A Vital Lesson from Piper Alpha – ‘Prove It’
The Piper Alpha disaster of 6th July 1988 killed 167 men and seared the memories of all touched by it. For some it remains a deep emotional wound that may never fully heal. Learning to live with and learn from grief is part of what it means to be human. It can be an experience that creates determination and energy to drive through improvement. Those of us with less direct contact with such events must also connect with these emotions to strengthen our drive to learn and implement the lessons. Accounts such as Stephen McGinty’s ‘Fire in the Night: The Piper Alpa Disaster’ can help with this.
Piper Alpha has been a primary source for many vital lessons for both high hazard and occupational health and safety. These include the need to ensure, for example,
- effective permit-to-work and shift handover procedures
- that hazardous events and how they may escalate are fully understood
- emergency systems and procedures are maintained in a state of readiness, are protected from the hazardous events where practicable, and will be put into action without delay
- thorough high quality auditing that is, by definition, independent.
Underpinning these practical lessons, Piper Alpha led to a major change in the regulatory environment for off shore installations, the Offshore Installations (Safety Case) Regulations 1992 (and 2005). This was an offshore adaption of the regulatory framework propose in 1976 in the First Report of the Advisory Committee on Major Hazards (ACMH) set up after the Flixborough explosion. The work of the ACMH was heavily drawn on for the first Seveso Directive, implemented as the CIMAH Regulations in the UK, and more recently the COMAH Regulations. The ACMH took inspiration from the Nuclear Installations licensing regime introduced in 1965. Following the King’s Cross fire in 1987 and crash at Clapham Junction in 1988, the Railways (Safety Case) Regulations 1994 (and 2000) were introduced. The MOD introduced safety case principles for military systems during the 1990s. And now, following the shocking Grenfell tower fire, the Independent Review of Building Regulations and Fire Safety: Hackitt review has proposed safety case principles are applied to buildings fire safety for large complex projects.
These regulations require the organisations accountable for risks capable of causing catastrophic widespread harm to demonstrate to a regulatory authority that they have
- a comprehensive understanding of their hazards and accident scenarios,
- identified and implemented appropriate prevention, control and mitigation measures, and
- systems in place to ensure these measures remain present and reliable.
This demonstration, when sufficient, gives such organisations their license to operate. Whilst not perfect, this ‘prove it’ approach to high hazard regulation has without doubt resulted in improved risk control.
We use a similar approach for occupational health and safety competence where the consequences of failure can be serious. We use knowledge and skills tests for driving on the roads and for vehicles such as fork lift trucks and cranes. We license asbestos contractors, certify radiation protection advisers and register gas engineers.
So why do we so often accept superficial demonstration of competence for management and leadership roles where the individual is accountable for serious health and safety hazards? Has it ever been acceptable to take it on trust that good decisions are always made when people are appointed to positions with such serious safety accountabilities and responsibilities? Why do we think that training that concludes with short term memory tests is proof of safety management and leadership competence?
Just one organisation I have encountered requires new managers to robustly demonstrate the success of their efforts to understand the hazards and control measures in their area of responsibility. They do this at the end of a 6 month probationary period with a panel of experienced managers and specialist advisors. They get support, but retaining their job depends on success with this process.
More organisations need to put in processes like this. Perhaps our failure to invest in developing and demonstrating competence in safety management and leadership, from front line managers to chief executives, explains why slow progress is made with improving safety performance and culture.
Are the benefits of requiring such demonstrations of capability by senior leaders an important missed lesson from Piper Alpha?
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