5 STEPS

To Achieving The Gold Standard

in COMAH Asset Management
CONTENTS

Introduction

COMAH site scores:

getting better, but theres still room for improvement

What the Competent Authority (CA) looks for

The CAs general approach relevant good practice
How the CA prioritises site visits
Reasons for CA intervention
Ratings from Strategic Priorities

The 5 STEPS towards the COMAH Gold Standard

1 Lead from the front

2 Review your asset register

3 Ensure primary containment measures are in place

4 Ensure integrity of mechanical equipment

5 Find the right resources

What next?

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INTRODUCTION

As an Engineering Inspection company that works

with many of the UKs COMAH sites, it became clear
to us that understanding the commitment to Asset
Integrity Management under the Control of Major
Accidents and Hazards (COMAH) Regulations is still
a challenge for Asset Managers and Engineers.

The Competent Authority (CA) has issued a range of useful guidance documents
on how they rank COMAH sites and what they look for. However, our feedback
suggests that a key concern for site managers is the focus that the Health and
Safety Executive (HSE) now places on COMAH sites, including any common
weakness areas.

No COMAH site wants to fall foul of the HSE and face prohibition notices or
potential prosecution. Yet, as the recent and unfortunate Alton Towers incident
has shown, enforcement by the HSE is not the only issue that those responsible
for asset integrity should be concerned with: the legal claims and negative
publicity can never be underestimated. Furthermore, there is a very real threat
of prosecution, with fines and imprisonment penalties, not just limited to
companies, but their directors too.

For the purposes of COMAH compliance, the CA will not necessarily focus on
pushing sites from good to exemplary but, will understandably focus on those
that need to improve significantly. However, sites should always bear in mind
that good practice in industry changes regularly and they should constantly
challenge themselves to improve.

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This eBook will show you that, with the right approach to Asset Integrity
Management, you can not only improve your safety scores, but simultaneously
improve efficiency and reduce plant downtime in the process, increasing profits
at the same time.

Our guide includes:

PP Statistics issued by the HSE on the performance of
COMAH sites
PP How the CA prioritises and enforces COMAH site visits
PP How COMAH sites can improve in the CAs 5 key strategic
focus areas
PP Benchmark results from a survey of Asset Managers and Engineers
on their key concerns, challenges and strategic priorities.

We also include advice from the HSE, risk and compliance experts at leading
law firm Pinsent Masons and a top-tier COMAH Site Director. We hope this
eBook will provide you with guidance to work towards what we consider to be
the gold standard of Asset Integrity Management.

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COMAH SITE SCORES:
getting better but theres still room for improvement

Since the HSE announced that it would be focusing on ageing COMAH sites as a
strategic priority in 2010 the scoring of COMAH sites has markedly improved.

The HSE has released figures showing how sites were scored between 2010/11
to 2015/16:

23% In 2010 23% of COMAH sites were

scored as poor or unacceptable

12% This dropped to 12% in 2015/2016

In the same period, there was a

corresponding 12% improvement in
37% the number of sites achieving good
or exemplary scoring, moving from
26% to 37%.

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Ageing Plant - the story so far...
Distribution of scores, by category, overall for each work year.

Source: Slide from David Glass (Principal Specialist for the HSE) presentation - Manchester,
September 2016

63% The HSEs results show that 63% of

sites are in need of improvement.

12% are performing badly. 12%

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WHAT THE CA LOOKS FOR

The CAs general approach to relevant good practice

This eBook is aimed to help those responsible for Asset Integrity Management to
strive towards achieving a gold standard. The CA is keen to stress that they do
not necessarily expect a gold standard, but relevant good practice.

This aligns with the approach taken in A Guide to the COMAH Regulations 2015
(L111), which defines relevant good practice as:

Relevant good practice should be adopted as a minimum and you should then firstly
consider: What more can I do to reduce the risks? And, secondly, explain: Why have
I not done it? Good practice represents a consensus between regulators, technical
experts, duty holders and other stakeholders on what constitutes proportionate action
to control a given hazard. Among other things it takes account of what is technically
feasible and the balance between the costs and benefits of the measures taken.

The HSE generally expect ACOP 84 to be adopted as a minimum, but emphasise

that sites should challenge themselves further. Sites need to consider that
industry standards change and so what was once considered relevant good
practice may not be so now if sites fail to keep up with emerging technologies,
such as new, or refined non-destructive testing methods and techniques.

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How the CA prioritises site visits
The CA collect and consider information about the hazards relating to your site,
the activity you undertake and your location. By reviewing this information
against the risks your materials pose to people and the environment, the CA is
able to create a ranked list of establishments to inspect during any one year. They
then determine the frequency and length of inspections and define the issues
that will be examined prior to visiting.

