The distinction between process safety vs personal safety

When we think about safety, we naturally think about the personal safety of individuals who could be
affected, and the various, often more traditional actions that can be taken to reduce the risk of injury
and ill health. Many types of personal accidents are common, and are therefore reasonably
foreseeable. Their control measures are often well established and straightforward to implement,
such as machine guarding, fire precautions, equipment checks, managing slips and trips and the use of
personal protective equipment (PPE). Low personal accident rates or number of days without an
accident are often considered to be a measure of success.
Image of two men working at St Fergus gas terminal in Scotland.
St. Fergus gas terminal, Scotland.©Crown Copyright, Health and Safety Executive

By comparison, process safety (safety in high-hazard process industries) is rather more complicated.
High-hazard process industries include chemical and oil and gas sectors. While they obviously suffer
personal accidents like all other workplaces, there is also the potential for a major incident. This is
because they deal with dangerous chemicals in large amounts and operate processes that, if not well
monitored and controlled, can easily go catastrophically wrong, resulting in major fires and toxic
releases. Major incidents like these are very infrequent events and can be difficult to predict (before
they happen) because of the multiple causes and complexity of what leads to them. Neglecting
seemingly small things (such as an intermittently faulty alarm or general maintenance) can end up
causing a major accident.
In process safety, the emphasis is on the prevention of major disasters that have been historically an
issue for the industry. Process safety needs both complex technical controls (on the plant itself) as
well as a robust safety management system. It requires a great amount of specialist technical
engineering and management skill to get right. Leadership is also important to give suitable high
priority to process safety even though the standards and controls mean that incidents should be rare
and may be outside the experience of operators.
Personal safety and process safety do link together (clearly, there is a risk of slips, trips and falls
occurring in any workplace); however, in process safety, the emphasis is on the prevention of the
high-risk, large scale catastrophic events that, though thankfully rare, could have devastating
consequences.
There are various definitions of process safety management but the definition given by the Institution
of Chemical Engineers (IChemE) is particularly helpful for this course and has been included in the
following Key Term box.

Key Term
Process Safety Management
A blend of engineering and management skills focused on preventing catastrophic accidents and near
misses, particularly structural collapse, explosions, fires and toxic releases associated with loss of
containment of energy or dangerous substances such as chemicals and petroleum products1.

IChemE’s definition is in turn adapted from the Center for Chemical Process Safety (CCPS) publication,
Guidelines for Process Safety Metrics definition2.

It is also important to understand what a process safety management system is for thinking about
how we can control the risks associated with process safety. We will use the definition that follows in
the Key Term box for this qualification.

Key Term
Process safety management system
“An organisation’s management system intended to prevent major incidents arising out of the
production, storage and handling of dangerous substances” (Health and Safety Executive’s Developing
process safety indicators: A step-by-step guide for chemical and major hazard industries (HSG254))3
1.2Process safety leadership

There have been a number of incidents in the process industry that have called into question the way
that safety is managed; specifically, in relation to inadequate leadership and poor organisational
culture.

Focus has historically been on the engineering solutions and design improvements that could be
made; however, the hydrocarbon explosions at Texas City and Buncefield in 2005, and the Macondo
blowout in 2010 (explosion of BP’s Deepwater Horizon offshore drilling unit in 2010), highlighted the
need to focus on not only the physical controls but also the leadership actions that will prevent such
events.

Image showing the after-effects of the fire at Buncefield oil storage facility.
After effects of the fire at Buncefield oil storage facility.
©Crown Copyright, Health and Safety Executive

Activity

Buncefield is discussed throughout this element so it would be useful for you to have an awareness of
the incident. The report into the HSE’s prosecution of companies involved in the Buncefield explosion,
together with photographs and video evidence can be viewed on the HSE website (www.hse.gov.uk).
Review some of the evidence and familiarise yourself with the case.

Hazard and risk awareness of leadership teams

Leaders need to be competent and actively engaged. At least one board member should have a good
understanding of process safety management to help the board understand its organisational process
safety risk, and the impact their decisions will make on this.

History has shown that if process industry leaders do not fundamentally understand the hazards and
risks inherent in their business, unless they are extremely lucky, ignorance may ultimately lead to
disaster. Lack of understanding may arise from things such as lack of technical knowledge or simply
lack of data on which to base a decision (lack of reporting). Leadership teams are key decision-makers.
If, through ignorance, they do not fully appreciate the consequences of their decisions (such as
delaying plant maintenance on old equipment or cutting critical workers), they will make poor
decisions that may make a major accident inevitable. To appreciate this, leaders need to be involved,
competent and actively engaged - it does not happen by chance. They need to be fully aware of the
hazard and risk potential of their processing activities and the potential consequences that decisions
on whether or not to take action may lead to. Though a major incident may never have happened to
the organisation in question, the major accident potential of its processes needs to be treated
seriously alongside other business risks, since it is far more likely to have an impact on reputation and
the survival of the business as a whole.

