Seminar One Introduction to Safety Case

1. Seminar OneIntroduction to Safety Case Date 11 April 2006

2. Seminar One is a basic introduction to Safety Case and the MHF Regulations 2000. Its timing has been triggered by the commencement of Round 2 Licencing activity It has been developed for the following purposes: To provide a brief and simple overview of the main parts of a safety case To be suitable for new MHF Operators Examples of incidents Context of MHF Regulations Outlines the reason for a safety case Introduction

3. Port Kembla Ethanol Tank Fire, NSW, Australia, 28th January 2004 Why is a Safety Case Needed?

4. Why is a Safety Case Needed? Coode Island, Australia – storage terminal fire, August 1991, no injury.

5. Why is a Safety Case Needed? Longford, Australia – explosion and fire, September 1998, 2 dead, led to the development of Victorian MHF legislation

6. Why is a Safety Case Needed? Texas City, USA – fire and explosion, March 2005, 15 dead, over 170 injured

7. Why is a Safety Case Needed? • Entschede, Holland – fireworks factory explosion, May 2000, 22 dead, 947 injured

8. Tosco Avon Refinery 23rd February,1999. Crude Unit, Tosco Corporation’s Avon oil refinery, Martinez, California. Workers were attempting to replace piping attached to an online 150-foot-tall distillation column Piping released naphtha which ignited. The flames engulfed fire workers who were located at different heights on the column Four men were killed and one seriously injured. Why is a Safety Case Needed?

9. Tosco Avon Ref. – Contributing Causes 1. Tosco Avon refinery management did not conduct an MOC review of operational changes that led to excessive corrosion rates in the naphtha piping. Above design rates Feed contained high water levels Prolonged operation on LV bypass valve caused ineffective line isolation 2. The crude unit corrosion control program was inadequate. Why is a Safety Case Needed?

10. Why is a Safety Case Needed? Bhopal, India – Dec 1984 Toxic release – methyl isocyanate 3000 to 8000 deaths, $0.3b to $3b

11. Why is a Safety Case Needed? Buncefield Incident – 11th December 2005 (Currently under investigation by UK HSE) 40 injured, no fatalities

12. There is a need for specific control of major hazards due to: Changing scale and complexity of specific facilities Housing encroachment into MHF buffer zones Changing community perceptions Loss of Corporate Knowledge associated with ageing plant and mobile workforce Range of major accidents that have occurred Prescriptive approach has proven inappropriate Why is a Safety Case Needed?

13. This has led to Regulations where: the Operator is expected to know what technical and human activities occur The Operator decides on the appropriate means of major hazard control for the facility, and prepares a SC explaining this The Regulator assesses and audits performance adequacy against the SC Why do we need a Safety Case?

14. Safety Case Submissions Rd 2 2007 Safety Case Submissions Rd 1 2002 Introduction of MHF Regulations Jul 00 Longford Royal Commission Report Jul 99 Longford Explosion Sep 98 Australian National Standard for Control of MHFs 96 Coode Island Fire 91 Background - The MHF Regulations Flixborough 74, Seveso 76, Bhopal 84, Piper Alpha 88

15. Focus on major hazards (catastrophic events involving Sched 1 materials i.e. high consequence and low frequency) Proactive risk based approach Places the responsibility on the facility Operator Facility Operator actively has to demonstrate safe operation Overview - Key Principles of MHF Regs

16. Overview - Key Principles of MHF Regs Consultation with different parties required at all critical stages Addresses both on-site and off-site safety Regulator ‘ review’ of this, tied to a licence

17. Overview - Focus of MHF Regulations Increasing risk Minor Risks Very high risks should already be eliminated after risk assessment within SC process Relative Frequency of Occurrence OHS risks already regulated Focus of MHF Regulations is high consequence (catastrophic) but low frequency incidents Consequence - Severity

18. Victorian Acts/Regulations Main Parts OH&S Act Manual Handling Certification Regulations Confined Spaces Regulations Issue Resolution Asbestos Regulations Noise Regulations Haz Substances Regulations Incident Notification Plant Regulations Major Hazard Facility Regulations DG Act Explosive Regulations Dangerous Goods (S&H) Regulations HCDG Regulations

19. Objective of the Regulations To provide for safe operation of major hazard facilities in order to reduce the likelihood of a major incident (MI) occurring and to reduce the consequences to health and safety and damage to property Overview – MHF Regulations

20. Specific parts of the MHF Regulations for this seminar series are: Safety management system (R301) Hazard identification (R302) Safety assessment (R303) Control measures (R304) Emergency planning (R305) Review of risk controls (R306, R404) Consultation - HSRs, employees, community (R501, R505, OHS Act) Overview – MHF Regulations

21. The SC must address all hazardous events that could result in: An uncontrolled incident that involves schedule 1 materials; and Poses a serious and immediate risk to health and safety What is the Safety Case?

22. A Safety Case is a detailed document that outlines: hazard identification and control mechanisms in place to prevent and mitigate all MIs for the facility the types of safety studies undertaken the results obtained from such studies the management arrangements in place to ensure the continued safety of the facility, its people and the surrounding community What is the Safety Case?

