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Speech to Engineering Equipment and Materials Users' Association (EEMUA). Warwick Conference Centre, 1 March 2011

Judith Hackitt CBE, HSE Chair

A Question of Ownership

I am very pleased to have this opportunity to speak at your conference this morning. I am sure that some of you in the audience will already know that the topics of process safety and asset integrity are ones which are very dear to my heart. In doing my homework before speaking to you today, I have been looking at the work the EEMUA does with its member companies. You have an impressive list of member companies all of whom are engaged in the use of engineering equipment and materials. The very purpose of EEMUA lies at the heart of what process safety and asset integrity is all about – helping your member companies who operate: process plants, power stations, offshore platforms, storage terminals and a whole host of other industrial facilities around the world to improve the safety, environmental and operating performance of industrial facilities in the most cost effective way. By establishing the means to share expertise and experience you can and do produce guidance standards, and specifications and define levels of competence required within the workforce.

But I also suspect that you already know that this highly laudable but largely technical approach to improving operating performance is not enough. Even with the best standards and specifications, things can still go very badly wrong - for example, if the standards are not adhered to throughout the lifetime of the assets, if the assets are pressed into a different service to that for which they were intended, if the computer tells the operator that the assets are working properly when in reality they are not.

None of these or the myriad of other things which can go wrong and which I could have mentioned are random hypothetical scenarios. They are real examples of what has gone wrong in the past, on more than one occasion, and which have resulted in major incidents and in some cases loss of life and major environmental damage. Most were the result of lessons which should have been learned, but weren't. And which, when they happened, people said we must ensure they never happen again - but they have.

There is no doubt at all that when events do happen, there is a shock wave that runs through the whole of industry - not just the company where the incident happens or the particular sector that runs similar processes. That is clearly the case at the present time in the wake of a series of recent major incidents - Buncefield, Texas City and the Macondo platform blow out in the Gulf of Mexico.

But what we must all learn from these incidents is not just the specifics of what went wrong in each one so that we can address those issues, but also to appreciate what else lies behind them - often the 'ordinary' and very mundane failures that trigger a chain reaction that leads to a catastrophe.

Much of the work that is done on process safety and asset integrity considers the need for multiple barriers to be in place and quite rightly so. But there is a danger in thinking that if a system is protected with multiple barriers it will take a highly improbable combination of freak circumstances to lead to a coincidence of multiple failures and a catastrophic incident - but it doesn't work like that.

I want to read to you a short section from the joint COMAH competent authorities' recent report into the underlying causes of the explosion at Buncefield in December 2005:

"The tank had 2 forms of level control; a gauge that enabled employees to monitor the filling operation; and an independent high-level switch which was meant to close down operations automatically if the tank was overfilled. The first gauge stuck and the IHLS was inoperable - there was therefore no means to alert the control room staff that the tank was filling to dangerous levels........The gauge had stuck intermittently after the tank had been serviced in August 2005...The IHLS needed a padlock to retain its check lever in a working position. However the switch supplier did not communicate this critical point to the installer and maintenance contractor or the site operator. Because of this lack of understanding [and communication] the padlock was not fitted.......... Keeping the process operating was the primary focus and process safety did not get the attention, resources or priority that it required."

There is nothing 'freaky' or improbable about any of that - it happens. I would not mind wagering that every one of you in this room know of level gauges that don't work properly all of the time. You might not know if you have equipment installed in your facilities that needs to be set up or operated in a certain way because that information has not been provided to you - so how good is your assurance that you do have all of the right information? And as for keeping the process going - that's what the job's about isn't it? Sadly that's what too many people still think - which is why I now want to move on to where this culture to keep going even when all is not as it should be seems to originate from.