Clearly, leadership teams must therefore be aware of the hazards and potential impacts of their plant
and sites (at every stage of their life cycle, from design to decommissioning). These impacts could not
only result in life-threatening safety events but also reputational damage and business losses.
Example

In the 1988 Piper Alpha oil rig disaster, 167 lives were lost, insured losses reached £1.7 billion and
impacted 10% of North Sea oil and gas production. Nearly 30 years on, the name “Piper Alpha”
symbolises a monumental failure of process safety and the reputation of the Occidental organisation
was tarnished forever.

Activity

Piper Alpha will be discussed several times in the course, so it would be useful to have an
understanding of the disaster. Use the HSE website, search engines and public access video sites to
understand (briefly) what happened and why the incident had such a profound impact on the industry
and process safety as a whole.

Further, leadership teams need to understand the criticality of the layers of preventive and protective
measures that prevent, detect and mitigate such undesirable events.

For those board members still unsure as to the importance of managing process safety, the
publication Corporate Governance for Process Safety - Guidance for Senior Leaders in High Hazard
Industries1 contains the following statement:

Safe operation and sustainable success in business cannot be separated. Failure to manage process
safety can never deliver good performance in the long term, and the consequences of getting control
of major hazards wrong are extremely costly... Major accidents may not just impact on your bottom
line profitability – they could completely wipe it out. Major incidents in recent years have shown that
the consequences for capital costs, income, insurance costs, investment confidence and shareholder
value can all be drastically affected. So why take the risk? However, getting it right pays large
dividends.

Activity

Consider the organisation or environment that you work in - how confident are you that leaders and
managers are fully aware of the hazard potentials of the organisation’s processes?

Board level visibility and promotion of process safety leadership

The Principles of Process Safety Leadership also place emphasis on board level visibility to promote
process safety.

Directors and senior managers play a key role in promotion of process safety - they provide
leadership, set direction and assign priorities, establish the health and safety tone of the organisation
and ensure that the organisation’s legal responsibilities are met.

As such, their actions are noted by workers and their visible leadership is essential in the development
of the safety culture of the organisation. Leaders need to reinforce personal safety, such as wearing
PPE, but also need to discuss and question the more complex issues such as resourcing and the
process operations. The actions taken at leadership level establish the level of commitment to process
safety that, in turn, helps to achieve the desired positive health and safety culture. Part of being
visible is personally leading initiatives, challenging the organisation (asking difficult questions) and
actually being physically present (visiting sites). In summary, they need to be role models and lead by
example.

The need to define process safety responsibilities

It is not only directors who have a role to play in process safety. Top management will delegate (even
though they will retain overall responsibility and accountability) to their employees. So, other
managers and workers will also have process safety critical roles and responsibilities as part of their
duties. Such responsibilities should only be delegated to those who are competent to carry them out
(or where that competence is actively being developed). These should be clearly defined at all levels;
from the board through to the maintenance workers who look after the installation, everyone has a
role to play in process safety. This is especially so for those with Process Safety Management (PSM)
critical positions. For example, the engineering manager may be responsible for the management of
change process, which ensures that modifications to plant or process are carried out only after
consideration of the safety implications; the maintenance manager may have accountability for the
development and implementation of the preventive maintenance and breakdown strategies, while
the engineers, electricians and fitters may be responsible for contributing to the risk assessments,
following the permit-to-work process and locking off equipment before work commences.

Activity

Consider how confident you are that you understand your process safety responsibilities. What about
your colleagues and senior managers?

The reasons for holding to account all individuals with PSM responsibilities

It is clear that if new plant is installed without due consideration to safety, then the potential for
injuries is high. For example, if everything is correct and an electrician simply takes shortcuts and does
not isolate the system before work, the potential for injury is also high. Everyone with process safety
responsibilities has a role to play and therefore should be held accountable for their actions,
regardless of their organisational level. In the context of an adequately resourced, competent
workforce, holding people accountable also encourages engagement. However, it is very important
for process safety to look for root causes of incidents rather than blaming an individual. Root cause
analysis finds wider failings in the systems, management and leadership. Also, in the example above, a
‘just culture’ would encourage the electrician to report near misses and contribute to the
development of safer working systems, without fear that a single mistake will lead to disciplinary
action. So, we might ask ourselves how such a culture is created, the answer is simple; senior
managers play a pivotal role. Senior managers set the standards for the design of plant, the
operational standards that are acceptable and conversely reinforce the fact that corner cutting and
taking shortcuts is totally unacceptable in process safety. Effective senior managers dedicate
resources to safety and ensure that true root causes are identified after incidents. This theme is
returned to under ‘Organisational learning’.

