The Benefits of Action Verification

At Finch Consulting our process safety team works with clients from a diverse selection of industries, and whether it’s a mining company, food manufacturer or education establishment, on some level they all have to manage a complex profile of risks including hazardous substances, machinery or equipment, and human factors, making a strategy for process safety management absolutely essential.

Posted

05.11.2024

Written by

Richard Bowen Tristan Pulford

Hazards such as toxic releases, fires, and explosions pose significant threats to personnel, the business and the environment. Among the most effective methods of managing such risks are structured hazard studies, however, while a hazard study may help you to identify how your equipment is most likely to fail and what the consequences of that failure may be, without action, it’s not sufficient to manage your most significant risks. Acting on the results arising from these studies must be carefully evaluated, implemented, and verified to ensure they address the identified issues, and this is where partnering with an independent process safety consultancy can offer significant benefits.

With your hazard study complete, the subsequent actions must either eliminate or mitigate the risks identified during the sessions to a level that is both suitable and sufficient. However, organisations often struggle to ensure that the actions are appropriate and that the issue has been addressed once the action is complete.

Industry guidance, such as the UK Health and Safety Executive’s (HSE) Successful Health and Safety Management (HSG65), emphasises that risk control measures must be proportionate to the level of risk and capable of fully addressing the issue. In practice, this means that each action must be evaluated to ensure it will resolve the underlying problem rather than simply providing a temporary fix. For example, installing a pressure relief valve might address the immediate risk of overpressure, but unless the root cause of the issue (e.g., inadequate process control) is also addressed, the risk may re-emerge.

Partnering with Finch’s process safety consultants can play a crucial role in this process by reviewing and validating the proposed actions.

Their objectivity allows them to critically assess whether the actions are fit for purpose and whether they comply with industry standards and regulatory requirements. The Centre for Chemical Process Safety (CCPS), a global leader in process safety guidance, highlights the importance of independent reviews in its publication Guidelines for Risk Based Process Safety. The CCPS argues that independent assessments help ensure that mitigation measures are both effective and sustainable over the long term.

The Need for Verification of Action Completion

Once actions have been defined, they need to be implemented and verified. This is a critical phase in the process safety management lifecycle, yet it is often one of the most challenging. Organisations may believe that once an action has been identified and assigned, the problem is solved. However, there are numerous cases where actions have been recorded as complete when they have been either partially implemented or are simply ineffective.

For example, in the US, the Chemical Safety Board (CSB) has repeatedly highlighted the dangers of incomplete or insufficiently verified corrective actions in its investigations into major industrial accidents. In its report on the 2005 BP Texas City refinery explosion, the CSB pointed to a failure to follow through on recommended safety improvements as a contributing factor to the disaster.

Independent action verification adds an additional layer of expertise to the process, as by reviewing the implementation of actions, independent specialists can provide assurance that the actions have been carried out as prescribed in order to achieve the intended risk reduction. This process typically involves Finch consultants checking documentation, inspecting physical installations, and verifying that the actions are functioning as expected. Additionally, this process can ensure that all completed actions are properly recorded, creating an audit trail that is crucial for demonstrating regulatory compliance.

Avoiding Common Pitfalls in Action Implementation

There are several common pitfalls in action implementation that Finch’s consultants are well-placed to identify and address:

Action Design: does the action address the issue that has been identified? Gaps in competence or system knowledge can lead to some actions being created that do not eliminate or mitigate the risk that has been identified. Worse still, some actions can even create unintended consequences that increase the risk instead of lowering it.
Incomplete Implementation: In some cases, actions are recorded as complete when they have not been fully implemented. This could be due to miscommunication, lack of resources, or the action being deprioritised. An independent verification ensures that this is not the case.

Inadequate Risk Mitigation: Actions may be implemented but are insufficient to fully address the identified risks. A Finch consultant can critically evaluate whether the action is sufficient or if further steps are needed.
Failure to Adapt: Over time, changes in process conditions, technologies, or operational procedures may render initial actions obsolete or insufficient. An independent review ensures that actions are still relevant and effective in mitigating risk.

By providing an objective, third-party assessment, Finch’s independent consultants help organisations avoid these pitfalls and ensure that process safety improvements are sustained over the long term.

The Health & Safety Executive place significant emphasis on the need for thorough risk assessment and action follow-up. The COMAH Regulations requires that identified hazards are mitigated through appropriate actions and that these actions are verified to ensure they are effective. Independent verification can help organisations meet these regulatory requirements by providing thorough action verification and ensuring that all risks are addressed in line with best practice. Moreover, their involvement promotes a culture of continuous improvement, as they can help identify opportunities for further safety enhancements beyond the immediate scope of the hazard study.

Relying solely on internal teams for process safety actions can leave organisations vulnerable to cognitive biases, incomplete follow-up, and insufficient risk mitigation. Finch Consulting offers objective, expert facilitation of your hazard studies and assurance that the actions arising from these studies are suitable, sufficient, and properly verified. By doing so, we help our clients avoid common pitfalls, meet regulatory requirements, and enhance their overall process safety performance.

For companies seeking to improve their process safety systems, partnering with Finch is an investment in long-term operational safety and resilience.

We give you the confidence to be a better business.

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The Benefits of Using an Independent Process Safety Consultancy for Action Verification

Posted

Written by

The Need for Verification of Action Completion

Avoiding Common Pitfalls in Action Implementation

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The Benefits of Using an Independent Process Safety Consultancy for Action Verification

Posted

Written by

The Need for Verification of Action Completion

Avoiding Common Pitfalls in Action Implementation

Written by

Richard Bowen

Senior Consultant

Tristan Pulford

Capability Director

Related insights

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HAZOP for thermal oxidisers – What are thermal oxidisers and why do they need a HAZOP?

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