HFL Consulting (now part of SLR)

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No doubt you will all have been very busy recently making changes on your site to enable compliance with the necessary precautions to work safely under the COVID-19 pandemic.  There are numerous pieces of guidance already produced to guide you further, and you will have been installing route signs, hand sanitiser stations, monitoring personnel temperatures, and providing appropriate PPE etc.  It is very likely that these new practices will be with us for a considerable period of time.

But, as you know, being a COMAH operator brings with it the necessity of developing and implementing robust systems of work, which will be heavily scrutinised by the Competent Authority – the focus being to use proportionate and appropriate risk assessment to determine the risk reduction measures to prevent, control and mitigate your major accident hazards (MAH).  So, as a COMAH operator much more consideration of the impact of the additional measures to prevent COVID-19 transmission must be assessed also from the point of view of the impact on process safety issues and the identified major accident hazards.

This will require that the considerations of additional measures to deal with the pandemic should ideally be assessed as you would normally assess changes on site within your process safety risk management system.

Hopefully you will already have appropriately assessed any organisational changes that have already been adopted on site, for example, different shift patterns; reduced shift numbers; deferral of maintenance, inspection and testing schedules; staff working from home, etc.

Don’t forget that if you have staff returning from furlough their competence level may not be at an appropriate level to prevent, control and mitigate those MAHs, so work will be needed here as well.

All of this, of course should be started by using the management of change or organisational change processes already implemented on site; with a focus on the prevention, control and mitigation of the identified major accident hazards.  So, to achieve these aims it will by necessity prompt for the impact of changed practices and changed resources particularly on the safety critical tasks related to the operational and maintenance practices.

What you will essentially need to do is identify those tasks throughout the process safety lifecycle that require more than one person to undertake, and determine for those tasks how the task itself can be accomplished in an equally safe manner – so, changes in operational and maintenance practices can be undertaken safely from a process safety perspective (and focussed on the hierarchy of control) as well as satisfying the social distancing rules to prevent transmission of the COVID-19 virus.

To do this, you can:

  • Review your hazard identification portfolios, bow-ties, critical task analyses, etc. to identify those critical tasks associated with safety critical equipment. Remember the process safety lifecycle.
  • Review the associated written operational procedures, maintenance procedures, method statements etc primarily looking for tasks that require more than one person.
  • Consider if the specific task can be done equally safely but in a different manner – sequentially rather than in parallel; use of different equipment, etc. Remember the hierarchy of control.  The best people to do this exercise would be the people who undertake the task.
  • Modify the procedures, provide training if necessary, etc.
  • Modify the Permit to Work procedure and its implementation to incorporate the social distancing rules and new working practices.

As with everything in COMAH land, there is always a lot more that needs to be done than first meets the eye. Don’t forget you have a specific duty to be able to demonstrate this when requested to do so by the COMAH Competent Authority (CA).  Your route to this is to ensure you have implemented your Management of Change processes systematically and robustly.

Join us for our free webinar on 28th May 2020 to discuss these issues further.