In the previously referenced Corporate Governance for Process Safety publication, the following
suggestions are made with regard to organisational competence and responsibility. CEOs and leaders
assure their organisation’s competence to manage the hazards of its operations; they:

-understand which questions to ask their workers and know which follow-up actions are necessary;

-ensure there are competent management, engineering, and operational workers at all levels;

-ensure continual development of process safety expertise and learning from new regulation and
guidance;

-provide resources and time for expertise-based hazard and risk analyses, effective training and
comprehensive scenario-planning for potential accidents.

-defer to the expertise of their workers, and do not dismiss expert opinions. They provide a process or
systems to ensure company leaders get expert process safety input as a critical part of the decision
making process for commercial projects or activities;

-ensure that the organisation monitors and reviews the process safety competency of contractors and
third parties; and

-are capable of openly communicating critical aspects of process safety with all internal and external
audiences.

The provision of adequate resources

Process safety needs to be adequately resourced; ensuring adequate resources are in place is the
responsibility of an organisation’s leadership. This helps ensure high PSM standards and resource
knowledge across the organisation. These resources can be:

human - the right number of people with the right skills and experiences;

financial - this may include capital expenditure and operational budgets to allow the plant to operate
safely; and

physical - such as equipment, buildings, offices and rest facilities.

Under-resourcing process safety is very risky. While it may be unreasonable to expect an unlimited
budget or unlimited pool of workers to draw on, it is entirely reasonable to expect a high-risk process
operator to take its responsibilities seriously. The impacts of a process safety incident can be
catastrophic.

Example
In August 2015, a series of explosions at a container storage station in Tianjin, Northern China
resulted in 173 deaths, and 798 non-fatal injuries. Total compensation paid by the insurance group
exceeded 37 million Euros.2

As well as the financial implications of such failures, there are huge moral expectations placed on
employers, that was clear after the Deepwater Horizon explosion in 2010 that saw the chair of BP in
the spotlight for the organisation’s failings and huge public backlash. There are also legal implications
in many countries that place accountability clearly at the feet of the leaders to ensure safety
(including process safety) is adequately managed.

Reasons for establishing process safety objectives and targets

There is an old saying that states “if you aren’t measuring, you aren’t managing” and this is as true for
the process industry sector as it is for any other. The meaning of process safety objectives and targets
is that effective organisations, serious about making safety improvements, will establish a clear set of
objectives (overarching process safety aims) and targets (short term goals) that are cascaded to
workers throughout the organisation at all levels. Leading and lagging process safety indicators (things
that you would measure to indicate progress towards your objectives and targets) should be
established in order to take the organisation towards its goal. These indicators will be discussed in the
context of a process safety management system in Element 2.

There are good reasons for establishing effective process safety objectives, targets and indicators. An
organisation could adopt a ‘wait and see’ approach to safety management, assuming that ‘no news is
good news’. However, a lack of incidents is no guarantee of safety, it could be the result of simply
being lucky. Effective process safety indicators identify safety critical controls and actions, and
monitor these to ensure that operations are running as intended, controls are robust and the site is
therefore under control.

Once these safety indicators and targets have been established, the Board should review progress on
a regular basis (typically quarterly). On an annual basis, the performance against these targets should
be published in order to celebrate success and highlight areas of improvement opportunities. For
many organisations (such as those appearing on the London Stock Exchange), this will be included in
the annual report to shareholders and therefore is publicly available.

Activity

Identify three process safety indicators that are used in your workplace to monitor process safety.
Write these down in advance of starting Element 2.

Commitment to continuous improvement

Leaders should not only actively and effectively monitor the safety performance; they should also
seek to continually improve, for example, by benchmarking against other organisations. Continual
improvement is key to ensuring an effective process safety management system.

Ultimately, process safety, like the personal safety explored at the start of this element, is a never-
ending story. Organisations develop, equipment changes and the desire for further safety
improvements is therefore a continual process. Rather than being disheartening, this is enlightening
as it acknowledges that the best organisations strive continually for the injury-free workplace and
acknowledge that it is achievable with the right level of commitment.

