PSM Element 1

Site: RRC Training Printed by: Mircea Caprar

Course: NEBOSH HSE Certificate in Process Safety Management Date: Saturday, 8 January 2022, 11:47 AM
Book: PSM Element 1
 Table of contents

Foreword
PSM Element 1 contents
1.1 Process safety management meaning
1.2 Process safety leadership
1.3 Organisational learning
1.4 Management of change
1.5 Worker engagement
1.6 Competence
References
Practice questions
Practice question answers
 Foreword

    

The NEBOSH HSE Certificate in Process Safety Management is the perfect qualification for those who need to understand the principles of process safety
management as part of their job. By studying for this qualification you will be able to contribute to the effective management of process safety and be able to
profile the major risks present in a typical process installation.

The qualification is particularly relevant to the following people working within a process environment:

• Team leaders, supervisors and managers

• Process operators

• Newly qualified health and safety advisors

The qualification is not designed for chemical and process safety engineers experienced in the specification, design and maintenance of the integrity of process
plant.

This course book has been structured to match the NEBOSH syllabus. It has been written by process safety experts, who take you step-by-step through the
content of the qualification. The information is divided into distinct sections, each of which starts by listing the learning outcomes for that particular section. It isn’t
full of jargon or confusing terms and offers useful examples, mock exam questions and helpful tips throughout to aid your learning.

Using this book as part of your course preparation and study could improve your chance of success. How you use this book is entirely up to you however, we
would definitely recommend that you use it as a revision aid as part of your formal course leading to the qualification. You may feel you want to read it from cover
to cover, or you may simply want to read certain chapters where you would like to concentrate your studies. You will also find it useful as a source of reference
when you are back in your workplace.

The NEBOSH HSE Certificate in Process Safety Management is intended to be suitable for students working anywhere in the world. The content is based on
recognised international best practice. Knowledge of specific legislation, either in the UK or in any other country, is not a requirement of the qualification.

Further information, including the Guide for the qualification can be found on the NEBOSH website at www.nebosh.org.uk.

The NEBOSH HSE Certificate in Process Safety Management also complements other NEBOSH qualifications such as the NEBOSH National or International
General Certificate in Occupational Health and Safety.

We hope you find this book useful and thank you for taking the time to learn more about process safety management.

A guide to the symbols used in this course book

PSM Element 1 contents


This element will explore what process safety is and will look at the importance of leadership in the process industries. It will also introduce organisational
learning, management of change, and how worker engagement can be managed.

Contents
1.1 Process safety management meaning

1.2 Process safety leadership

1.3 Organisational learning

1.4 Management of change

1.5 Worker engagement

1.6 Competence

References

Practice questions

Practice question answers

 1.1 Process safety management meaning

1. 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 quite common, simple and therefore reasonably foreseeable;
their control measures are often well established and straightforward to implement. These include machine guarding, fire precautions, equipment checks,
managing slips and trips and the use of personal protective equipment (PPE). We probably think about low personal accident rates or number of days without an
accident as a measure of success.

By comparison, process safety (safety in high-hazard process industries) is rather more complicated. So-called 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 spectacularly wrong,
resulting in major fires and toxic releases, for example. 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 (like 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 good deal
of specialist technical engineering and management skill to get right. Leadership is 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.

2. A definition of process safety

You will find various definitions of process safety but the one that we will use here is: “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 products.” (Energy Institute, adapted from the Center for Chemical Process Safety of the American
Institute of Chemical Engineers1).

As you can see, it has all the elements of what we have discussed earlier.
 1.2 Process 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.

 
1. Hazard and
risk awareness
of

leadership
teams
Leaders need to be competent
and actively engaged. Indeed,
the earlier referenced PSLG
report states that “at least one
board member should be fully
conversant in process safety management in order to advise the board of the status of process
safety risk management within the organisation and of the process safety implications of board
decisions”.

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 an already elderly plant or cutting critical staff), they will make poor decisions that may make a major
accident inevitable (just a matter of time). 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 to do (or not do) things 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.


Further, they of course 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 Industries3 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.”

2. 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. Of course,
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 which, 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 short, they need to be role models.

3. 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 subordinates. So,
other managers and workers will also have process safety critical roles and responsibilities as
part of their duties. Obviously, 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 and following the permit-to-
work process and locking off equipment before work commences.

4. The reasons for holding to account all

individuals with PSM responsibility
It is clear that if new plant is installed without due consideration to safety, then the potential for injuries is high, eg 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 or even
sacking. 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 rather than paying lip service to it, and
ensure that true root causes are identified after incidents. This theme is returned to under
‘Organisational Learning’ below.