23. Document the state of safety arrangements for the facility Demonstrate to the satisfaction of WorkSafe, through content and supporting material, that: the operator knows what technical and human activities occur how hazards are managed how safety will be managed in the event of an emergency What must the Safety Case do?

24. What must the Safety Case do? (cont’d) Identify methods to be used for monitoring and reviewing all activities for continuous improvement of the safety arrangements of the facility over its lifetime.

25. Safety Case Content?

26. Summary of the SMS prepared under R301 Documentation of the Safety Assessment -outcome R302, R303 Schedule 4 Information - Facility Description - Safety Information Main Components of a Safety Case

27. Summary of SMS prepared under R301 The Safety Case must contain a summary of the SMS elements including: Safety policy and objectives Organisation and structure Operational controls Means to achieve Part 3 (Safety Duties) and 5 (Consulting, Informing) compliance Management of change Principles and standards Performance monitoring Audit Ref Sched 2 Main Components of a Safety Case

28. Documentation of the Safety Assessment – R302, R303 Identification of all the major incidents which could occur. Identification of all the hazards that could cause or contribute to causing a major incident. Risk Assessments. Methods and criteria for identifying and assessing the above. Main Components of a Safety Case

29. Process or activity description Schedule 1 and Dangerous Goods materials and their characteristics Facility layout drawings Future facility changes Plan of facility and surrounding area. Main Components of a Safety Case Schedule 4 Information - Facility Description

30. Schedule 4 Information -Safety Information Control measures that prevent or limit consequences of MI’s Performance monitoring Safety Management System cross reference Incorporation of safety and reliability into design and construction Incident history – last 5 years Main Components of a Safety Case

31. Break More on Safety Assessment follows…..

32. Safety Assessment Hazard identification – for determining MIs Risk reduction studies – for determining controls Emergency scenarios– for training and controls Risk evaluation - for determining risk acceptability Recommendations and review – for continuous improvement Main Components of Safety Assessment

33. Safety Assessment Hazard Identification • Using Hazop/What If, RA and specialist reviews, the MI’s and their causes (of MIs) are determined Process Hazard Identification (HAZOP/What If) Risk Assessment (RA) Process Unit Technical Review Input (Specialist Review) Major Incident Event Grouping

34. Risk Assessment Analysis and Assessment of the hazards and potential MIs on site using LOPA Risk matrix FTA/ETA QRA Provides a more detailed analysis of causes/frequency/outcomes/controls for each identified MI Can enable risk offsite to be assessed Enables comparison of risk reduction options Safety Assessment

35. COMMUNITY EMERGENCY RESPONSE PLANT EMERGENCY RESPONSE PHYSICAL PROTECTION & MITIGATION SYSTEMS AUTOMATIC SIS CRITICAL ALARMS AND OPERATING PROCEDURES BPCS PROCESS DESIGN Layer of Protection Analysis Safety Assessment • Analysing the safety measures and controls that are between an uncontrolled release and the worst potential consequence - risk reduction study

36. The information for assessment can be presented as a bow-tie diagram. Mitigative Controls Preventative Controls MI Outcomes Causes Controls Controls Hazards Consequences Safety Assessment

37. Safety Assessment Preventative Controls Mitigative Controls MI Outcomes Causes MI Controls Consequences Hazards Controls

38. Promote preparation for response to emergencies Ensure necessary equipment available and maintained Ensure personnel are trained and prepared to respond Identify communication methods required Identify community resources required Consultation with emergency services and local council Emergency Plans

39. Analysis of the explosion, heat flux for the pool fires or jet fires or toxic consequence levels to determine fire fighting access and to identify affected impact areas Determination of the fire water and foam requirements for extinguishing the fire and/or protecting affected equipment Available as a resource for training in specific scenarios Emergency Incident Scenario Plans

40. Occupied Buildings Risk Assessment Analysis of the impact of MIs on occupied buildings Mainly risks (due to flame impingement, explosions, toxic gas) from other buildings/operations What Else is in a Safety Case Report?

41. Plastics Factory 2004

42. Continuous Improvement Opportunities to reduce risk are identified Recommendations are assessed and prioritised An action plan is developed and implemented SFARP What Else is in a Safety Case Report?

43. Operators must review (and revise) hazard identifications, risk assessments and control measures to ensure risks remain reduced to SFARP: at the direction of the Authority prior to modification after a major incident when a control measure is found to be deficient Upon licence renewal or at least every 5 years New information becomes available regarding possible MI hazards previously unknown SC Review & Revise

44. The SC must demonstrate adequacy of all Safety Duties required by the MHF regulations Safety Duties are ongoing requirements An Operator of a major hazard facility who fails to comply with the MHF regulations could jeopardise the continuation of their licence. Summary

45. Safety Case Seminar Series 2006

46. Occupational Health and Safety (Major Hazard Facilities) Regulations 2000, Victoria Major Hazard Facilities Regulations – Guidance Notes, WorkSafe WorkSafe Victoria www.workcover.vic.gov.au NSW Major Industry Hazard Advisory Papers 1 to 9 Centre for Chemical Process Safety UK Health and Safety Executive, www.hse.gov/comah Sources of Additional Information

47. Questions ??????? Seminar 1