UK Perspectives on Process Safety Management
There are marked differences between the legislation in North America and legislation in the United Kingdom. In the United States, there is a strong code-based approach to hazard management, which, like any other technique, has good points and bad points. The code-based approach can be very good because then companies know exactly what their responsibilities are to the law. It is quite different in the United Kingdom.
In this newsletter, John Barker tells us what started the development of process safety regulations in the United Kingdom and how the country approaches process safety.
Lessons Learned on Process Safety
About 30 miles or so from Bath is a small mining town in Aberfan, Wales. Coal mining was once a major industry in the United Kingdom. A hundred years ago coal was mined in huge quantities and utilized for steel and energy production. The port in Cardiff, which is the capital city of Wales, was known in the last century as the busiest coal-exporting port in the world. There was a huge amount of mining activity in Wales.
Aberfan became famous for the wrong reasons. On October 21, 1966, a spoil tip near the village of Aberfan collapsed. A spoil tip is a pile of waste rock and soil removed during coal mining. The National Coal Board (NCB) had run out of space on the valley floor, and begun placing colliery spoil tips on the mountainside above the village. After particularly heavy rains, liquefaction occurred in the tip, which caused the material of the tip to collapse and engulf the village killing 116 children and 28 adults.
It was a national disaster when it happened, and even now the community hasn’t recovered from it. If you look at the demographics in Wales, there is a huge dip in 50 to 60-year-olds in that part of the world. It is very sad and tragic. The incident led to the formation of the primary health and safety legislation in the United Kingdom, the Health and Safety at Work etc. Act of 1974.
Many incidents and accidents influence the creation of process safety legal standards. If you work in the United Kingdom in any risk management role, you'll come across HSWA 1974 legislation. It has a lot of impact on ioMosaic Corporation ’s approach in Europe. Some of the features and functionalities in Process Safety Office? SuperChems? software came about because of HSWA. For example, we plot societal risk and plot risk contours and present results both graphically and numerically. Figure 2 shows an example of a societal risk chart where the adverse outcome considered is immediate fatality resulting from fire, explosion, or exposure to toxic vapors. Societal risk measures are important for managing risk in a situation where there is a potential for accidents impacting more than one person.
UK Regulatory History
The way risk and probability are discussed and considered in Europe started back in the 1970s. HSWA 1974 was the start of a whole series of Acts of Parliament, regulations, and guidance shaping international approaches to risk management. All of these regulations refer back to the HSWA regulation which established guidelines for what is expected of employers when it comes to protecting both the workforce and the public.
A lot of the European legislation on risk management and the way we work with risk was actually driven by European Union legislation. For example, if the European Union decided to adopt a new directive on explosive atmospheres, the requirements would be enacted by all of Europe. This method might be comparable to the way the United States Federal law would affect individual states.
It is very interesting that when Brexit came to the forefront of Britain's politics, one of the first meaningful changes in legislation was in risk management, converting EU-derived legislation into UK law to ensure the continuity of standards and practices. HSWA 1974 also remains in place.
What is Health and Safety
In the United Kingdom, if you say, “I do health and safety work,” most people will likely assume this involves restaurant inspections ― checking to see if the equipment is working properly, or taking food temperatures, and things like that. This can get quite irritating sometimes because health and safety is a serious business. It is not about preventing people from drinking sour milk or checking if the coffee is too hot. It's about preventing catastrophic loss.
Measuring Risk Tolerability
Within European risk management, we are very interested in the tolerability of risk. Once the level of risk is calculated, next look at whether the risk exceeds a certain threshold. ALARP or ‘as low as reasonably practicable’ considers common risks and the comparable level of exposure caused by the specific risk. What the UK regulations say is that if you are exposing workers to levels of risk that far exceed everyday risk, then you need to do something about it.
Reference points are taken from common everyday risks, like for example, the risk of driving a vehicle. In the United Kingdom, death from a road accident for a typical driver is probably about 1 in 10,000 per year.
Much of our work as process safety management professionals entails figuring out whether the risk is tolerable. We ask, how high is the level of risk, and what do we need to do to mitigate it? If the risk is very very low, we ask, do we have to do anything about it at all?
This approach could be different in the United States because there might be a compliance code that says, you must do something about that particular hazard. In the United Kingdom, we say that if the level of risk is not high enough, we can live with that hazard.
Societal risk (or collective risk) considers the total risk at a given site. As shown in Figure 4 below (yellow line), broadly speaking, the steeper the gradient, the more adverse people are to real catastrophic risk happening. There is a great feature in Process Safety Office? SuperChems? software for creating graphical representations of societal risk charts.
Depending on what industry you are working in, the results can be very different. For example, the nuclear industry could have a very different total risk than the electrical industry.
The concept of practicality and what risk management is required is at the core of UK law. The requirement is that the risks be managed so far as is reasonably practical, weighed against the trouble, time, and money needed to control it. There are lots of things that are possible to do to manage risk, those possibilities might be technically feasible, or they might cost a huge amount of money.