In the previously referenced Corporate Governance for Process Safety - Guidance for Senior
Leaders in High Hazard Industries 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 personnel, and do not dismiss expert opinions. They provide a
process or system 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;
 are capable of openly communicating critical aspects of process safety with all internal and
external audiences.

5. The provision of adequate resources

Process safety needs to be adequately resourced; ensuring adequate resources are in place is
the responsibility of the leadership of the organisation. Again, returning to the PSLG leadership
principles, we find the following: “Appropriate resources should be made available to ensure a
high standard of process safety management throughout the organisation and staff with process
safety responsibilities should have or develop an appropriate level of competence.” 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;
physical - such as equipment, buildings, offices, rest facilities, etc.

Under-resourcing process safety is a risky business. While it may be unreasonable to expect an unlimited budget or unlimited pool of personnel 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 - in
September 2001, an explosion in the AZF fertiliser factory in Toulouse, France resulted in 29 deaths, 30 serious injuries and 2,500 other casualties. Total
compensation paid by the insurance group exceeded 1.5 billion Euros. As well as the financial implications of such failures, there are huge moral expectations
placed on employers, which was clear after the Deepwater Horizon explosion in 2012 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.

6. Reasons for establishing process safety objectives and targets

There is an old adage 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 staff 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. We will discuss these indicators in the context of a process safety management system in Element 2.

There are sound 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 good old-fashioned
luck. 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 (often quarterly) and, on an annual basis,
the performance against these targets should be published in order to celebrate success and highlight areas of opportunity. 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.
7. Commitment
to continuous
improvement
Leaders should not only actively
and effectively monitor the safety
performance; they should also seek to continually improve, eg by benchmarking against other organisations.

Ultimately, process safety, like the personal safety we explored at the start of this element, is a never-ending story. Organisations develop, plants change 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 or the incident-free plant and acknowledge that it is achievable with
the right level of commitment.
 1.3 Organisational 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.

1. The significance of learning lessons from incidences of actual or

potential consequence
Major incidents cannot easily be ignored - they create an awful lot 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’ - but if the plant simply
breathes a collective sigh of relief 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 (rather than to you), there is a tendency to be complacent and think it could never happen to you
(simply based on the idea that it has not so far and therefore you must be doing it all right). But, you might just have been lucky. If you fail to investigate and
learn lessons (of how to do things differently), the danger is that the very same issue will repeat and next week, next month or next year, you will not be so lucky.

2. 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.
It may not be necessary to carry out a thorough investigation into all incidents; indeed, some have little potential for serious harm (eg minor cuts and bruises may
receive a low level of investigation), but ignoring the true potential of an incident can be a costly mistake. Unless you fully understand your 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.

We have already discussed the importance of learning from incidents. Investigations obviously
help you do that. 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.

Reasons for investigating accidents and incidents

These reasons are to:

identify root causes and underlying causes of the incident;

 prevent the incident happening again (which 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 staff and the public that there is a desire to improve and learn lessons, this will in turn improve morale in the organisation;
determine if any disciplinary actions are needed. Though this can have an impact on morale it is sometimes necessary in serious cases.

It stands to reason that the benefits of accident investigation therefore flow from the reasons for investigation:

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;
legal compliance will be achieved;
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;
by considering patterns and trends, hot spots or repeat issues can be addressed.

3. Documented management processes to

retain corporate knowledge
Earlier, we referred to the concept of ‘corporate amnesia’. This 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 (career move or retirement, for example), 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 disseminate 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 (we look at management of change later in this element).

4. 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.


5. 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 you decide 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.

6. 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 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 (PFD);
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 (P&IDs);
process control systems, including software integrity;
relief system designs;
fire detection and protection plans.

External information is available through the manufacturers’ data, national legislation, any applicable European Union Directives (see:
https://europa.eu/european-union/documents-publications_en), the UK Health and Safety Executive (see: www.hse.gov.uk), the US Occupational Safety and
Health Administration (OSHA), trade associations and professional bodies such as the Institution of Chemical Engineers; International, European and British
Standards; the International Labour Organisation (ILO) and other documents, all of which are often freely available on the Internet.

  

 1.4 Management of change

1. Management of change control measures

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 report10 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...”8

In the text Chemical Process Safety: Learning from case histories9 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.

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 unwittingly 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 (eg 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 or HAZOPS.

