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Staffing assessment in support of a COMAH report |
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2011 - Chemical manufacture
The client was updating its COMAH report and recognised a need to include an objective assessment of staffing arrangements. Andy was asked to conduct a study using the HSE method described in CRR348/2001. He facilitated a number of workshops in order to complete physical and ladder assessments. His report concluded that most necessary arrangements were in place, but that the details of their application was sometimes lacking. He made recommendations to improve emergency arrangements so that prompt and effective responses would be more likely during an incident, and to review competence management programs. |
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Supporting updates to a COMAH report |
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2011 - Gas
Major modifications were taking place on site to accommodate a new process. This included reuse of some redundant plant and installation of new. As a result, the site's COMAH report needed to be updated. Andy assisted by providing text for the report to cover human factors. Also, he worked with the client and their design contractors to ensure human factors were being adequately considered in the project. He produced a human factors integration plan covering the modifications that was incorporated into the project plan and was submitted as an attachment to the COMAH report to demonstrate the approach being taken. |
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A gap analysis of the approach taken to addressing human factors in a COMAH report |
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2011 - Gas (LPG)
Due to the quantities of Liquefied Petroleum Gases (LPG) stored at the client's sites, and hence potential for major accidents, they were required by Control of Major Accident Hazard (COMAH) regulations to develop a safety report. Whilst they had carried out some human factors assessments the assessor from the Health and Safety Executive (HSE) was not satisfied that they had addressed all the relevant issues in sufficient detail. Andy was asked by the client to carry out a gap analysis of what had been done vs. latest standards and guidance. He found that they had made a very good initial attempt, and had been effective at identifying critical tasks and some of the errors that could occur. However, their decision to base their analyses on existing procedures meant that some of the realities of the job had been overlooked. Also, their approach to identifying potential human errors was not particularly systematic. The result of these weaknesses was that opportunities to improve human factors had been missed and so it was not possible for the client to demonstrate that they were managing the risks effectively. Andy advised where the client's methods and approached required improvement. |
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Developing a human factors integration plan for designing a new onshore and offshore facility |
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2010 - Gas storage
Following his involvement in a similar, but much smaller project Andy was commissioned to act as human factors expert for a large offshore gas storage facility with onshore processing. The main deliverable during early front end engineering was a human factors integration plan that identified the activities that needed to be performed in order to integrate human factors into the project design and operations phases, with specific activities incorporated into the overall Project Plan. Following discussions with all the major stakeholders it was agreed that human factors would be a line responsibility within the Engineering disciplines (similar to other safety aspects) so that effective integration into the design is ensured. Each discipline Lead would be accountable for addressing human factors within their area of responsibility. Given the safety implications, the project’s safety function would be responsible for the overall monitoring of human factors implementation within the project. However, the specialist nature of some elements meant support and assistance would be required from a human factors specialist on a consultative basis. The plan itself was to be used to record significant human factors landmarks and references in its support of the required safety case (offshore) and safety report (onshore COMAH) |
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COMAH safety management system |
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2007 - Food and drink
The client was planning to significantly increase the quantity of highly flammable material being stored on site. This would make it a Top Tier establishment under the COMAH regulations.
Andy's role was to specify requirements for developing the company's safety management system required to demonstrate major hazard risks were as low as reasonably practicable. This involved discussions with the Competent Authority and analysis of the company's activities. Andy developed a specification that identified what systems and procedures the client needed to develop in order to satisfy the requirements of COMAH. This specification was written in a way that could be included in the COMAH safety report as a description of how the company manages its major hazard risks. |
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COMAH risk assessment processes |
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2006 - Steel manufacture
The client had experienced an incident that should have been predicted and prevented as a result of risk assessment carried out for COMAH. Andy was asked to investigate how the risk assessment process had failed. From talking to key personnel and reviewing related documents, Andy was able to develop a root cause 'why tree.' From this he recognised that the incident had been predicted but the mindset of people at the site meant they focused on only part of the problem and hence did not develop a full solution. This was further affected because assessments had been carried out at a generic level, and specific areas with higher risks had not been identified . Also, changes had occurred in the way areas of the site were being used and because the management of change processes had not worked as intended, there had been no prompt to revisit the original risk assessments. Andy was able to make recommendations about how to improve the underlying processes and specific applications of risk assessment and management of change. The objective being to not just prevent the same incident occurring, but to have a wide ranging impact on how risks are managed. |
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Human factors for a new facility |
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2006 - Gas terminal
Andy was seconded to the pre-operations team during the final design and construction phases of a new gas terminal. Andy's role was to facilitate task analysis and risk assessment, and to use the results to specify plant and interface design, procedural and competence requirements. This was a significant contribution to the preparation of the COMAH safety report and development of safe systems of work. Andy has provided ongoing support to the project, and this has demonstrated that human factors best practices can be incorporated into a project with minimal extra time and cost over 'traditional' approaches. |
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Review of how procedures are addressing the needs of COMAH |
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2006 -Oil Refinery/Petrochemical
The client had recognised that in certain circumstance that procedures are a key risk control measure. As part of preparation for COMAH it was necessary to demonstrate that the actual procedures in place were covering all the requirements to minimise the likelihood of major accidents and to ensure mitigation. Due his previous involvement in procedures at the site, Andy was asked to review the current situation.
Working to a tight timescale, Andy directed an internal audit of procedures and COMAH carried out by the client's personnel. He then visited every department to carry out his own 'sample' audit to act as a cross reference. This combined approach meant Andy had information to demonstrate that whilst minimum requirements were being achieved, there was an underlying problem that meant the link between procedures and COMAH was not being made in an effective manner. As a result he was able to recommend a change of emphasis in the way tasks were analysed that would have multiple benefits of focusing procedures onto major hazards and improving the understanding of people who use the procedures. |
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Development of a permit-to-work system |
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2004 - Oil
The site had recently become a COMAH establishment. This created the requirement for a formal permit-to-work system. Being a very small and simple operation, the client did not have the resources to develop, operate or maintain a complex system. Andy was asked to develop a system that was compliant with relevant regulations and guidance, but practical for the operations taking place and staffing levels present on the site. Andy developed a two-part permit-to-work system. The first part was used during the planning stage of a job to analyse the potential risks and specify the necessary controls. The second was used to control the work on the days it was being carried out. The client felt this was a very practical solution. |
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