There are various measures of consequences defined, rated from A to D for both
safety and the environment. A rated establishments will be visited annually,
whilst others will be visited less frequently if they present a reduced risk.
Examples of these include non-complex sites or sites with no off-site risk.

However, within the same A to D rating parameters, poor performers will receive
more visits from the CA than better managed sites.

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Reasons for CA intervention
David Glass, Mechanical Engineer and Principal Specialist for the HSE, speaking at
our COMAH Seminar on 29th September 2016, advised that the order of priority
for site visits and interventions is as follows:

PP Enforcement history (formal cautions and warnings, COMAH

Improvement/Prohibition Notices (INs and PNs); prosecutions; other
notices)

PP Issues of non-compliance and failure to implement CA actions

PP RIDDOR (and precursor RIDDOR) incidents relating to loss of
containment

PP Ratings from strategic priorities (< 30 = positive impact on

intervention)

PP Ratings from specified inspection topics

PP EPR Rating (Operator Performance & Compliance with Permit) or
Compliance Assessment Scheme (CAS) where appropriate

PP Pre-receipt agreements prior to safety report submission.

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Ratings from Strategic Priorities
Under the strategic priority of Ageing Plant, the HSE has issued guidelines as to
the areas that they will evaluate to inform their inspections and enforcement.

The key areas are:

1. Leadership
2. Asset Register
3. Primary Containment
4. Integrity of Mechanical Equipment (Safety Critical)
5. Resources

As part of this process, your business will be scored between 10 and 60 and
assigned to one of six safety hazard groupings:

10 Exemplary 20 Good

Needs to Improve,
30 partially compliant 40 Poor

50 Very Poor 60 Unacceptable

We now consider how COMAH sites can improve safety in these key areas,
whilst furthering efficiencies and operational goals in the process.

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THE 5 STEPS TOWARDS THE
COMAH GOLD STANDARD

LEAD FROM
THE FRONT

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One of the top strategic priorities of the CA is leadership. In the Ageing Plant
Operational Delivery Guide Version 1 / June 2010, the CA set out what they are
looking for from a sites senior managers:

To what extent are the sites senior managers aware of the performance of the
systems designed to maintain the integrity of safety-critical assets and what is their
commitment to ensuring that such assets remain fit for service at all times?

Are you paying lip service to leadership?

Unfortunately, it is all too common for senior management and directors to
develop integrity management processes, but fail to oversee if they are being
adhered to once implemented. They express shock in the aftermath of an
integrity failure, yet the reality is that the signs were there if they had looked.

There shouldnt be an assumption that the systems you have are working too
many times we see companies and senior management assume their processes and
procedures are working, yet conditions on the ground betray ineffective application.

And too many times these issues are relatively easy to find it is a continuing
disappointment that change is brought about by a one day Competent Authority
inspection, when the problems should be readily visible to management. Simply
touring the site, querying poor condition, asking questions of employees, scrutinising
maintenance records and engaging with the workforce on the plant will reap
tangible benefits. And in the first instance, that costs only a little time.

David Glass, HSE

A red flag: a leading lawyers lesson on

management buy-in from the Alton Towers crash
Most involved in Quality, Health, Safety and Environment (QHSE) management will
be all too aware of the 5m fine levied at Merlin Attractions Operations Limited
following the crash on the Smile rollercoaster at Alton Towers in June 2015.

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At our COMAH event in September 2016, Colin Read, Partner at leading law
firm Pinsent Masons, revealed a less known issue in the case. You can see the
full video here. The judge remarked that it was quite telling that the directors
shares were not linked in any way to safety performance.

Steps to take
PP Get out on to the plant floor and ask operators about performance
or issues

PP Ensure that safety is a key component of your budget - would a judge

or the HSE look favourably on a cost-cutting measure that halves your
maintenance staff?

PP Link staff bonuses to safety targets

PP Dont leave everything to the maintenance or engineering departments
PP If you rely on external consultants, be an intelligent customer
PP Build COMAH into your INDG 417 approach to leadership
PP Ensure processes are subject to formal senior management review.

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THE 5 STEPS TOWARDS THE
COMAH GOLD STANDARD

REVIEW YOUR
ASSET REGISTER

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Many COMAH sites suffer from fragmented records, with P&IDs, Competent
Body and consultant/outsourced inspections kept on separate registers. There
can also be problems with delays between inspections and their subsequent
reports and third party reporting not always providing sufficient information for
sites to identify risks.

If you are striving towards a gold standard, now is the time to review your systems.

Having a clear overview of the safety inspection/testing status across

all of the plant was the third biggest challenge for Asset Managers and
Engineers we surveyed.