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

(eg engineering, health and safety, production department, research and development, operational staff, maintenance workers, etc);
tracked and managed as different stakeholders review and approve or make comments;
given final approval by a suitably responsible 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:

the MOC file should clearly document all of the changes proposed and be retained as a formal record;
any process documents, eg process and instrumentation diagrams, operations manuals, etc should be updated with relevant changes;
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 staff and
maintenance workers.
Training
All staff 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.
 1.5 Worker engagement

Sometimes, 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, to reap the benefits and avoid the limitations. Consultation will necessarily be on a wide variety of subjects including process hazards, process
controls, development of policies and process safety performance.

1. Benefits and limitations

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;

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;
some poorly structured consultation processes (eg poorly managed committees) may be disruptive rather than consultative, discussing trivia or non-safety
matters rather than addressing core process safety issues.

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;
lessons learnt from incidents and near misses.
In addition, by engaging with workers, the employer can gain commitment and buy in when developing and implementing new policies.

2. Types of consultees and their role/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. 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, which 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 at 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 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.

3. 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 staff. In addition, workers’ representatives can be invaluable during accident investigations
and workplace inspections.

4. Engagement with workers should be a priority

As engagement is so important, it should be given high priority. 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 ‘town hall’ 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 arising;
the effectiveness of communication 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.
 1.6 Competence

In this next section, we will explore the subject of competence. We have discussed the need for this many times already in different contexts. It is a core
requirement for leaders (understanding the process and implications of decisions) when learning lessons, properly assessing and properly managing change.

1. The meaning of competence

There are legal requirements for employers to employ ‘competent staff’ - 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 his/her training.

2. 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 and competence ensures that workers have the relevant skills, knowledge and experience to carry out tasks that are required by their role. 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;
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.
3. Competency management systems
Not all workers need skills in all areas. While many requirements will be common to all workers,
eg 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 staff
may not, and some require specialist skills such as fire-fighting or first-aid training. Obviously,
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 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 rolled up 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.

Example of a training matrix extract:

The European Process Safety Centre11 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 minimum-facility 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 (design and build, 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/role needed to be carried out. People are measured against these requirements and competence gaps identified.
5. Maintaining competence, training and development. The above gaps are filled with relevant training and other interventions. Refresher training will help
maintain this.
6. Competence assessment and re-assessment. Training is all very well, 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, eg 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 (competence requirements change
over the life of a site, for example).

4. Training and development programmes

applicable to process safety risk
Some process safety risks are widely applicable across the sector and, indeed, 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 personnel and newly qualified engineers, giving fundamentals of PSM;
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), and these may also include practical exercises.
 References

1. Energy Institute, Process Safety

2. HSE: Safety and environmental standards for fuel storage sites - Process Safety Leadership Group - Final Report
3. Corporate Governance for Process Safety: Guidance for Senior Leaders in High Hazard Industries
4. HSE (COMAH)
5. HSE Safety Bulletins
6. Chemical Safety Board
7. International Association of Drilling Contractors
8. The Flixborough disaster, Report of the court of inquiry 
9. Sanders, R. Chemical Process Safety, Learning from Case Histories
10. COMAH Competent Authority, Inspection of Competence Management Systems at COMAH Establishments, Operational Delivery Guide, produced by the
HSE, EA, SEPA.
11. EPSC, Making the Case for Process Safety Competence 
 Practice questions

Q1. Process safety mainly deals with:

a. high frequency, high severity risks.

b. low frequency, high severity risks.
c. low frequency, low severity risks.
d. high frequency, low severity risks.

Q2. Within a management of change procedure, final approval for removal of a safety critical device should be given by a:

a. senior manager.
b. lead operator.
c. chemical engineer.
d. process technician.

Q3. Benchmarking is used to identify good practice across similar:

a. committees.
b. organisations.
c. techniques.
d. procedures.

Q4. What is the most important benefit of involving workers when carrying out risk assessments?

a. To reduce resistance and conflict when risk assessments are introduced.

b. To make sure there is a balanced representation of workers and managers.
c. To enable employer and employees to comply fully with legal requirements.
d. To gather detailed practical knowledge about workplace hazards and risks.

Q5. Which of the following is the most direct evidence of worker competence?

a. Consistently performing a work-related task correctly to the required standard.

b. Signing a document to confirm that a procedure was read and understood.
c. Completing an attendance form following a process safety toolbox talk.
d. Carrying out a work-related task without harming themselves or others.
 Practice question answers

Element 1 answers: 

Q1 - b

Q2 - a

Q3 - b

Q4 - d

Q5 - a