[ID] => 10271
[post_author] => 34
[post_date] => 2018-10-24 09:02:26
[post_date_gmt] => 2018-10-24 08:02:26
[post_content] => The UK Tank Storage Association (TSA) held its 18th annual conference and exhibition this past 27 September, once more at the Ricoh Arena in Coventry, home to Coventry City FC and Wasps RUFC. The heaving exhibition room hosted 62 companies keen to display their wares to the assembled throng of storage terminal professionals, a throng that grows larger every year.
The conference, under the theme of ‘Building Better Performance and Leadership’, came at a critical time for the UK tank storage industry, with Paul Denmead, TSA president, saying: “There are many challenges ahead, including the impact of Brexit and withdrawal from the Customs Union, and the government’s ambitious plans for decarbonisation, which would see a significant reduction in the need for hydrocarbon transport fuels from 2040 onwards.”
Indeed, that 2040 timescale may yet prove conservative: since the TSA conference there have been calls to bring forward the phase-out of gasoline- and diesel-powered vehicle sales to 2035 or even sooner.
The conference was ably chaired by Paul Thomas, chair of the Process Safety Forum (PSF), a group formed nearly ten years ago at the behest of the UK Health & Safety Executive (HSE) to bring together the expertise of five trade associations – including TSA - with understanding of the risk management of highly hazardous processes. PSF now has 14 trade associations involved in its work.
“I expect there will be a lot of ‘preaching to the converted’ today,” Thomas began. “We all know and believe that excellence in process safety leads to excellence in commercial performance.” He urged delegates to share that knowledge and passion and to leverage the role that TSA plays alongside other organisations to help share the message to a wider audience.
The keynote presentation was given by John Leavens, director at IHS Markit, who described the current and future trade imbalances in refined petroleum products and their impact on the demand for storage capacity. At the heart of his presentation was the impending arrival of sulphur limits on marine fuels, imposed by the International Maritime Organisation (IMO) in order to reduce sulphur oxide emissions from shipping activities and due to enter into force on 1 January 2020.
At present, marine fuels used outside special Emission Control Areas (ECAs) have a maximum allowable sulphur content of 4.5 per cent. As from 2020, this limit will be reduced to 0.5 per cent, which will place severe constraints on refiners, who have been used to seeing the marine fuels market as a useful sink for high-sulphur material and will be left with a surplus of high-sulphur fuel oil (HSFO). Not all refineries are equipped with desulphurisation systems and not all have the ability to crack HSFO into lighter products, so there may be some movement of fuel oil to refineries with upgrading capacity.
Meanwhile, many refineries are expected to increase crude runs to produce enough gasoil and marine diesel oil (MDO) to supply those ship operators that choose to burn lighter, low-sulphur grades instead of HSFO. Leavens confidently expects a spike in prices for middle distillates (and lighter products) around the 2020 deadline, perhaps lasting two years; this will increase the price differential between HSFO and gasoil/MDO, making the installation of scrubbers to allow the continued use of HSFO by ships an attractive option. That should mitigate the price differential over time.
Meanwhile, Leavens also expects refiners and tank storage terminals to see more business in terms of blending products for marine fuels, possibly including some products – vacuum gasoil, for instance – that have not traditionally been used in bunker fuel.
Leavens also addressed the potential impact of the move towards electric vehicles (EV) but said that improvements in fuel economy in internal combustion engines, both gasoline- and diesel-powered, is having a bigger impact on overall energy demand. He expects overall demand for refined products in Europe to change little in the period out to 2040.
With the ongoing digitisation of the supply chain comes a greater vulnerability to cyber-attacks and, while some companies seem to be doing their best to ignore the risks, this is something that tank terminal operators need to take seriously. Sarabjit Purewal, principal specialist inspector at HSE, reminded delegates that those subject to the Control of Major Accident Hazards (COMAH) Regulation, the UK’s implementation of the EU Seveso III Directive, have a responsibility to address cyber-security in the same way they do physical security.
