The Safety Case Journey for Singapore - WSH Institute · Hazard identification process ... Process Hazard Analysis (PHA) Major Accident Prevention Policy ... •Quantitative Risk

A Great Workforce A Great Workplace

© 2015 Government of Singapore

The Safety Case Journey for Singapore

Jaime Lim Sr Assistant Director (Major Hazard Installations)

OSH Specialist Department Ministry of Manpower

WSHI ICES MOM 27 Nov 2015

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Background

How we got here

Our implementation plans ahead

2

Presentation Outline


Major Hazard Installations (MHIs)

• Fixed installations, including petroleum refining and manufacturing facilities, chemical processing plants and facilities where large quantities of toxic and flammable substances are stored or used

• The likelihood of a major accident for such installations is low due to the stringent workplace safety and health management system in place

• The complex operating environment and high inventory of hazardous chemicals means that any incident can potentially result in catastrophic consequences

Background

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MHI Study Mission – May 2013

Key Recommendations:

1. Better coordination among regulating agencies

2. Better integration of safety protocols/requirements at MHI level e.g. safety case

3. Better management of domino effect risks

4. Enhanced capability building initiatives for regulators /industry

5. Structured process to share lessons learnt from MHI incidents

Visited Germany, United Kingdom and Netherlands to study how these countries manage MHIs

CAs are better able to identify gaps and monitor potential domino effects within MHI clusters

Competent Authorities (CAs) cooperate and coordinate efforts to manage risks posed by MHIs

Safety Case consolidates and demonstrates to authorities the integration of their various SHE* protocols

* Safety, Health and Environment 4


Inter-Agency Taskforce for Major Hazard Installations (IAT-MHI)

Chaired by MOM with Director-Level representatives from

MEWR, MHA, MOM, MTI, NEA, SCDF, EDB & JTC

Review of Regulatory Framework for MHIs

In Mar 2014, MOM set up an Inter-Agency Taskforce to review and enhance existing regulatory framework for MHIs to be in line with international best practices

• Introduce Safety Case regime for MHIs

• Establish the National MHI Regulatory Office (NMRO)

In Dec 2014, IAT-MHI completed review & recommended:

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Regulatory Framework for MHIs

Shifting away from Prescriptive One-Size-Fits-All Regulatory Approach

• Greater flexibility for MHIs to tailor risk mitigating measures to best suit needs • MHIs to take on greater responsibilities, proactively identifying & managing

SHE risks

Safety Case regime where MHIs integrate all SHE protocols onsite Demonstrate to regulators that MHI risks have been reduced to as low as

reasonably practicable (ALARP)

Effect Safety Case Regime

• Introduce MHI Regulations under the Workplace Safety and Health Act • Share pertinent information among MHIs when needed, to mitigate potential

domino effect in the event of a major incident, allowing neighbours to take the risks into account in their risk management and emergency response planning

National MHI Regulatory Office (NMRO) • Setting up NMRO, to better coordinate Safety Case assessments, inspections

and investigations • Led by MOM, the NMRO will also consist of officers from SCDF and NEA and

will serve as a single regulatory front for MHIs on SHE matters 6


A Case which an MHI makes to the regulators, setting out how risks from major accidents hazards can be reduced to ALARP*, ensuring safe operations in a sustainable manner

* ALARP: As Low As Reasonably Practicable

What is a Safety Case?

A Safety Case includes details of:

Hazard identification process

Identification of hazards with the potential to cause major accidents

Evaluation of major accident risks

System/procedures put in place to control them

Measures to limit major accident consequences

MHIs to convince the regulators that the strategy for managing safety is satisfactory, through the adoption of ALARP principle

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• Safety Case is an MHI regulatory tool used in European Union United Kingdom, Germany, Netherlands and Norway

• In the wake of the 1998 Longford gas plant incident, Australia has also implemented Safety Case to enhance oversight of MHIs

• Safety Case is also implemented in ASEAN countries, Malaysia and Brunei

• US Chemical Safety Board (CSB) broached the issue of adopting the Safety Case Regime following the 2012 Chevron Refinery fire

Countries with Safety Case Regime

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Safety Case implemented in UK since 1984

• Seveso Directive, with subsequent revisions

Control of Major Accident Hazards (COMAH) Regulations require MHIs to

• Take all necessary measures to prevent major accidents involving dangerous substances

• Limit the consequences to people and the environment of any major accidents which do occur

Regulated by Competent Authorities (HSE jointly with Environment Agencies)

COMAH in the United Kingdom

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“The need for the COMAH regulations is clearly

accepted by industry – being critical both to

managing the hazards and for maintaining public

confidence.”