Survey undertaken by British Engineering Services at their COMAH event, September 2016

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 Steps to take
The CA provides some helpful instruction regarding what it expects
to see within the Asset Register in Appendix 2 of the Ageing Plant
Delivery Guide.

You should ensure that your Asset Register meets these

key benchmarks:
PP A list of important plant equipment and their locations
PP A list of relevant hazardous fluids within the plant and their
properties (e.g. Material Safety Data Sheets)

PP Information should be easy to access and use, even if records are

fragmented

PP Information is kept up-to-date and mirrored by accurate up-to-date

processes and instrumentation diagrams, P&IDs, and other plant or
process documentation

PP Clear identification of primary containment, safety-critical mechanical

equipment, the failure of which could result in a major accident (e.g.
tanks, vessels, pumps and piping)

PP A multi-layered barrier of safeguards, covering prevention, control

and mitigation

PP Some form of risk ranking system / prioritisation

PP Arrangements in place to identify and highlight equipment subject
to significant ageing.

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THE 5 STEPS TOWARDS THE
COMAH GOLD STANDARD

3
ENSURE
PRIMARY
CONTAINMENT
MEASURES ARE
IN PLACE

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It is important that COMAH sites have a clear strategy in place for managing
plant integrity throughout the plants lifecycle, from the initial design/
construction through to repair and retirement. Primary containment measures
are one of the key areas that sites should focus on at the initial design/
construction stage and the HSEs scoring shows that that this area requires the
most improvement on COMAH sites.

Ageing Plant - 2015/16 data

Source: Slide from David Glass (Principal Specialist for the HSE) presentation - Manchester,
September 2016

The HSE has set out the control measures it expects sites to take in relation
to the accidents and hazards in their guide: HID Regulatory Model Safety
Management in Major Hazard Industries.

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There are two key steps to control measures

1
Multi-layered barriers of protection
Sites should ensure that there are multi-layered barriers of protection that
address technical, managerial and procedural arrangements. These will include
measures to both prevent and minimise harm in the event of a loss of integrity,
which will link in sequence to each major accident scenario.

However, mitigation measures should always be seen as a last resort and

every step should be taken to ensure that they are prevented with primary
containment.

Sites should be able to show that there has been a logical and rational flow
of analysis leading from hazard identification through to effective risk control,
expressed as a set of appropriate barriers (or risk control systems).

2
Proper profiling of risk
There should be a system in place to prioritise the importance of measures that
are in place and how vulnerable the systems are to deterioration and failure.

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 Steps to take

PP Hazard Identification
- Identify intrinsic hazards (toxic, flammable, reactive, corrosive,
explosive, infectious)
- Identify physical properties (temperature, pressure, fluid state)
- Determine hazardous property conditions
- Determine processes or activities that will result in hazardous
condition.

PP Risk assessment
- Identify challenges to integrity e.g. high/low pressure, high/low
temperature, overfilling, corrosion, human error, etc.
- Identify potential consequences of hazardous condition
- Determine probability/likelihood of hazardous event occurring.

PP Risk profile
- Determine the nature and level of the hazards identified from
the risk assessments
- Evaluate the likelihood of adverse effects occurring
- Evaluate the level of disruption and costs associated with each
type of risk
- Analyse the effectiveness of controls in place to manage
those risks.

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How implementing a risk based inspection
approach saved one client 10 million euros
In supporting a major chemical company, we provided a Risked Based
Inspection (RBI) framework in accordance with the Health & Safety Guidance
document Best practice for risk based inspection as a part of plant integrity
management, Contract Research Report 363/2001. This was applied to a site
with over 350 items.

We carried out a review of the entire site prior to a major shut down, utilising a
team of both mechanical and process engineers from our customer and British
Engineering Services staff. The output from the review resulted in a more
targeted inspection regime, as well as extending the outage frequency from 3
years to 5 years. The inspection regime targeted the damage mechanisms in a
more systematic way, the resulting frequency enabled our customer to realise a
10m Euro saving on their shutdown costs over a 15 year period.

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THE 5 STEPS TOWARDS THE
COMAH GOLD STANDARD

4
ENSURE
INTEGRITY OF
MECHANICAL
EQUIPMENT

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After the initial design and construction stage, the integrity of mechanical
equipment must be maintained throughout the rest of its lifecycle. As can be
seen from the previous section, the HSEs scoring shows that this is the second
area most in need of improvement on COMAH sites.

The Safety Assessment Federation (SAFed) has published a very useful

guide, The mechanical integrity of plant containing hazardous substances -
A Guide to Periodic Examination and Testing (IMG1) that covers the issues
that COMAH sites need to consider throughout their lifecycles. The Guide
includes a flowchart that shows how key stages inform the Written Scheme of
Examination (WSE).

