Safetip #129: Process Safety Self-Assessment
Worker Safety and Process Safety
A comprehensive occupational safety program addresses both worker safety and process safety, especially in asset-intensive or highly-hazardous industries, such as oil and gas, and chemicals. The aim of process safety is to prevent fires, explosions and other incidents due to accidental releases of hazardous chemicals used in processes.
To reduce the risks of incidents, OSHA has a standard for Process Safety Management of Highly Hazardous Chemicals, while the EU’s Seveso III Directive and the UK’s Control of Major Accident Hazards regulations (COMAH) also include requirements for Process Safety Management.
Process Safety Management is not just about compliance, it is also about enabling safe and efficient operations through the implementation of a corporate governance framework for process safety.
The OECD Guidance for Senior Leaders
To assist organizations with the implementation of a governance framework for process safety, the OECD (Organisation for Economic Co-operation and Development) developed the “Corporate Governance for Process Safety: OECD Guidance for Senior Leaders in High Hazard Industry”.
The guidance identifies the essential elements of corporate governance for process safety, and establishes best practices for senior decision-makers and leaders in the chemical, petrochemical, petroleum and other hazardous industries.
Pages 16-19 of the guidance document include self-assessment questions for senior leaders. The self-assessment aims to show how well your organization is managing process safety. The questions are intended to be answered by senior leaders as a first step, and then questions and answers should be discussed with EHS managers and other staff members to address any gaps or get more information. The questions are divided into the five elements of the corporate governance framework for process safety. Here’s a sample:
Leadership and Culture
- Do you have a policy on corporate governance for process safety which describes management expectations, required commitments, and corporate activities in relation to process safety?
- Do you actively work to remove any barriers to the reporting of “bad news” up the management hierarchy, and promote an open culture for communicating process safety issues?
- Do you go out on plant visits and conduct safety tours, audits or inspections?
- Do you implement the same safety standards for all parts of the organization?
- Do you understand the process safety risks associated with your organization’s operations?
- Do you understand the means of prevention, control and mitigation of major process safety hazards?
- Do you have arrangements in place to ensure safety systems are working effectively, and to seek out areas of weakness?
- Do you have a management of change process to assess changes for process safety impacts arising from changes to organizational structure or the local environment?
- Do you have a process safety management system?
- Do you proactively seek out information relating to process safety on site?
- Are your process safety audits based on ensuring that procedures deliver an effective control of risk, rather than compliance only?
- Do you audit your contractors to ensure they effectively control risk?
- Do you have a full suite of current process safety performance indicators appropriate to the level of risk of your site?
- Are roles and responsibilities clearly defined in relation to process safety?
- Do you have effective process safety competency requirements for all personnel with process safety impacts?
- Do you maintain an intelligent customer role on process safety issues when you have contracted out activities to third parties?
- Do you consider the imported risk from contractors, suppliers or customers, particularly when significant parts are contracted out?
- Do you have a prioritized process safety risk mitigation/improvement plan for every part of the organization?
- Do you ensure that sufficient resources are available to mitigate the consequences of a major accident?
- Do you review key audit and assessment findings, and expedite actions when appropriate?
- Do you have accountability for the completion of corrective actions identified in significant audits, inspections, investigations, and management of change assessments, etc.?
If you’re in an asset-intensive or highly-hazardous industry, consider rolling out the self-assessment to your senior leadership team, and ask them to discuss it with the rest of the organization, to ensure excellence in process safety and mitigate risks of incidents.
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