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Published: 26th September 2022

Celebrate the PAST – Prepare for your FUTURE

High Hazard industry leaders and COMAH Regulators share future key messages for Process Safety Management competence and compliance preparedness requirements. In Summer 2022, UK and ...

High Hazard industry leaders and COMAH Regulators share future key messages for Process Safety Management competence and compliance preparedness requirements.

In Summer 2022, UK and global high hazard industries celebrated a significant milestone – 20,000 staff trained in Process Safety Management (PSM)

This reference article is intended to inform industry leaders – to help them with their future planning considerations. It includes a summary of contributor’s key messages taken from a ‘talking heads’ film, which accompanied the 20,000 PSM Champions celebrations.

Responsible process safety training success was achieved by over 300 UK and global high hazard companies, celebrating the fact that since 2010, 20,000 delegates have now adopted the Process Safety Management (PSM) industry framework training standards.

The standards, listed in this HSE COMAH guidance document are benchmarked to COMAH competence and compliance requirements – to help improve all business’ operational integrity, safety and reduce the risk of a Major Accident. The PSM training standards have been developed for industry by the UK Process Safety Management Competence Programme (PSM CP) Board (including representatives from the Health and Safety Executive) and are delivered exclusively by Cogent Skills.

Contents

In this article you will find key messages from:

  • Matt Lea. HSE. Principal Inspector.
  • Stephen Elliott. Chemical Industries Association Chief Executive.
  • Max Walker. HSE. Head of Onshore Chemicals Strategy
  • Richard Roff. Process Safety Management and Competence Programme Board. Chair
  • Mike Nicholas. Environment Agency. Senior Advisor: COMAH

Board Level Process Safety Representation Needed – and written into every Director’s job description

Matt Lea. HSE Principal Inspector Chemical, Explosives and Microbiological Hazards Division.

HSE’s analysis of 2019-2022 major hazard leadership interventions has highlighted the links between poor performance on site and a lack of competency in the management of major hazards at senior leadership level.

Boards should have at least one person who is accountable for process safety performance and who understands how the decisions made at board level can impact upon safety, both now and into the future.

  • Major Hazard Leadership needs to be clearly defined and written into every Directors job description.
  • Process Safety and Competence Performance representation is needed at Board Level
  • A cause for HSE concern during COMAH site inspections – some Major Hazard senior leaders just weren’t visible
  • HSE wants reassurance that senior leaders know what’s going on at their sites and understand is there are any external factors influencing their performance?
  • The COMAH Competent Authority is building on-going intelligence and other COMAH sites will be added to the list of possible Major Hazard Leadership interventions

Process Safety Management is not just for Process Safety Professionals. All Business Leaders should Embrace the Process Safety Management Training Programme – To ensure the Safety of People, Assets and the Environment

Stephen Elliott. Chemical Industries Association. Chief Executive.

There are 900 COMAH sites in UK ONLY 1/3rd of COMAH sites have adopted the PSM Training Standards – lots more to do!

Informed Process Safety discussions and decisions are required by senior management teamsto understand ongoing performance and measurement.

PSM is not just for Process Safety Professionals! It’s for those with Legal, Financial, HR, Operational, Technical and Commercial responsibilities

A major incident can affect your Financial performance, business reputation, credibility within workforce and local communities AND ‘License to Operate’

Leaders who’ve not yet engaged with the PSM Training Programme? WHY NOT?

It’s up to leaders to EMBRACE PSM and reassure yourself that you are doing everything you can to ensure the SAFETY of your people, assets and the environment

Are Your Competence and Process Safety Management Systems Ready for Change?

Max Walker. HSE. Head of Onshore Chemicals Strategy & Divisional Support – Chemicals, Explosives & Microbiological Hazards Division.

Discussing Net Zero Carbon 2050 changes and new opportunities for COMAH and High Hazard site’s future markets, new energy sources and supply chain.

  • Are your existing systems fit for purpose? Net Zero carbon emissions changes can cause risks to worker safety, nearby community and the environment.
  • Ensure standards of compliance are maintained. Especially if you are planning to re-purpose, mothball, decommission or introduce new assets?
  • Adopting to unfamiliar new technologies, such as carbon capture or hydrogen use as an energy source? Careful thought is needed to understand risks and potential impact on your existing safety arrangements.
  • New net zero solutions investors with little experience in managing a major hazard process – COMAH may apply! From your design and development phases through to operations. How will you acquire compliance skills to run a plant safely?
  • Adapting to Net Zero change within your COMAH or high hazard business? Review workforce competence management systems to make sure you keep pace with change.

It’s Essential to Prioritise Process Safety Education

Richard Roff. Process Safety Management and Competence Programme Board. Chair.

  • Need to maintain operational safety and reduce environmental risk? The principles of Process Safety Management at operational, management and leadership levels, apply to you!
  • Not yet engaged in process safety management training? You’re missing out on something your peers or competitors already have in hand.
  • Leaders – does your site have the potential for a catastrophic operations incident? It’s ESSENTIAL that you prioritise the adoption of process safety education.
  • The PSM programme’s training standards have been developed specifically by industry – for industry, for you and your teams, to help keep your operations safe

Act Now – Business as Usual is Not an Option

Mike Nicholas – Senior Advisor: COMAH. Environment Agency

The Environment Agency is changing the way they regulate – with more focus on business resilience and management systems

Rapid environmental change can affect process safety operations. Process Safety Management needs to be enhanced to embed ways of adapting to the impacts of climate change – does your organisation have the systems, skills and competencies required to manage climate relevant risks and opportunities?

  • We’re all experiencing Rapid Environmental Change. Businesses should consider this within their Process Safety Operations
  • Extreme weather and other climate change impacts can pose THREATS to businesses, for example Lightning, storms and wind, hotter and colder temperatures, with associated fire and freezing impacts, and flooding
  • We need to act now. Climate impact may already be creating increased and uncontrolled risks for your business.
  • The Environment Agency’s climate ambition is to create a net zero nation resilient to climate change.
  • We’re changing the way we regulate – to put more focus on business resilience and management systems
  • Business as usual is not an option! We’re now encouraging senior leaders to set out their ambitions, to manage the risks and opportunities we all face.
  • We need a rapid step change in our preparedness and resilience.
  • It’s the role of senior leaders to motivate, inspire and be accountable for this change.
  • What are the risks, to and from your business, from a rapidly changing environment?  You can begin by asking how climate change impacts affect your business, for example:
  • Does your organisation have the systems, skills and competencies required to manage climate relevant risks and opportunities?
  • To ensure a safe and resilient Net Zero future. Now, more than ever, Process Safety Management needs to be enhanced to embed ways of adapting to the impacts of climate change. 
  • We’re all in this together. We want to help to prepare businesses and their supply chains for current and future impacts, driving adaptation and resilience.  

Useful Links

HSE COMAH Competent Authorities Publication.

To help inspectors to determine whether operators have done enough to ensure that they have sufficient competency in process safety at all levels within an organisation, from the most senior leaders to frontline personnel.

Major Hazard Leadership Intervention Tool

Environment Agency Publication

To help prepare for climate impact

Living better with a changing climate

Cogent Skills Process Safety Management Training.

Developed by the Process Safety Management Competence Programme Board, we are the exclusive training delivery partner, who delivers the following Process Safety Management (PSM) training standards framework to industry.

Future Ready

Cogent Skills is sector based, working with companies from across the Science Industries embracing Life Sciences, Industrial Sciences and Nuclear.
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