The Health and Safety Executive defines reasonably practicable as:
‘Reasonably practicable’ is a narrower term than ‘physically possible’ …a computation must be made by the owner in which the quantum of risk is placed on one scale and the sacrifice involved in the measures necessary for averting the risk (whether in money, time or trouble) is placed in the other, and that, if it be shown that there is a gross disproportion between them – the risk being insignificant in relation to the sacrifice – the defendants discharge the onus on them.
Cost Benefit Analysis
Cost benefit analysis (CBA) is a useful tool to try and answer the conundrum of whether it is reasonably practicable. CBA sets the risk reduction benefit (for example, fatalities and injuries prevented) against the net costs to the operator of introducing the safety measure (for example, business interruption, change in productivity, capital outlay).
The interesting thing about CBA in the United Kingdom is that the value to prevent a fatality (VPF) can vary tremendously. For example, for a local road improvement program the local council might have a VPF of ￡100. What they are saying is, we are only prepared to spend ￡100 to save a life. On the other side, you have industries that are very nervous about the risks, and the willingness to avoid fatalities is a far higher figure. The UK Department for Transport periodically publishes data used by some industries and the VPF for rail is currently set at ￡1.826 million per life.
VPF can be used to determine whether the cost of a specific risk reduction option is grossly disproportionate to the benefit. When looking at a particular level of risk the question becomes, how much are they prepared to spend to mitigate that risk further?
Foreseeability
It is worth noting here that the Health and Safety Executive does prosecute if a risk is considered foreseeable but was not identified during a hazard analysis study. Foreseeability is an interesting concept when considering common risks and the comparable level of exposure caused by a specific risk.
There was a serious case where an employee was manning a gate and during the work day, he was struck by a fast-moving motor vehicle. The level of assessed risk by the safety professional had been set incredibly low. When questioned on the level, his response was that he had never heard of a worker being struck in this manner before. “It was like a one-in-50-year chance”, he said, and he had never come across this situation before.
However, during prosecution, the regulator stated, “This risk was foreseeable because if you are going to have a man posted on the road, odds are sooner or later he’s going to be hit because he is standing in the road.”
The foreseeability argument contradicted everything the safety expert knew about cost-benefit analysis, about tolerability, and about the level of assessed risk. Take this as an important lesson in your risk assessment that foreseeability turns upside down those well-structured arguments about how much money one should spend and how much risk mitigation one should get back.
In Conclusion
There are many approaches to risk management around the world. When it comes to process safety and risk reduction, the situation is not always clear-cut, but it is of critical importance to ensure that all potential hazards are identified and considered.
Pipeline Safety Webinar
In this complimentary 60-minute webinar, John Barker teaches how pipeline operators might use the outputs of risk assessment to better support investment decision-making. Examples of the environmental consequences of pipeline failure, which can be particularly costly for operators to remediate, will be presented. The basis for comparison of environmental risks against other risks, such as safety, will also be discussed in this webinar to help operators understand where best to invest in risk mitigation.?
To register for the webinar, visit the AIChE website > https://bit.ly/3LiUJAJ
Using Risk Assessment to Support Investment Decision-Making
Read this paper by John Barker on the management of onshore transmission oil and gas pipelines and the choices that operators must make for investment decision-making, particularly concerning the environmental consequences of incidents where there is a loss of containment (LOC) event from the pipeline (i.e. a leak or rupture).
To download the white paper, visit our website > https://bit.ly/3eHJ4MQ
Facility Siting and the New EPA RMP Rule Workshop
Join us in Houston, TX, on Tuesday, September 24, 2024, for this complimentary in-person workshop presented by Georges Melhem of ioMosaic Corporation and Devon Downs of Farley & Partners LLP , on the key aspects and the challenges to the new EPA regulatory requirements for facility siting. Seating is limited, register now.
To learn more and register, visit our website > https://bit.ly/3VQD5ud
Latest Career Opportunities
If you’re someone who enjoys learning new things and tackling a variety of challenges daily, we’d love to speak with you. Check out more opportunities with ioMosaic Corporation.
Process Safety Consultant for Relief & Flare Systems
As a Process Safety Consultant for Relief & Flare Systems, you will be providing expertise in various areas of pressure relief and flare systems evaluation and design. You will be responsible for evaluating processes and procedures to ensure compliance with relevant process safety standards and regulations. You will also be responsible for identifying potential hazards and risks and developing practical solutions to reduce them.
To view this opportunity and apply, visit > https://bit.ly/49S2NTQ
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Senior Process Safety Consultant
As a Senior Process Safety Consultant, you will report to a director and will partner with global clients in the development, implementation, and continuous improvement of their process safety and risk mitigation programs. You will be responsible for evaluating processes and procedures to ensure compliance with relevant process safety standards and regulations. You will also be responsible for identifying potential hazards and risks and developing practical solutions to reduce them.
To view this opportunity and apply, visit > https://bit.ly/3VefeEY
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