Personal up close experience of these issues in both the chemical and construction industries has enabled Comah Structure Inspections to develop a unique perspective of the needs of chemical operators who control asset intensive sites and also have to meet significant challenges to address in terms of increasing service demand, increasing stakeholder expectations, deteriorating infrastructures and constrained funding.
There is, however, no escaping the fact that major hazard organisations require competent staff that has the necessary skills, knowledge and experience to undertake critical tasks in such a way as to prevent a major accident or minimise the consequences to people and the environment should one occur.
Most COMAH sites are involved in the production of speciality chemicals. Staff at these sites are highly competent in chemical and / or mechanical engineering. In some instances there might, however, be a lack of client side specialist knowledge and skill relative to the expert inspection competence required for the site buildings and structures (the built infrastructure).
Such lack of expertise in the built infrastructure can result in serious structural deterioration going unnoticed for long periods of time. In addition, a lack of specialist competence can also result in a failure to identify substandard or non-compliant facilities. Either scenario, or worse still, a combination of both will result in a dramatically increased risk of a loss of containment incident or serious accident
Incidents arising from infrastructure failures, whilst rare, usually have catastrophic consequences. The Buncefield Disaster is a prime example of where a lack of specialist infrastructure competence was the root cause of a major environmental incident:
The COMAH Competent Authority Intelligence Review Group (CAIRG) reviewed evidence from loss of containment incidents within the chemicals sector covering several years. The findings, set out in the HSL Annual Operational Intelligence Report 2010, showed human error was, by far, the most frequent cause for “loss-of-containment events”.
The Competent Authority (CA) is currently working to identify and eliminate gaps in competence on major accident hazard sites. As a result, all top tier COMAH sites and a third of tier 2 sites will have their Competence Management System (CMS) subjected to a strategic audit (link to COMAH audit pdf?) by the CA between 2012 and 2015.
A lack of a qualified and competent infrastructure inspection person or organisation will probably be identified as a gap in your CMS and could result in failure during a Competent Authority Part A audit.
This will lead to a more onerous Part B follow up. Worse still, and more importantly, if you are not carrying out competent inspections of your built infrastructure you are increasing your risk exposure to a serious accident or loss of containment incident.
In order to identify and target sites where a detailed competence management inspection would be appropriate, a sample check inspection (known as a Part A Inspection) will be carried out by the CA. The Part A Inspection will give a broad overview of how the Operator is managing competence and focuses on whether key personnel are achieving the desired outcomes when undertaking critical tasks.
The Part A Inspection is based upon sampling how a task critical to the prevention of a major accident is actually undertaken. This check inspection will reveal whether there are any underlying concerns about the effectiveness of the Operator’s CMS.
The Part B Inspection is a more in-depth inspection of the management of competence, and is normally only undertaken when the initial Part A Inspection gives rise to concern about the way in which competence is managed.
As mentioned earlier, specialist infrastructure competence is a critical component of the safety and environmental controls on major hazard sites. This being the case, your business needs to be able to answer “YES” to the following questions:
All hazardous sites should now be reviewing the education, training and experience of the personnel currently responsible for the management of repair and maintenance activities on the site buildings and structures. Any gaps in competence should be noted.
A lack of a qualified and competent person or organisation for infrastructure inspection is likely to be identified as a gap in your CMS and could result in failure during a Competent Authority Part A audit. This will lead to a more onerous Part B follow up. Worse still, and more importantly, if you are not carrying out competent inspections of your built infrastructure you are increasing your risk exposure to a serious accident or loss of containment incident.
If an operator’s existing arrangements do not meet the criteria for competence, consideration should be given to nominating or appointing a Competent Person or Body with overall responsibility for built asset inspection and maintenance.