Background.....
Seveso III – Public
Information
The European Commission updated the Seveso Directive in line
with the Aarhus Convention [1] on public information, public participation in
decision-making and access to justice on environmental matters. This is quite a culture shift from the
requirements in the Seveso II Directive.
In line with the Aarhus Convention the changes will mean
that:
- the level and quality of information for the public will need to be improved, particularly for those likely to be affected;
- active provision of information – not just on request;
-
the information will need to be available
electronically and kept up to date.
It’s a scene familiar to many of us. The HAZOP Chair asks “And are we comfortable that the safeguards you mentioned are sufficient against this hazard? Can you explain that to us?” And the process engineer is at the centre of attention, expected to have the facts at her fingertips. But it’s not a major crisis. The design is well done. The hazards, although complex, are understood, and the approach being taken may be novel to some, but is the right solution. So the answer is given, the team gives it consideration, the scribe records the discussion, the process moves on.
Many of us work in complex, high
hazard industries. The application of
safety in design, ergonomics, risk assessment, process safety, means that for
the vast majority of time, the hazards stay as potential, not actual
harm. We are degree qualified engineers,
chartered, even fellows of our institutes.
We play our part, get the job done. Within our offices, within the plant, within
the technical bubble we work in, our jargon, our common understanding, our
acronyms and buzzwords communicate to our peers, our operators, and sometimes
our management, that we have our risks under control.
Picture the same engineer, but this time at the local town
hall. The new regulations being
introduced across the EU in 2015, shaped by our experience and the experiences
of our neighbouring countries, mean that the public will soon have access to
more information about our high hazard plants, the substances we routinely deal
with, the controls that we have in place.
But she’s now outside of the technical bubble, and the audience doesn’t
have the knowledge and understanding she’s used to. They’re not unintelligent; they may well have
complex jobs, managing complex situations.
But SIL, LOPA, QRA are not part of their daily lives. They have no idea what a “mitigated event
likelihood” is, or how we set and achieve a target. Chemical formulae and jargon may well make
them feel stupid. Would that engineer be
able to explain that all is under control?
But that is exactly the challenge that Judith Hackitt set us
at the Hazards 24 conference this May in Edinburgh. We are the people who understand the risks, and
deal with the balance of keeping risks as low as reasonably practicable. And with our understanding, and our skills,
we should be able to explain to the man or woman on the street how we can and
should have facilities managing major accident hazards, maybe not directly in
their “back-yard”, but certainly close enough to them to be affected by our
work.
Lee LeFever makes explanation videos for a living. In his November
2012 book, “The Art of Explanation”, he presents an A-Z scale of knowledge and
understanding. We are topic experts. We sit in our bubble, at the WXYZ part of the
scale. But the people we need to reach
are back at the start of the scale, and with our jargon, impenetrable language,
and science stuff, we leave them behind a large wall. The cost to them of understanding what we are
on about is huge. Why should they even
bother trying?
It should be simple:
an explanation describes facts in a way that makes them
understandable. But to make that
explanation work, we need to have the ability and the courage to picture
ourselves in another person’s shoes, and communicate to them from that
perspective. However, a good explanation is not always
easy. It needs to start from the context
of what the audience can understand, and set the scene. If the concept is difficult, we need to find
analogies to things people do understand, that don’t trivialise the issue, but do
lower the cost of understanding.
For example, we deal with the concept of ALARP across
industries, and in many legal jurisdictions around the world. We all can grasp the concept that society
does not seek to eliminate all risk. For
us engineers, this means that we need to make the maximum impact that we can,
but we don’t have infinite time or money to solve all the problems. And there’s only so far we can go. We can aspire towards zero harm, but the law
recognises that’s not always possible.
If we were to extend the ALARP concept to, say, speed
limits, we wouldn’t necessarily end up with a strict hierarchy of 20 mph near
schools, 30 mph in built up areas, 60 mph on A roads, 70 mph on dual
carriageways. When the school is
emptying of children, we could do a lot of harm at less than 20 mph, and 10
minutes later do no harm at all at a higher speed. 60 mph would not be appropriate in freezing
fog, or driving rain. If we happened to
be all alone on a four lane motorway in good conditions, we could probably
safely drive at 100 mph or more with no consequences for us or for the rest of
the world.
Our safety case regime means we take an approach to the
hazards, in this case the speed, that’s proportionate to the risk. We look at the kind of risks we want to
control, like we might plan our journey past that school, and onto the
motorway. We think about the likely
scenarios we would face, and whether our local situation would influence the
likelihood of snow, ice, and rain. We
would examine the features of our car, and how its design, control and safety
systems would help us with the journey. We
would publish our case to the regulator about how we would keep the risks on
this journey to a sufficiently low level to meet our expectations, and the
expectations of the wider society. We
would have to keep the regulator informed about this for as long as we were planning
to carry out such journeys.
[As an aside, Montana in the USA did operate an ALARP speed
limit regime, in that state law asserted that "A person ... shall drive
the vehicle ... at a rate of speed no greater than is reasonable and proper
under the conditions existing at the point of operation ... so as not to unduly
or unreasonably endanger the life, limb, property, or other rights of a person
entitled to the use of the street or highway." American case law does not however share the
UK legal tradition of “reasonableness”, and this approach was ruled
unconstitutional in 1998.]
The preceding example illustrates that while ALARP can be
impenetrable for some, with a little creativity, we could develop explanations
for people that would help them over the high-cost barrier, let them understand
why they should care about what we do, and put them in the market for better
information on the risks. But such
explanations are not readily available for us to cut and paste. We need to generate these as industries, as
professions.
It’s not hard to imagine the consequences if we don’t. While we are all closer to some major hazard
sites than we may realise, we can all be guilty of relegating them to the
“someone else is looking after that so we’re grand” category. In my 16 mile commute to Aberdeen, I cross three
major pipelines, but don’t think too much about the management of that
risk. And on these small islands, if we
don’t do our jobs well, we may well end up beyond NIMBY – Not In My Back Yard,
to what Stephen Norris called “BANANA”, “Build Absolutely Nothing Anywhere Near
Anybody”. We can’t afford for that to
happen.
The challenge is out there.
We need to explain better, and we need to think more about how we
explain. We know we are professionals,
that we are part of amazing industries doing fundamentally important things,
maintaining life and living standards for many.
We all have “explainer” in our
job titles, whether we want to or not.
Further reading:
“The Art of
Explanation”, Lee LeFever, Wiley and Sons, 2012
“The
Back of the Napkin”, Dan Roam, Marshall Cavandish 2009
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