In spite of the very clear lessons of the past and the multiplicity of corrective actions and commitments that have been made to prevent a repeat, we in HSE have identified some key factors which seem to be major contributors to a "decay" process which takes place in that learning process with the passage of time:

The true role of those who are charged with managing safety also needs to be properly understood - especially by senior managers and leaders. The "safety manager" is there to ensure that everyone else is playing their part in managing safety as an integral part of every person's job. It is part and parcel of the purchasing and procurement manager's safety and process integrity role to ensure that equipment is bought to specification and that all of the necessary detailed information on installation and maintenance is obtained at the time of purchase. It is essential that design engineers properly document all of the design considerations and limitations so that they can be passed on and preserved for future reference.

And finally in this analysis of the challenges we face we must remember that all of the industries here today - your membership - have not only been through changes of ownership but also a significantly increased level of contractorisation and outsourcing - both of the mechanical work on the plants you own and operate but also of chunks of the process itself.

So, if these are the challenges, how do we address them?

First and foremost, organisations like EEMUA need to carry on doing all of the good work you are currently doing to set standards, to continuously remind your members of the importance of asset integrity and to provide forums for sharing learning and experience.

Companies like Scottish Power, who you will hear from later this morning, can demonstrate to others how to do process safety and asset integrity and can speak with real credibility and conviction about the business benefits it has delivered for them.

We need to raise awareness of the importance of asset integrity outside of companies like yours with your hardware suppliers, your service providers, your contractors and in some cases your customers.

But above all we need to raise the profile of asset integrity with senior leaders and managers. Three years ago, HSE ran a conference entitled: "Leading from the Top". Our target audience was not engineers and technical specialists but people at the top of organisations engaged in the full spectrum of major hazards industries - senior managers and business directors from chemicals, oil, gas, power, rail and nuclear industries. Our message to them then was not unlike the theme of your conference - we wanted to "encourage" them to stop focusing upon why they were different from each other and to open their eyes to what they could learn from one another. Since that conference back in 2008, all of our activities with major hazards industries have emphasised the importance of that leadership and ownership from the top. We state in our strategy for Health and Safety in Great Britain in the 21st Century that leadership is not just important but fundamental because without it none of the other elements of an effective health and safety system will function properly or be sustained.

True leaders are willing to listen and to act on bad news, not to see it as a problem. They ensure that full and comprehensive systems are in place and that everyone in the organisation understands their responsibilities. They value the skills and expertise of others. They may not, indeed cannot be, experts in everything, but they do know the right questions to ask.

Whilst the consequences may be different in some respects, there are some parallels here with the financial sectors and indeed perhaps some of your businesses attitude to financial risk as well as asset integrity. Perhaps there is something we need to teach all future managers and leaders about the need to believe that things can go wrong. You cannot assume continued, uninterrupted growth in any sector of the economy and ignoring the risks or seeking to "offset" or transfer them is a dangerous approach to management and leadership. The ability to think about what can go wrong is not the preserve of the pessimist, or the regulator, or the poor engineer - it's a crucial management skill.

We must (re)generate a better understanding of risk and a greater commitment to building inherent safety into plant design, operation and maintenance. Many of the plants and equipment which are in operation are still working beyond what had been envisaged when they were built and will continue to run long into the future. We need more examples of leadership like the one being demonstrated by Scottish Power. And we need to consider new and innovative ways of making process safety an integral part of everyone's role.

Because this is to some extent about re-learning lessons that should already have been learned it is not easy – because no-one likes to have to admit that there has been a failure of leadership and management in the past – but in many cases there has.

We must also ensure that new technologies and new equipment which will find its way into your company's portfolio in the future start out with a proper understanding of the hazards and risks in those processes. This is not a barrier to innovation and development, it is critical to successful innovation.

The work of EEMUA and its members is greatly valued by HSE. We recognise the important role you are taking in being part of the solution and contributing to the delivery of the strategy. But the challenge lies in getting everyone to truly own their part if the whole system is to work effectively. Nowhere is that ownership more important than amongst the leaders of the organisations who are in your membership.

Updated 2011-04-03