure safety

poor understanding of causes of major

incidents different from personal safety

failure to identify and learn from process

upsets & deviations no data collected.

inadequate Process Safety leadership by senior

management

How PSPIs can help

A well designed system of PSPIs can;

provide specific information on how well process

safety risks are being controlled amplifying
existing weak signals before a major incident.

challenge no news is good news attitude to

process safety

allow improvements in process safety controls to

be demonstrated

provide both leading and lagging data for

maximum benefit

How PSPIs can help

Lagging indicators designed to identify failures of safeguards
& controls that can cause upsets or near misses

Initiating event

Operating
Procedures

Possible lagging indicators

Safeguard
defects

Upset

High pressure
alarm/trip
Possible leading indicators

Major
Accident

Pressure relief

Plant integrity inspection

Leading indicators designed to identify weaknesses in key

elements of safeguards & controls that could lead to failure

How PSPIs can be developed

HSE Guidance HSG 254

Developed jointly with CIA

and individual companies
Originally started with post
BP Grangemouth pilot in
Scotland 2003/04
Step by step guide
developed and trialled
HSG 254 published 2006
Clear methodology for
developing PSPIs linked to
MA events for a site.
Available on HSE website.

http://www.hse.gov.uk/pubns/books/hsg254.
htm

How PSPIs can be developed

OECD Guidance on Developing
Safety Performance Indicators
related to Chemical Accident
Prevention, Preparedness and
Response.

Produced by working group on

chemical accidents

Recently revised 2nd edition,

based on pilot programme with
expert review

Uses HSG 254 methodology

Freely available on-line at

Sets out 7-step process with 3

examples, more practical detail
and explanation than HSG 254
http://www.oecd.org/dataoecd/60/39/21568440.pdf

How PSPIs can be developed

New guidance from American
Petroleum Institute

API RP 754 PSPIs for

refining and petrochemical
industries

Defines four tiers of

indicators to provide both
leading and lagging data

Tiers 1 & 2 are loss of

containment events against
defined threshold levels

Tiers 3 & 4 provide

information on the
performance of safety and
management systems.

http://www.api.org/standards/psstandards/

How PSPIs can be developed

Key starting questions for every organisation:

How will the information be used? By whom and

when?

Who is involved in setting the indicators?

Have they been prioritised based on vulnerability to

deterioration and the relative risk that the control
measure protects against?

Do you measure at a sufficient frequency to detect

rapid change?

What will change in the organisation as a result?

Do the indicators match the risk profile of the
business?

How PSPIs can be developed

Lagging & Leading

Causes confusion - the most important issue is to

obtain the right information

Set lagging indicators to show critical deviations

from the desired outcomes failures in risk controls
and safeguards leading to upset or near miss.

All adverse findings must be followed up indicator

doesnt tell you what the problem is!

Set leading indicators for the critical must do

activities/elements of controls/safeguards show
defects or weaknesses in advance of a failure.

How PSPIs can be developed

Site specific v corporate indicators
Site based indicators more closely match the risks
specific to the processes and activities on site.
It is easier to involve the workforce in setting site
indicators compared to corporate more relevant.
Great amount of benefit comes from the analysis
required to set indicators a lot is learnt about the
importance of the various control measures.
Corporate indicators are more suited to benchmark
performance across a number of businesses
Corporate indicators are more relevant where the
same risks and systems for controlling them exist
across businesses

How PSPIs can be developed

PS Leadership is vitally important to ensure:

Process safety is given the right degree of attention

and focus;

Process safety considerations feature in key business

decisions, and

Understanding of major hazard risk and the

importance of critical control measures is
communicated and championed.

Recent UK PSLG Guidance on PS Leadership Principles

http://www.hse.gov.uk/comah/buncefield/pslgprinciples.pdf

UK approach to PSPI implementation

Senior management and employees should be involved in

setting indicators
Indicators should be set following an analysis of the
vulnerability of control measures
The indicators adopted should match the risk profile of the
enterprise
A balance of leading and lagging indicators should be used
A small number of focused indicators should be used to
avoid overload.
CEOs and senior managers should make business decisions
taking account of information from indicators
Information from indicators should be used to improve
performance,
Indicators should be reviewed regularly and changed with
experience

UK approach to PSPI implementation

HSE expectation for all CoMAH/Seveso

sites to have suitable PSPIs in place.

Implementation requires staged approach to

identify, trial and fully implement indicators.

Top tier sites should have PSPIs by 2011

Progress monitored at site inspections.

Lower tier sites 1-2 years later.

Series of workshops held for operators and
trade associations.

PSPI example
PSPIs for a fuel storage depot with pipeline
and jetty filling;

Buncefield, UK, incident 2005 large

vapour cloud explosion arising from
overfilling of petrol storage tank.

Led to establishment of Process Safety

Leadership Group (PSLG)

Final report Safety and environmental

standards for fuel storage sites includes
worked example of PSPIs in Annex 1
http://www.hse.gov.uk/comah/buncefield/fuel-storage-sites.pdf

PSPI example identify major

accident causes and risk controls
Risk control
systems

Challenges to integrity
Overfilling

Control and
instrumentation
Operational
procedures
Competence
Inspection and
maintenance
Design
PTW
Plant change
Control of
contractors

Accidental leakage

Over-pressure

Corrosion

Wear

Physical damage

Subsidence

PSPI example lagging indicators

For each risk control define purpose, or

what success looks like.

Identify a measurable successful

outcome to provide a lagging indicator

For example;

To prevent overpressure of transfer pipeline number

of times pressure >10bar during transfer
To prevent overfilling of tank number of times tank
filled above defined safe fill level

PSPI example leading indicators

Identify critical elements or activities of risk

controls, need to consider which
Must work correctly every time
Are more likely to deteriorate over time
Are undertaken most frequently

For example;
To prevent overpressure number of times ship unloaded
without ship to shore checks correctly completed
To prevent overfilling - % completion of inspections and test
of tank gauging system

Thank you for listening

Any questions?