1.3Organisational learning

Individuals learn from mistakes throughout their lives but organisations frequently repeat the same
mistakes they made decades before (this is commonly referred to as ‘corporate amnesia’). In this
section, we will look at why this is so important in process safety and how to ensure organisations
learn.
The significance of learning lessons from incidences of actual or potential consequence
Major incidents cannot easily be ignored - they create a huge amount of damage. As an organisation
(or even as an individual), it is tempting to play down the significance of a near miss that could have
led to a major incident (but was caught in time and averted). For example, if a process line ruptures
during a nightshift and chemical is sprayed into an empty area of the plant, it is easy to categorise this
as a ‘near miss’ or ‘environmental release’. However, if the organisation simply feels relieved it was a
near miss and ignores the true potential, then the root cause may not be fully identified and the
wrong level of response may be given.
When incidents happen to other similar plants or organisations, there can be a tendency towards
complacency and a perception can arise that it could never happen to your own organisation (simply
based on the idea that it has not so far and therefore your organisation must be doing everything
correctly). But, this could just be down to good luck. If investigations are not carried out and lessons
are not learned, the danger is that the very same issue will repeat and next week, next month or next
year, you will not be so lucky.

Activity
Think of a recent process safety incident that has occurred in your workplace that did not result in
injury (for example, a spill or loss of containment). How was the investigation managed? Was it
investigated briefly as a ‘near miss’ or was it viewed as having the potential for a more serious event
and investigated more thoroughly?

The reasons for and benefits of accident and incident investigation

Incidents happen in all workplaces, and the process industry is no different. While hopefully major
incidents and disasters are few and far between, the need to investigate and address the causes of
the minor events should not be underestimated. It is essential to focus not only on what actually
happened, but on the potential.

Key Terms
Immediate cause
Result directly from unsafe acts (for example, worker behaviour, such as ignoring safety instructions)
or unsafe conditions (for example, on-torch fume extraction on a welding gun not working properly).
Root cause
An underlying circumstance that allowed the unsafe condition or act to exist (for example, perhaps
there are inadequate resources for safety training or insufficient supervision or risk assessment). Root
causes are often described as ‘management failures’.

Example
In the Piper Alpha disaster, the immediate cause was the release of flammable liquefied propane gas
(LPG). The root causes of the release included failure of the permit-to-work system, inadequate lock-
out and isolation standards and inadequate design standards.

It may not be necessary to carry out a thorough investigation into all incidents; indeed, some have
little potential for serious harm (for example, minor cuts and bruises may receive a low level of
investigation), but ignoring the true potential of an incident can be a costly mistake. Without a full
understanding of the process (throughout its life cycle) and the interplay with things such as staffing
levels and other organisational changes, it can be difficult to appreciate the potential risk.

Activity
For the incident you have considered in the last Activity, what were the immediate and root causes
that were identified?

As previously discussed it is important to learn from incidents and investigations help with this.
Ultimately, the purpose of the investigation is to prevent the accident from happening again as next
time the outcome could be worse. There are, however, many other good reasons for investigating
accidents and incidents.
These reasons are to:
-identify root causes and underlying causes of the incident;
-prevent the incident happening again (that could result in a more serious outcome next time);
-allow risk assessments to be updated so that organisations learn from past experience;
-document and record the details of the incident for future use;
-meet any legal requirements to report and investigate accidents and to assist with any civil claims
that could result;
-enable patterns and trends to be discovered;
-demonstrate to workers and the public that there is a desire to improve and learn lessons, this will in
turn improve morale in the organisation; and
-determine if any disciplinary actions are needed. Though this can have an impact on morale it is
sometimes necessary in serious cases.
The benefits of accident investigation therefore flow from the reasons for investigation. The benefits
are that:
-once causes have been established, these can be addressed through revised risk assessments and the
risk reduced;
-fewer serious events should occur as lower-level incidents are not allowed to escalate;
-it can provide evidence that the organisation is meeting legal obligations;
-claims will be easier to deal with as the records and reports will be more readily available;
-workers will feel valued as even small incidents will result in action to keep them safe;
-any disciplinary action will be progressed fairly; and
-by considering patterns and trends, hot spots or repeat issues can be addressed.

