The Safety Report

As envisaged in the amended MHI Regulations South Africa

Presented at the MHI Workshop, Johannesburg

27 October 2017

By

Motlatsi Mabaso CEng MIChemE

Director:

MMRisk | Process Safety Consultants

Presentation Outline

• Key Concepts

• When and Why to compile a Safety Report

• Overall structure of the Safety Report

• The Approval Process for Safety Reports

• Elements forming part of a Safety Report/ Safety Case

• The Process Safety Management System

• Discussion and Conclusions

Key Concepts

• Dutyholder Company/Organisation that runs/ controls a Major Hazard Installation/ Establishment

• Hazard “Something with a potential of going wrong”

• QRA Quantified Risk Assessment = a quantitative account of hazards identified, their likelihood of being realised and the effects if they are realised. This includes an assessment of Risk results against defined criteria. Risk = combination of consequence (effects) and likelihood

• ALARP As Low As Reasonably Practicable Measurement concept: the point at which any further costs incurred to reduce risk are grossly disproportionate to the risk reduction benefits gained. (“Optimal Stopping Point”)

When to compile a Safety Report (SR)

For High Hazard facilities • Safety Report demonstrates and reassures that you have:

1. Identified the hazards at your facility;

2. put in the appropriate measures to: a) Prevent them from occurring

b) Limiting their extent if realised

3. Considered strategies to manage your risk to ALARP

Quantified Risk

Assessment

(QRA),

Emergency

Response Plan

(ERP)

QRA,

Major Incident

Prevention Plan (MIPP),

Safety Management

System (SMS)

FACILITY HAZARD RATING

QRA, MIPP,

Safety Report

(SR), SMS

… and why compile one

Safety Report Overall Structure

1. Information on Safety Management System of the Organisation • How are you structured to prevent major incident hazards?

2. The location of the establishment • Where are you located geographically, any special features, who are your

neighbours?

3. The establishment • What are the specifics of your process and materials handled?

4. Hazard identification and incident risk analysis • What hazards exist, what are the effects and likelihoods of occurrence?

5. Measures of protection & intervention to limit consequences of a major incident • Now that you’ve quantified your Risk, how will you manage it?

Safety Report approval process Regulation in Force

Safety Report compilation

Management System Implementation

Obtaining Final Approval

Licence to Operate (LtO)

• Granted by the Dept of Labour

• Licence will have to be maintained through inspection/ audit

• Safety Management Systems will have to be implemented, maintained and improved

Official approval/ consent to operate, based on satisfaction

that the Dutyholder has identified and understood all

operational requirements to protect the public, workers and

the environment.

Proposed Safety Report approval process (High Hazard Facilities)

Licence

to

Operate

Safety Report Contents: 2. The environment of the establishment

• Geographic location

• Meterological information

• Topography information (hills, valleys, open water?)

• Other Hazardous Facilities

• Sensitive receptors

Safety Report Contents: 3. The establishment

• Describe main activities

• Describe chemical processes

• Describe Dangerous substances • Identities (IUPAC, CAS, etc.)

• Maximum quantities

• Flash point, toxicity data, etc.

• Loss of containment behaviour

• Major accident hazards

• Proposed preventive measures

Safety Report Contents: 4. Hazard Identification and incident risk analysis

• Potential major incident scenarios (and their causes/ hazard sources)

• Probability and consequence

• Assess prevention, control and mitigation measures

• In Safety Report: Main findings and arguments of Risk Analysis

• Clear indication of standards used (SANS 1461 requirements)

Safety Report Contents: 5. Measures of protection & intervention to limit consequences of a major incident • Identify Safety Critical Elements

(SCEs)

• Define their performance criteria • What should the equipment do in an

emergency? • Is it likely to do what it’s supposed

to?

• SCEs may include: • Detection and protection systems • Shut off valves • Water curtains • Loss of containment response

equipment

Safety Report Contents: 1. Information on Management System of the Organisation

[PROCESS] SAFETY MANAGEMENT SYSTEM:

• Implements Major Incident Prevention Plan (MIPP) objectives

• Compares to: • ISO 14001 (Environmental Management System);

• ISO 9001 (Quality Management System)

• OHSAS 18001 or ISO 45001 (Occupational Health and Safety)

• A central Safety Management Manual • Aims and objectives of system

• Guide reader to policies, records and procedures to address the aims and objectives

Safety Management System Elements to be addressed (Page 1 of 4)

• GENERAL DESCRIPTION AND OVERVIEW • Describes the management system structure

• LEADERSHIP AND COMMITMENT • Statements and policies showing senior management commitment

• POLICY AND STRATEGIC OBJECTIVES • Drafting of Safety Management policy/ philosophy

• ORGANISATION, RESOURCES AND DOCUMENTATION • Organograms, equipment and people, document control

Safety Management System Elements to be addressed (Page 2 of 4)

• ROLES, RESPONSIBILITIES, TRAINING AND COMPETENCY • Of all people involved in the management of major hazards

• HAZARDS AND EFFECTS MANAGEMENT • Reference to HAZID procedures, HAZOP procedures, Hazards and

Effects Register templates/ procedures, Risk Assessment Matrices

• SUBCONTRACTOR AND SUPPLIER MANAGEMENT • Keeping registers, ensuring that they have safety management plans

and/or adequately trained on safety

Safety Management System Elements to be addressed (Page 3 of 4)

• FACILITIES DESIGN AND CONSTRUCTION • How has safety been taken into account? Reference to Siting Studies,

Occupied Buildings assessments, Construction Safety Policies, Safety and Risk Standards wrt Building and Equipment Design

• OPERATIONS AND MAINTENANCE • Reference to procedures and instructions for safe operation, maintenance,

alarm management, Management of Change

• MANAGEMENT OF CHANGE • procedures for planning modifications and design of new installations

• CRISIS AND EMERGENCY MANAGEMENT • Reference to Emergency response plans, procedures, organograms, escape

routes, escape equipment, PPE, etc.

Safety Management System Elements to be addressed (Page 4 of 4)

• INCIDENT NOTIFICATION, INVESTIGATION AND REPORTING • Philosophy, targets, standards and procedures for incident reporting

• PERFORMANCE MONITORING, AUDIT AND ASSESSMENT • Performance against stated objectives in the MIPP. Reference to audit

templates and procedures.

• PERFORMANCE REVIEW, CORRECTIVE ACTIONS AND CONTINUAL IMPROVEMENT • Procedures for preventing, identifying and managing non-

conformances and breaches of the system.

Discussion

• Self-Regulation Co-Regulation

• Hazard level approach: Approach will be proportional to the Risk

• Conversation/ Dialogue between Dutyholders and the Authorities, not Teacher/ student relationship

• Safety management will require more effort Robust system

• Safety Reports the AIAs will be very useful in guiding Dutyholders

Dipotso? Any questions? Not too difficult please!