Industry regulators for hazardous materials processing facilities require an incident management system to investigate, record and report process safety-related incidents.
The Bureau of Safety Environmental and Enforcement (BSEE) contains the following key element of their Safety Environmental Management System (SEMS) regulation:
Investigation of Incidents: procedures for investigating incidents, corrective action and follow-up.
Organizations generally have basic incident recording and reporting systems for occupational safety incidents, but these are seldom adequate for process safety-related incidents. Without auditing, workflow and system integration capabilities organizations risk significant financial and legal penalties from regulators when serious process incidents occur and their incident management systems are found to be lacking.
What is an Incident Management System?
The Incident Management System (IM system) is a key system in operations and should record all incidents resulting from plant operating activities. IM systems typically capture information from the Shift Handover and Permit-to-Work systems, where incidents are generally first encountered and documented.
Depending on the type and severity of incident, records must be retained for a number of years. Actionable items are processed through the Management of Change system (MOC) with evidence that the associated risks have been mitigated for review during potential internal and external audits.
Characteristically the IM system involves complex workflows, authorizations and sign-off, audit trails, issues and action tracking, and reporting. Along with these, there are 5 critical elements an IM system must have in order to be successful:
- Integration with shift handover and permit to work system: During plant operations, the shift handover log is the source of operational incidents, and the permit to work systems is the source for incidents occurring during maintenance, and on-going site activities.
- KPIs to monitor types and frequencies of specific high severity incidents: Data should be available that clearly delineated various types of incident base on severity and risk to ensure that critical events are emphasised and monitored. Trending these key KPI is also important to ensure that they are moving in the desired direction, and if not alerts should be provided for required action.
- Accessible information on past incidents: It is generally accepted, and studies have confirmed that corporate memory is about 3 months, after which incidents and their relevant learnings are forgotten. In order to avoid repeating previous incidents, this information needs to be captured and be available to all at interest for reference purposes.
- Workflows to monitor corrective actions on critical items: Workflows are required to make sure actions are tracked to completion, particularly critical items that may be associated with and MOC should be tracked to completion and sign-off with an audit trial of actions taken by responsible parties.
- Broader integration of IM system, and in particular with MOC and SJA: Incidents investigations generally result in corrective actions that require a ‘change’ and integration with the MOC system is required to ensure the relevant parties participate in the reviews and that the agreed actions are completed. In addition, integration with the SJA will act as a means of informing the permit issuing process of any requirements resulting from previous incidents so that these are not repeated.
Is your organization’s IM System adequate?
If your incident investigation and reporting system provides only the minimum documentation and reporting as follows:
“Process & procedures in place to record and report incidents and near misses. Investigation report details are recorded and manual tracked to ensure recommendation actions are implemented”
Then your system is not adequate to manage process safety incidents and protect your company from liability and risk. You should seriously consider transitioning to a fully integrated and optimized system that records and monitors the broad scope of relevant system data:
- Incidents and near misses are reported and tracked electronically.
- Workflows are in place with sign-off as necessary to track investigations and to ensure actions/recommendations are implement through the MOC process.
- Relevant KPIs are established to monitor performance and corrective action is initiated if performance is considered unsatisfactory.
- Investigators are trained in established analysis and investigation methods. A systems, and holistic approach to cause and effect analysis is implemented.
- Process is in place to make available local site, facilities and industry-wide safety alerts to all departments and such alerts are disseminated to all relevant personnel