Documented management processes to retain corporate knowledge

As discussed earlier, the concept of ‘corporate amnesia’ is where organisations fail to retain their
memory of previous incidents. Organisations are made up of individuals. If an organisation fails to
actively record organisational learning (from past incidents), it will only retain that knowledge whilst
specific individuals (those who can remember it) remain with the organisation. When they leave (such
as career move or retirement), the information and understanding is slowly lost until the organisation
is in danger of repeating the same mistakes (or worse, reverses a critical intervention because the
original reasons for doing it were lost). It is therefore essential for organisations to actively capture,
record and share critical information, data and reasoning on which decisions were based, as well as
decisions themselves. In terms of documentation, this would typically include original design
specifications and records of all subsequent plant modifications (management of change is considered
later in this element).
Arrangements with other relevant organisations in sharing lessons learnt
Because major incidents are extremely rare, it is very limiting if organisations only look internally to
learn lessons. A particular organisation may never have suffered a major incident, but there may be
several examples out there of similar organisations, running similar processes, with similar control
arrangements, who have had major incidents or near misses. If this information were shared, the
potential benefits are much greater for the process industry as a whole. Process safety regulators and
industry groups actively encourage information sharing in this way. Some examples of sources of
information are listed in the following Examples box.

Examples
-In the UK, the Health and Safety Executive (HSE) investigates and publishes reports on major
accidents2, emphasising the lessons to learn for related industries. They also publish specific safety
alerts.3
-The ‘Responsible Care’ programme has a global charter for members4. One part of the programme is
the voluntary sharing of information on best practice, risk management and the chemicals that are
produced.
-The UK Institution of Chemical Engineers publishes a ‘Loss Prevention Bulletin’5 that focuses on
incidents and lessons for the wider industry.
-The CSB in the US carries out investigations into major incidents, including (but not confined to)
those related to the process industries. Its results and findings are published and are often
accompanied by videos and case studies6 to highlight deficiencies and where improvements can be
made.
-In the oil and gas contracting sector, the International Association of Drilling Contractors also
publishes safety alerts.7 External information of this type, together with internal data on incidents,
can therefore be used as ‘lessons learnt’ in the continual improvement process.

Activity
Visit the Chemical Safety and Hazard Investigation Board’s (CSB) website at www.csb.gov and look at
the information that is available to assist in process safety, including the videos that can be used for
training. Read the news release into the findings of the Watson Grinding facility propylene explosion
in Houston, Texas in 2020 as an example.1

Purpose and use of benchmarking

Benchmarking is the process of comparing the performance of your own organisation against that of
another, using standard, agreed criteria. This may mean reporting agreed data on a variety of
performance indicators (such as number of unintentional releases/loss of containment events) in a
given period or number of hours worked. When ranked against similar data reported by others in the
industry, this helps in deciding whether your performance is normal for the industry or significantly
better (or worse) than average. This can drive change through the desire to improve.
Benchmarking can also yield benefits when seeking to implement or improve upon procedures. Many
organisations are happy to share documentation such as management of change, permit-to-work and
behavioural observation programme information if it can assist a fellow organisation.
Sources of process safety management information
Process safety management information is necessary for the safe operation and maintenance of
process plant and should be documented, reliable, current and easily available to the people who
need to use it.
Information internal to the organisation that will be needed to operate the plant within its safe
operating envelope (see element 3.1) and to enable potential changes to be properly reviewed for
their impact on safety and reliability could be:
-safety data sheets (SDS);
-process design criteria;
-process flow diagrams;
-safe operating procedures (SOPs) setting safe limits, such as for temperatures, pressures, flows,
compositions and levels as well as evaluation of the effects;
-inspection, audit and investigation reports;
-maintenance records;
-piping and instrument diagrams;
-process control systems, including software integrity;
-relief system designs;
-fire detection and protection plans
External information is often freely available on the Internet. Some examples of useful sources of
process safety management information include:
-manufacturers’ data;
-national legislation;
-trade associations and professional bodies; and
-International, European and British standards, and other authoritative texts.

1.4Management of change

Key Terms
Management of change (MOC)
In high-hazard industries, it is recognised that even seemingly small changes (such as to equipment,
workforce, procedures, and process conditions) can have large potential consequences if they are not
thought through properly beforehand. MOC is a management control approach to make sure that
proposed changes are properly assessed and authorised.

The management of change process

The Flixborough disaster in the UK in 1974 highlighted the need for effective management of change
processes all too well. Modifications to pipework to allow maintenance on a leaking vessel were
carried out without proper consideration of the design requirements and by people without the
required competence. The result was a pipe line that was not rated to withstand the pressures that it
experienced and it ruptured, resulting in a release and explosion that killed 28 people. In the report
into the official inquiry, the following observation was made:
No calculations were done to ascertain whether the bellows or pipe would withstand these strains; no
reference was made to the relevant British Standard or any other accepted standard; no reference
was made to the designer’s guide issued by the manufacturers of the bellows; no drawing of the pipe
was made, other than in chalk on the workshop floor; no pressure testing either of the pipe or the
complete assembly was made before it was fitted. As a result, the assembly as constructed was of
completely unknown strength and failed to comply with the British Standard... 1