Purewal explained lucidly how the move towards linked and open IT systems, especially in the past five years, has opened up new vulnerabilities. In particular, the proliferation of new control and monitoring systems, prompted in part by the falling cost of sensors, has increased connectivity throughout the supply chain. This raises the risk not only that there are more points of vulnerability in the chain, but also that any attack on one weakness can more easily propagate throughout the network.
Purewal highlighted how easy it is these days to become a hacker – tools and instructions are easily available online – and that companies need to guard not just against a malicious, targeted attack but also against random malware released into the internet by ingenious hackers.
While cyber-security shares a lot of concepts with physical security, operators cannot think in terms of layers of security, a common approach to improving physical security. This is because a malicious attack will use these layers of protection to open up vulnerabilities.
The EU’s new Directive on the Security of Networks and Information Systems (NIS Directive), which took effect in May 2018, places requirements on certain strategic facilities to address cyber-security issues; some tank terminals fall under the scope of the Directive.
Purewal pointed delegates to some useful resources when drawing up risk assessments for cyber-security. The second edition of IEC 61511 requires cyber-security protection but does not say a lot about it; IEC 62443 has more information but is an ongoing project. HSE is using IEC 62443 as the basis for its own guidance, including guidance for its own inspectors, published in March 2017. One problem they have had to address is how to measure ‘as low as reasonably practicable’ (ALARP).
A second edition of HSE’s guidance to inspectors is now out for review; at nearly double the size of its predecessor, this edition takes the NIS Directive into account and also responds to feedback that it has to be more usable by industry. On the other hand, HSE does not want to be too prescriptive. Also, any guidance needs to couch the issue in terms understandable to non-specialists. Nevertheless, HSE is aware that cyber-security is a moving target.
Work on the topic so far has, Purewal said, identified three significant issues:
- The importance of knowing that supply chain partners are addressing cyber-security threats
- It is vital to know immediately that a cyber-attack has happened, so that it can be dealt with and operations can get re-started
- The availability of capable and knowledgeable people.
Purewal reassured delegates that addressing cyber-security risks is a fairly straightforward task and that they should be able to cover 80 per cent of vulnerabilities quite readily. But companies must understand their systems, how they are connected and where they are exposed.
HSE will start a cyber-security inspection programme under COMAH in the fourth quarter of 2019; NIS self-assessments start in December 2018 for those in scope, with reports due for submission in April 2019.
Andrew Nixon, senior adviser at the Environment Agency (EA), provided delegates with an update on activity in the realm of flood prevention and response, something that the TSA conference has covered in previous years. EA is working with industry to improve resilience, Nixon said, noting that sites in scope of COMAH have a responsibility to prevent off-site environmental impacts, including during flooding.
EA has been working with the COMAH Strategic Forum to develop guidance and to identify hazards and common causes of failure in flood scenarios. A second edition of its document Preparing for Flooding
was published in June 2015, outlining good practice in the identification of risk and risk reduction methods. EA also commissioned the Chemical and Downstream Oil Industries Forum (CDOIF) to develop guidance and best practice in terms of flood preparation; this was published in December 2017 and has received international recognition – it was referenced by the US Chemical Safety Board (CSB) in its investigation into the fire at the Arkema plant in Crosby, Texas in the wake of flooding from Hurricane Harvey in August 2017.
Recent flooding events have generated some important lessons for tank terminal operators, Nixon said. It is vital to understand a site’s topography and its surroundings – where would flood water drain to; how would effluent be treated and stored; are there access routes to and from the site if flooding occurs. It is also vital to understand the flood risk at a site and, if flooding occurs, how bad could it be, how fast would water be moving and what damage could it create. Operators need to remember that flood defences can fail and that, if they do, other mitigation measures may well be affected too.