“Since the introduction of the OHS (Major Hazard Facility) Regulations in July 2000, WorkSafe has observed: • No major incidents since the 1998

Longford Explosion • In-depth regulatory inspections and

verifications are continuing to achieve assurance of safety at MHFs.”

Department for Business Innovation & Skills, UK Manager, Health and Safety Operations,

WorkSafe Victoria, Australia

Benefits of a Safety Case Regime

• Improved understanding of hazards and risks • Enhanced knowledge of technical & managerial controls

required to manage major accident hazards and risks • Better oversight by regulators

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Safety Case Regime

Intention:

To cover industrial installations which pose a major potential hazard, to:

• Workforce

• Neighbouring communities

• The environment

due to the quantities and nature of substances they handle

Safety Case regime to be effected through the enactment of the Workplace Safety and Health (Major Hazard Installations) Regulations,

under the WSH Act

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Type of Trade Activities

Chemical Types and Threshold Quantities

Definition of MHIs

Premises engaging in processing, manufacturing

and/or bulk storage of dangerous substances

specified in the Tables of Dangerous Substances

— Listed in the WSH (MHI) Regulations

The maximum quantities of dangerous substances

equal to or exceed threshold quantities as

indicated in the Tables of Dangerous Substances; or

The aggregation of the ratios of dangerous

substances equals to or exceeds one

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• A single consolidated Safety Case

• ALARP demonstration • Integrate &

demonstrate robustness of all SHE protocols to regulators

• Sharing of domino information with neighbouring plants

• Reviewed once every 5 years

Single front, jointly regulated by MOM, NEA & SCDF

Proposed Safety Case Regime

Quantitative Risk

Assessment

(QRA)

Safety & Health

Management System

(SHMS) including PSM

Emergency Response

Plan

(ERP)

Process Hazard Analysis

(PHA)

Major Accident Prevention Policy (MAPP) establish guiding principles and action plans

to prevent major accidents

SAFETY CASE

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Committee of Supply Debate

On 9 Mar 2015, MOM’s Senior Parliamentary Secretary, Mr Hawazi Daipi, announced in Parliament the introduction of WSH (MHI) Regulations and the establishment of NMRO

Announcement at Budget 2015

Managing Major Hazard Installations (MHI)

MOM will adopt a Safety Case regime where MHI Operators will need to

integrate all their Safety, Health and Environment protocols onsite, and

demonstrate to regulators that they have managed their risks to as low as

reasonably practicable. We will introduce a set of MHI Regulations under the

Workplace Safety and Health Act to effect the Safety Case regime. A

National MHI Regulatory Office will be set up in 2016 to better coordinate

Safety Case assessments, inspections and investigations.

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• Single front, jointly regulated by MOM (Lead), NEA & SCDF, to be set up in mid-2016

• Oversee Safety, Health and Environment (SHE) matters in MHIs

• Receive and assess Safety Cases from MHIs

• Conduct onsite verification of Safety Cases

• Investigate MHI incidents

• Engage and outreach to MHIs

• Plan and coordinate multi-agency work, including QRA submissions

Major Hazards Department (MHD)*

Roles of MHD

* NMRO officially recognised as a government department 15


Proposed Implementation Timeline

Mid-2015 onwards

• Safety Case capability building for regulators and MHI industry

• Develop Safety Case technical guidance, through Joint Gov-Industry Work Group (JWG)

• SC technical guidance to be published before enactment of WSH (MHI) Regulations

3Q 2017 to 3Q 2020 Phased-in Safety Case

submissions from MHIs

2015 2016 2017

Enact WSH (MHI) Regulations, to require Safety Case submissions by MHIs

3Q 2016

Safety Case regime for MHIs takes effect

3Q 2017

2018

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Role of the SC JWG

• Support enhancement of Process Safety Regulatory Framework in Singapore by developing implementation proposals for Safety Case Regime