Image showing the damage caused after a fire and explosion incident at Nypro Chemicals in
Flixborough.
Nypro Chemicals, Flixborough, fire and explosion incident.©Crown Copyright, Health and Safety
Executive

In the text Chemical Process Safety: Learning from case histories2 such changes are described as
“modifications made with good intentions” and there are many examples of where, despite trying to
do the right thing for the plant, without the correct level of hazard evaluation, risk assessment and
planning, the outcome was undesirable. These include tanks collapsing, road tankers failing and
reactors exploding - at no point did the management intend to do the wrong thing, nevertheless the
outcome was disastrous. There are a number of control measures that should be implemented to
ensure effective management of change, and prevent or reduce the potential for process safety
incidents occurring.
Formal documented system
An effective management of change (MOC) process is a cornerstone of process safety. It is a formally
documented system developed to identify required modifications.
Requirement for hazard and risk analysis
The MOC process requires hazard identification and risk assessment to ensure that the full
implications of any change are understood before it is put into practice, to ensure that new hazards
are not introduced and that existing risks are not increased. It should include procedures for both
permanent and temporary modifications, and will include hardware and software changes. In order to
capture all of the proposed changes, the process must be robustly implemented and this is often
achieved by ensuring that a senior manager champions the process within the organisation, ensuring
it is seen as an enabler rather than a barrier to engineering changes and removing any negative
attitudes.
The MOC process should review the proposed modification to the existing operating parameters and
design criteria. As well as the installation of new plant and equipment, the MOC process should be
used to evaluate and record any planned changes to safety critical devices, replacement of equipment
with non-identical alternatives, changes to alarms or other operating parameters, especially those
that are outside the ‘safe operating envelope’ (this will be covered in more detail in Element 3). In
some circumstances, changes to key workers; for example, changing staffing levels, should be
considered as requiring MOC.
This means that the following documentation may be required to support the MOC application:
-original process design criteria;
-existing process drawings;
-detail of proposed changes, including mechanical and electrical equipment specifications;
-details of trip and alarms planned;
-risk assessments;
-hazard and operability analysis (HAZOP).
Process for all changes to be authorised
The MOC application must be:
-clearly defined and communicated to those in the approval process;
-submitted in advance of the change by the person proposing the modification to all relevant
stakeholders; (for example, engineering, health and safety, production department, research and
development, operational workers, maintenance workers);
-tracked and managed as different stakeholders review and approve or make comments; and
-given final approval by a suitably responsible and competent person(s). Formal approval should be
granted by senior management for the most significant changes (such as removal of safety critical
devices).
Changes documented
All changes to process plant and process design should be correctly documented in order to ensure
process knowledge retention. This means that:
-the MOC file should clearly document all of the changes proposed and be retained as a formal
record;
-any process documents, such as process and instrumentation diagrams and operations manuals
should be updated with relevant changes; and
-the MOC file should be retained with the design specifications for future reference.
Consult and inform
When consulting and informing those affected by the changes, the following needs to be considered:
-Effective change management should be the result of collective decision-making and effective
consultation rather than the decision of one individual.
-Those affected should be consulted through the process and any changes should be communicated
to those affected, including operational workers and maintenance workers.
Training
All workers should be trained in the need for MOC, the circumstances when MOC is necessary and the
process for gaining MOC approval. Those in the approval process should receive additional training to
ensure their competence.
ActivityThink about your MOC process - either, one you are currently working with, or from a previous
role. How effective is it? Is it valued by all involved? Is it rigorously used at all times? Could you make
any improvements?

1.5Worker engagement

Usually, legislation requires employers to consult with their workforce; even when this is not the case,
it is still good practice to do so, and this can be achieved through either direct discussions with the
workers or through worker representatives. This is because the workers have often experienced
situations that give rise to concern or have ideas for improvements that could be made. They also
provide valuable practical insight into the operation of the process that can greatly assist with the
evaluation of proposed changes. Process industries make very extensive use of contractors, so they
should also be involved in consultation. Consultation will necessarily be on a wide variety of subjects
including process hazards, process controls, development of policies and process safety performance.
Benefits and limitations of consultation
An employer does not have to consult with workers on all matters, but there are some circumstances
when it is advisable to do so; these include the:
-introduction of new measures that affect health and safety; these can include new process hazards
and new or revised process controls;
-planning and implementation of new technologies that could affect health and safety;
-appointment of persons to provide health and safety advice or to assist in the development of
emergency procedures;
-development of health and safety training;
-review of health and safety performance and the provision of health and safety information to the
workforce; and
-lessons learnt from incidents and near misses.