Nixon pointed to a recent OECD document, Towards an All-Hazards Approach to Emergency Preparedness and Response
, which covers natural hazards and stresses the importance of leadership in preparation and response efforts. EA and the other COMAH competent authorities have used this, alongside their experience of recent events, in the preparation of an Operational Delivery Guide on flood preparedness. This outlines a timeframe for inspection and implementation, to provide assurance that COMAH sites are covered, using a consistent approach. It prompts the sharing of best practice and broader thinking by terminal operators, especially in terms of wider flooding issues and recovery plans. And in terms of planning, Nixon concluded, it is best to do this on a dry day!
After a rejuvenating lunch, during which delegates had plenty of time to browse the exhibition stands, Tony Gower-Jones of the Tripod Foundation gave a challenging presentation under the title ‘Building Better Performance Measures for Better Conversations to Provoke Change’. Or, to put it another way, how to build conversations that will provoke change by using better performance measures; as Gower-Jones said, “You can only manage what you measure.”
A lot of companies work on the premise that, if they do not injure anyone, they are performing well. That is true in a way but, Gower-Jones said, it is a crude metric with a poor signal-to-noise ratio – that is, because there have been no injuries does not necessarily mean that the operation is safe.
There are now, though, plenty of tools available to explain why accidents happen: basically, this is when controls fail, either due to individual choices or lapses. Those happen for many reasons and often reveal an organisational bias. Thus, the need for a change requires a new conversation at the management level.
What sort of conversation should that be? Currently, Gower-Jones said, management tends to focus on events, not on causes. But that is because that is the data they are given. If we want to change the conversation, we have to look at things differently.
Instead of just counting how many people get injured, Gower-Jones said, look at the reliability of the barriers that are put in place to prevent accidents; get different teams to identify which barrier controls are crucial. Human error is a factor in most – if not all – accidents but, he said, what type of errors are occurring? If we can see why people make mistakes, we can put in place measures to stop them making them. Look at management activity and behaviour, he advised: incentivise the process not the outcome. And measure the completion of safety-critical activities.
“Be careful what you measure,” Gower-Jones warned. Choosing the wrong metrics can generate unhelpful changes in reporting behaviour. He advised the measurement of positives, which offers a lower likelihood of the figures being fiddled. And think about the conversation you are trying to create. “The right conversation leads to cultural change, and that leads to better safety,” he concluded.
VOICE OF EXPERIENCE
Ian Travers, a regular presenter at the TSA conference during his many years at HSE and now as an independent process safety consultant, gave an insight into the lessons he has learned from 30 years in major hazard risk control, particularly in the realm of leadership. In his presentation he echoed many of Gower-Jones’ comments, particularly the need to think in terms of outcomes rather than processes, and to listen to and engage with the workforce.
Too many business leaders get it completely wrong and can easily appear remote and out of touch with the company’s operations, particularly in the aftermath of an incident. Most leaders do not go out of their way to discover hazards – they don’t want to know and will deny it if told, Travers said. Management cannot be complacent about the hazards inherent in their operations; they have to recognise that no system or procedure is perfect and understand the hazards and risks they present.
There are, Travers said, five key questions when it comes to process safety:
- How could it go catastrophically wrong?
- Where/when is it most likely to go wrong?
- What controls or systems are there to prevent a major incident?
- Which of these controls are most vulnerable to failure?
- What information is there to show that those systems continue to operate to the desired performance standard?
Process safety leadership is a continual task, Travers said. And it is a continuous loop in which every decision and action to improve safety needs to be validated, evaluated and measured. And it is a process in which communication is a key element.
More communication can be expected at TSA’s 2019 conference and exhibition, which will take place on 26 September. More information will be found on the TSA website.
[post_title] => TSA: The tank arena
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[post_name] => tsa-tank-arena
[post_modified] => 2018-10-23 15:10:00
[post_modified_gmt] => 2018-10-23 14:10:00
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[guid] => https://www.hcblive.com/?p=10271
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