A MAPP need only be a short document, but must be linked to your major accidents.
A Major Accident Prevention Policy (MAPP) is a statement of general intent that should set out your policy on the prevention of major accidents. The MAPP doesn't need to contain a detailed description of your Safety Management System (SMS). However, it should give sufficient detail to show you have systems in place to cover all the required aspects.
The key to the MAPP is the link to your potential major accidents, to both people and the environment.
Your MAPP must contain your policy setting out your aims and principles of action concerning the prevention of major accidents, and a description of the SMS for achieving these aims. It does not need to be a long document and can refer to other documentation where relevant.
There is plenty of guidance available about the required information, but the trick is linking it to your major accidents and including a proportionate amount of detail. C3's experienced consultants can help you get the balance right.
A SMS must be proportionate to the hazards, activities and complexity of the site.
A Safety Management System (SMS) is a key part of COMAH compliance and is covered by Regulation 7 of COMAH 2015, which states that:
Most sites already have systems in place for most of the required areas (e.g. roles & responsibilities, training, procedures, etc.), but find that some improvements need to be made to demonstrate the linkage to the site's risk profile. In C3's experience more substantial improvements are often required around the topics of: hazard identification and risk assessment; design and modifications of installations; and emergency procedures.
C3 can assist you with all aspects of your site's safety management system, using our collective knowledge of systems that have been successfully implemented elsewhere. We can also provide good practice audits that generate practical and pragmatic advice for how your systems can be improved.
Do you know which of your systems are key to the prevention and control of major accidents?
Over recent years we have seen a shift in emphasis of the UK regulator away from broad high-level audits to more focused and challenging intervention visits aimed at specific areas of good practice. These include an increased focus on Permit to Work, Competency and Management of Change (MoC) to name but a few.
As a consequence C3 has been requested by our clients to assist them in reviewing their core Risk Control Systems as well has helping put in place a sustainable and meaningful suite of Process Safety KPIs.
C3 stands alone amongst our competitors being able to offer a wide range of operational support including the review, audit and where necessary overhaul of your Key Risk Control Systems, because our team includes individuals who have held senior site based roles on Upper Tier COMAH installations and therefore at our core C3 understands the challenges and responsibility operating complex manufacturing sites bring.
Measuring performance - early warning before catastrophic failure.
A guidance document (HSG254 'Developing Process Safety Indicators') has been produced by the HSE and the Chemical Industries Association (CIA), and includes the following paragraph in its abstract, which concisely summarises the aims:
'Too many organisations rely heavily on failure data to monitor performance, so improvements or changes are only determined after something has gone wrong. Discovering weaknesses in control systems by having a major incident is too late and too costly. Early warning of dangerous deterioration within critical systems provides an opportunity to avoid major incidents. Knowing that process risks are effectively controlled has a clear link with business efficiency, as several indicators can be used to show plant availability and optimised operating conditions.'
Developing Process Safety KPIs must always start with the identification of major accidents and the key risk control systems that are in place to prevent and control them. For each key risk control system a leading and lagging indicator is then developed to provide 'dual assurance' to confirm that the risk control system is operating as intended or providing a warning that problems are starting to develop.
C3 consultants have many years of working with key risk control systems, both within consultancy but also as senior managers on Upper Tier COMAH installations, providing a unique perspective on the relevant issues to help you develop a suite of indicators that is relevant and effective.
Ensuring competence involves so much more than just having a training plan.
The majority of Intervention Visits relating to competence follow the CA's Operational Delivery Guide 'Inspection of Competence Management Systems at COMAH Establishments'.
The HSE carries out the inspection in two parts:
Although the Competence Delivery Guide is freely available on the HSE's website, it is written to cover a wide range of installations; therefore it can be difficult to know how to apply it to a specific site and it's risk profile.
C3 consultants can provide you with a variety of support, ranging from a Human Factors Health Check of your systems against the HSE’s expectations up to the implementation of a Competence Management System.