Key Terms
Consultation
The two-way exchange of information between parties, in this case between employer and worker.
This is different from and far more effective than the one-way exchange when people are simply
‘informed’ of a decision that has already been taken.

Benefits from consultation are:

-better employer relationship with workers and contractors;
-clear demonstration of management commitment to process safety;
-closer co-operation that improves the safety culture;
-workers feeling more involved and more likely to be co-operative, and procedures more likely to be
adhered to; and
-practical insight into the operation or process and its hazards and operability/maintainability.
Limitations arising from consultation include:
-not all matters being agreed by true consultation - some decisions (such as staffing) may need to be
taken at high level and imposed, and this can result in frustration;
-consultation takes time and this may not always be possible in the case where rapid decision-making
is needed; and
-some poorly structured consultation processes; (for example, poorly managed committees) may be
disruptive rather than consultative, discussing trivial non-safety matters rather than addressing core
process safety issues.

In addition, by engaging with workers, the employer can gain commitment and buy in when
developing and implementing new policies.
Types of consultees and their responsibilities
There are several different methods of consulting with workers; these include:
-Safety committees - a formally established group of worker representatives who meet with
management in order to assist in the two-way communication of information around safety issues.
The representatives are responsible for ensuring that the views of the groups that they represent are
heard.
-Discussion groups - these are groups that are established to discuss issues of mutual interest, that
can be work-related or not. These are often made up of volunteers with an interest in the topic.
-Safety circles - outside the formal discussions that workers may have with their representatives,
workers may meet more informally to discuss safety problems in their workplace. This is an ideas-
sharing group and any issues that require action are highlighted to the safety committee via the
representatives for action.
-Departmental meetings - including health and safety as an agenda item within team and
departmental meetings can provide a good opportunity for workers to voice concerns. These could
then be passed to representatives or to management for action.
-Email and web-based forums - electronic communication media, such as multi-media messaging
groups and online forums, can enable workers who may be remote from a central base or who work
outside of core hours to highlight and voice concerns. These methods will need to be overseen to
ensure that the topics are appropriate and that appropriate issues are taken to the relevant team for
action.

Activity
Write down all of the ways in which your organisation consults with workers. Which are truly
consultative and which are informative? Can this be altered to increase consultation?

Necessity of including workers

Experience has shown that consultation that truly engages with workers yields huge benefits; for
instance, when workers are involved in risk assessments, organisations gain a more accurate picture
of the way the tasks are carried out, and benefit from practical suggestions for improvements and
control measures. When workers are then involved in the development of procedures and safe
systems of work, the implementation is less likely to be met with resistance from workers. In addition,
workers’ representatives can be invaluable during accident investigations and workplace inspections.
Their input ensures that issues are effectively raised and actioned, and helps ensure that inspections
and investigations are conducted accurately and thoroughly.

Reasons for prioritising worker engagement

As consultation and engagement is so important, it should be given high priority by management. For
example, scheduling in committee meetings for the full year, and then sticking to the dates, provides
a clear demonstration by management that they are committed to the process. Management should
participate in the consultation process and not cancel meetings or fail to attend as that undermines
the importance of the process. Plant stand downs or all staff meetings can also be a useful
demonstration of their commitment to engage with the workers. As a critical safety process, the
arrangements for consulting and engaging should be audited like any other element of the safety
management system.
The audit could include:
-measurement of the number of the scheduled meetings that were held against the plan;
-the attendance at the meeting and the number of departments represented;
-the accuracy of the minutes and the rate of completion of any actions; and
-the effectiveness of communications and extent to which they reached workers.
The findings should be reported to senior management as part of the audit of the safety management
system.

1.6Competence

Competence is a core requirement for leaders (understanding the process and implications of
decisions) when learning lessons, properly assessing and properly managing change.
The meaning of competence

Key Term
Competence
The ability to undertake responsibilities and to perform activities to a relevant standard, as necessary,
to ensure process safety and prevent major accidents. Competence is a combination of knowledge
skills and experience and requires a willingness and reliability that work activities will be undertaken
in accordance with agreed standards, rules and procedures.1