Steps to take

PP Utilise both internal and external expertise and experience

in formulating RBI process, the WSE and examination policy
- External resources can bring additional expertise and experience
from similar sites
- Internal resources often have the most in-depth knowledge of
existing processes and the plant

PP Ensure that staff (internal and external) have suitable

experience and qualifications
- Technical experience and qualifications are vital
- Do inspection bodies have the UKAS accreditation to
BS EN ISO/IEC 17020 standard?
- Check non-destructive testing competence under the BS EN 1SO 9712
standard, or accreditation to BS EN ISO/IEC 17025 standard.

PP Ensure internal and external resources have clearly

identified roles.

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 PP Understand key user requirements when formulating
the WSE e.g.
- Asset Manager - ease of managing a large number of plants
- Maintenance Manager - grouping related inspections

PP Consider your reporting requirements e.g. instantaneous

reporting to ensure plant is returned to service in a timely
manner, not reporting by exception

PP Continuously test your systems, review and improve.

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THE 5 STEPS TOWARDS THE
COMAH GOLD STANDARD

5
FIND
THE RIGHT
RESOURCES

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Resources - Identify your strengths and weaknesses
Resource pressures is the single biggest challenge faced by Asset
Manager and Engineers.

Survey undertaken by British Engineering Services, September 2016

One of the most important starting points on your journey to achieving COMAH
gold standard for Asset Integrity Management is identifying your teams
existing strengths. You need to determine, if any, aspects you wish to keep in-
house or outsource to a specialist third party.

In our 2016 COMAH seminar, Andy Vernon, Site Director for top-tier COMAH
site BASF, emphasised the importance of evaluating your internal strengths and
weaknesses, to identify where your own staff, or suppliers, add the most value.
He also highlighted the need to ensure that independence between operations
and inspections/testing is maintained in your evaluations.

Andy discussed the benefits of a collaborative approach using British

Engineering Services. They believed that managing their own Written Schemes
of Examinations, using an RBI approach, while outsourcing inspection and
some technical expertise, was the best solution for them. They wanted to
keep ultimate responsibility in-house and utilise their own expertise, while
developing a collaborative relationship with British Engineering Services.
This included access to expert Engineer Surveyors who could draw upon their
experience at other sites and industries to inform their approach.

BASFs final approach may not be right for everyone, but all COMAH sites
can benefit from ensuring that they undertake a thorough analysis of their
strengths and weaknesses, prior to developing a best-in-class Asset Integrity
Management system.

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 Steps to take

PP What could be done internally?

- What are we good at?
- What should we be good at?
- Where do we add value?

PP What should be outsourced?

- What cant we do?
- What are suppliers good at?
- Where do suppliers add value?

PP Further considerations within the process

- Maintaining independence between inspection and operations.

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WHAT NEXT

60% of Asset Managers and

Engineers surveyed stated that their
60% biggest concern with COMAH safety
and compliance was selecting the
correct approach to Asset Integrity
Management.
British Engineering Services Survey, September 2016

As you have seen, there are a number of steps you can start to take in working
towards the gold standard of Asset Integrity Management on your COMAH
site. However, if you are like the majority of Asset Managers and Engineers
we recently surveyed, selecting the right approach may be one of the biggest
challenges you face.

If so, why not follow in BASFs footsteps and utilise your own internal expertise
whilst drawing on the breadth of accredited expert technical expertise and
insight that British Engineering Services can offer? As our case study earlier
shows, we have helped sites achieve improved safety along with multi-million
euro cost savings.

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 Steps to take

PP Identify potential risks through fitness for purpose inspection

PP Select the correct inspection regime for their sites
PP Formulate and approve Written Schemes of Examination
PP Undertake the latest non-destructive testing techniques
PP Devise and carry out Risk Based Inspection regimes
PP Have a single, transparent overview of the safety and
inspection status of their plant with our instant reporting,
which includes:
- An overview of when examinations are falling due
- 4 filterable defect codes
- An area for customers to add and manage their own comments,
such as remedial action taken to noted defects
- Phrase search function.

We offer a nationwide service and rapid turnarounds carried out by experienced

Engineer Surveyors with industry-leading accreditation.

Our focus puts you, the customer, first. We not only improve COMAH
compliance but use our technical expertise to guide you towards the best
approach to maximise plant efficiencies and operations in the process.

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 WE HELPED ONE COMAH
SITE IMPROVE SAFETY
AND ACHIEVE A
10 MILLION EURO SAVING.
WHAT COULD YOU ACHIEVE?

SPEAK TO A COMAH EXPERT

British Engineering Services, 5 New York Street, Manchester M1 4JB

T 0345 678 2985 E info@briteng.co.uk W britishengineeringservices.co.uk
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