• Coordinate with SRMC/SCIC QRA Work Group to ensure revised QRA Guidelines are fit for adoption into Safety Case Regime

Safety Case Joint Gov-Industry Work Group (SC JWG)

Government Representatives

MOM Mdm Jaime Lim (Co-Lead)

SrAD (MHI)

SCDF LTC Ng Geok Meng Assistant Dir (HazMat)

Maj Lo Wai Mun Assistant Dir (Licensing)

NEA Mr Chen Fu Yi Sr Engineer (Central Building Plan)

Industry Representatives

SCIC

Mr Amit Bhatnagar (Co-Lead)

Singapore Refining Company

Mr Evert Klein ExxonMobil

Ms Gloria Wang Shell

Ms Agmer Lee Secretariat

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SC JWG Deliverables

• Develop Technical Guidance for Safety Case regulatory regime Consistent with Seveso Directives

• Develop strategy to build industry capability in implementing Safety Case

• Identify potential opportunities to

harmonise Safety Case regime against existing regulatory requirements

• WSH (MHI) Regulations • Guide to MHI

Regulations

Safety Case Technical Guidance Document • Technical Guidance • Safety Case Assessment

Guide

By Regulatory Agencies

By JWG

Safety Case Joint Gov-Industry Work Group (SC JWG)

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• Industry consultations indicate that MHIs understand the benefits of the Safety Case Regime and are receptive to it

• Agencies will continue to work closely with the industry to jointly develop guidelines, including technical guidance, for the Safety Case regime

• Future streamlining of existing SHE regulatory requirements for MHIs, with the introduction of Safety Case Regime

– With greater clarity of Safety Case requirements/implications, refinements can be made to further streamline existing regulatory requirements

Industry Feedback Thus Far…

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• Safety Case allows MHIs flexibility to showcase ALARP demonstration and better management of domino effects

• Authorities will work together with MHIs to co-develop technical guidance on Safety Case

– SC JWG

• Single, coordinated regulatory front for Safety Case matters among MOM, NEA and SCDF

– MHD

• With the introduction of a Safety Case Regime, regulators are prepared to streamline existing regulatory requirements

In Summary…

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A Great Workforce A Great Workplace


Thank You!

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# Description Key Components

1 Management system and organisation to prevent major accidents (a) MAPP includes MHI’s overall aims and principles of action

with respect to control of major accidents (b) SMS includes general management system and addresses:

• Identify and evaluate major hazards • Operational control and Management of Change (MOC) • Planning for emergencies • Monitoring performance

• Major Accident Prevention Policy (MAPP)

• Safety Management System (SMS)

2 Description of the MHI and its environment (a) Site description and location (b) Description of main activities and products, sources of

major accident risks and conditions under which major accidents could happen and preventive measures

(c) Description of processes and operating methods (d) Description of dangerous substances

• Description of MHI

• Hazard Identification

Key Components of a Safety Case

Existing requirements are in red



3 Risk assessment and prevention methods (a) Detailed description of major accident scenarios

• Probability or conditions which they can occur • A summary of trigger events in each scenario • The causes being internal or external to the MHI

(b) Consequence assessment including extent and severity of identified major accidents

(c) Description of safety equipment and their technical parameters

• Quantitative Risk Assessment (QRA)

• Process Hazard Analysis (PHA)

• Prevention methods, risk controls, mitigation systems

4 Protection measures to limit consequences of an accident (a) Description of equipment installed to limit

consequences of major accidents (b) Organisation of alert and intervention (c) Description of deployable resources (internal or

external) (d) Summary of elements needed to draw up emergency

plans for Internal ERP and External ERP

Emergency Response Plan (ERP)




5 ALARP demonstration, improvement plans

Including monitoring of process safety performance indicators (PSPIs)

ALARP Demonstration

6 Information sharing

Share appropriate information about the installation’s nature and extent of the overall hazard of major accidents with other installations in the cluster, to enable them to take into account of the aforesaid into their MAPP documents and on-site emergency plans

Info Sharing


Documents

The Safety Case Journey for Singapore - WSH Institute · Hazard identification process ... Process Hazard Analysis (PHA) Major Accident Prevention Policy ... •Quantitative Risk