There are legal requirements in many countries for employers to employ competent workers - but
what is competence? Competence has been defined over the years in many ways but, simply put, it is
the blend of knowledge, skills and experience that enables a person to perform tasks well. It is more
than completion of a course or obtaining a certificate, but a process that also requires the person to
obtain practical experience to support their training.
The role of competence in safe working and behaviours
In health and safety terms, workers should be provided with training so that they know how to
perform their job safely, from the day-to-day operational tasks in the production area, through to
emergency procedures and specialist training for safety representatives, first aiders or emergency
team members.
Training ensures that workers have the relevant knowledge, skills and experience to perform activities
to agreed standards, rules and procedures. From the day-to-day operational tasks within the plant to
the emergency response, permit-to-work and isolation procedures that are so important in process
safety. Without adequate training, the decision as to what is the safe way or the best way to do a job
would be left to the discretion of the individuals and this would result in wide and varied working
standards. When the standards are clear, it is also easier for supervisors to monitor worker behaviour
to ensure that compliance is maintained.
By training and ensuring the workers are competent, the employer can expect that a high level of
compliance with safe working practices will be achieved, and that worker behaviours will be excellent.
Benefits of training include:
-new workers or those moving into a role can understand the requirements of the job much faster
and are therefore safer;
-training to the correct standards will also ensure that the correct method of work is passed on rather
than bad habits and unsafe actions; and
-when tasks are performed to the right standard, fewer mistakes are made and productivity is
generally higher. Well trained workers also feel valued and a solid training programme can assist in
career development.

Activity
Training is an essential part of building competency. Consider when and how you carry out safety
training. Do you hold refresher training in safety topics? Are new workers more up to date with
standards and requirements (after their safety induction) than longer-term workers?

Competency management systems

Not all workers need skills in all areas. While many requirements will be common to all workers, such
as action to be taken on hearing an emergency alarm, many will depend on the role that people fulfil.
For example, production operators will require training in permit-to-work, office-based workers may
not, and others will require specialist skills such as fire-fighting or first-aid training. Some workers will
be specifically recruited for their technical expertise (such as chemical engineers) but will still need
site and process-specific training. Key to this is defining the process safety-critical tasks that need to
be carried out (routine, non-routine and emergency). Techniques such as task analysis (the structured
approach of analysing a task by breaking it down into its component parts and considering the
hazards at each stage of the task) will help here, as the tasks are looked at in detail (including
potential for human error) and the skill-sets required for each step determined.
Different skill-set requirements (including the level and standard) can be incorporated into defined
roles. Many organisations develop a training matrix as a starting point for developing individual
competence and to provide a framework for career progression.
The following table shows an extract from a training matrix.

Role
Basic induction
Permit-to-work
Lock-out and isolation

Production operator

Shift fitter

Quality technician

Process engineer

Admin assistant

Risk assessment
Management of change
Fire extinguisher

Production operator
Shift fitter

Quality technician

Process engineer

Admin assistant

The European Process Safety Centre2 guidance suggests the following framework for competence
management systems for process safety:
1.High-level policy statement – just like any other priority, it needs commitment from the top.
2.Facility minimum process safety competence (PSC) requirements – this is where the facility
minimum PSC requirements are identified and defined. For example, you might always need someone
on hand with deep understanding of exothermic reactions and control of thermal runaways. Other
requirements might depend on the life-cycle of the plant (such as the design and build and
commissioning vs normal use, for example).
3.Selection and recruitment of workers – a process for recruiting people with the right skills.
4.Individual competence needs analysis and managing competence gaps – this is making the general
site requirements very specific for the needs of the task or role to be carried out. People are
measured against these requirements and competence gaps identified.

5.Maintaining competence, training and development – the identified gaps are filled with relevant
training and other interventions. Refresher training will help maintain this.
6.Competence assessment and re-assessment – Training is vital, but the ability to carry out the
required critical function needs to be assessed and periodically re-assessed.
7.Special competence requirements for emergency situations – emergencies (abnormal situations)
subject people to much greater pressure than routine operation, so demands special training; for
example, to cope with the psychological stress and having to rapidly diagnose and act to bring a
process back under control.
8.Ownership and commitment – individuals need to be encouraged to be fully engaged in the need
for, and development of, competence.
9.Continuous improvement – the effectiveness of the PSC management system itself needs to be
periodically reviewed (for example, competence requirements change over the life of a site).

Activity
Think about how you check competency after training. Attending a training session is one part of the
jigsaw, but how does your organisation ensure that after training workers are truly competent?

Training and development programmes applicable to process safety risk

Some process safety risks are widely applicable across the sector and there are general training
courses aimed at different levels within the process industry. These tend to fall into three groups,
aimed at:
-process safety leaders (senior executives and directors), giving an overview of their responsibilities;
-managers, supervisors, designers, safety advisers and newly qualified engineers, giving fundamentals
of PSM; and
-operators and technicians, giving a detailed understanding of specific process hazards and controls
that they are likely to encounter on site.
However, it is important not to limit the training to standard operating conditions, training may also
be needed in non-standard operations (such as those covered in management of change processes)
and also emergency situations (where safe shut-down is critical). These may also include practical
exercises.
Image showing technician working on site.