An Interview With Peter Davidson, Executive Director at the Tank Storage Association.

Peter is Executive Director at the Tank Storage Association responsible for developing and promoting excellence in risk management in the sector and for leading engagement with key government stakeholders and regulators. Prior to joining TSA Peter was Safety, Commercial and Projects Director at UK Petroleum Industry Association. Peter was a pivotal member of the Buncefield Standards Task Group, the joint industry and regulator body responsible for improving safety in the fuel storage sector. His early career was at ABB as the Regulatory Compliance Manager.

Peter, welcome. Thank you for chatting to me. I’m looking to encourage and promote process safety, particularly with new engineers and people new to process safety so that they see it as an important aspect of their career. I invited you to take part because you've been very influential to me. We walked a very dodgy path together following the Buncefield major accident to get industry and regulators united and on the same track and signed up to never let that sort of incident occur again. I'm very grateful for all of your hard work over the years.

I wanted to chat to you about what brought you to be one of the major influences in UK health and safety high hazard sector?

How did you end up here?

A key role in risk management was not what I was expecting. I started out with ABB, very large Swiss/Swedish engineering company as an automation engineer designing control systems. That's really where it started, because I was designing control and safety systems for highly regulated industries. Most of my work was in the pharmaceutical sector, but also nuclear - working on many projects at Sellafield. So, there was always this idea of a very detailed commitment to understand the processes to design the software to ensure that we built in inherent safety. And that was where I expected to be now, but then the Buncefield event happened.

I had the opportunity to work for a Trade Association, the UK Petroleum Industry Association, UKPIA, to represent the interests of downstream oil, primarily the refineries and a number of terminals. At the time the sector knew they needed to do more on process safety to implement the findings from the Buncefield Standards Task Group. That's really why I made the switch. But did I expect to be here? No!

When you were doing that complex technical work with ABB, what was your mindset? Was it that this has got to be right, because there's no room for error or there could be a catastrophe?

It is very influential. I have always been one of those folks that like things to be written down, very clear and unambiguously. That has really driven me to be noticeably clear about the way in which process safety systems and information should work. The reasons underpinning control system design and guidelines need to be accessible and easily understood. If people understand what the difficulties are, or the challenges associated with a particular process or environment, the more likely it will sink in and they will understand the need for control.

What excites you about your work?

It’s bringing together people from different backgrounds, companies, and sectors to find common solutions to problems. There are very few problems in our industries that aren't fixable. It just takes time and commitment from all those involved to try and find a good workable solution. The excitement comes from when you find those solutions, particularly if they are simple, easy to understand and to implement. We have an amazing capacity to unnecessarily over complicate safety.

In the last 10 or 15 years, what do you consider the most important improvements in risk management which delivered on the ground benefits?

It’s this concept of greater collaboration and communication between businesses, but also with regulators. I don't think that we had the same relationship with our regulators 15 years ago as we do today. There are peaks and troughs, but we have a far, far more collaborative approach. It isn't adversarial, either with a regulator or between businesses within a particular sector. There's a willingness to try and work more closely together to solve some of the problems that we share and a realisation that, anything that happens to one is going to impact us all. Which is clearly what we saw from Buncefield and many other incidents before that.

Does your voice get heard, and are the views of industry taken seriously?

Yes, anyone who's involved in these discussions, and the work that goes on as part of those discussions must be prepared to put in the effort. When businesses, regulators or trade unions and other stakeholders, see individuals and organisations putting effort into genuinely trying to improve, people do take notice. It would be different if all we did was wave the red flag and complain about everything. I'm pretty sure that regulators know we will be the first to put our hat in the ring to work on guidance development, data gathering or analytics for our sector.

Do you see a similar collaborative approach outside the UK across Europe?

We have a unique and excellent model here in the UK. I talk to my European colleagues regularly about process safety. I don't see the same approach and there is far more prescription across Europe. An approach that, provided you follow the standards and tick all the boxes, then that's all you need to do. There doesn't seem to be the concept that you need to think out of the box about what could go wrong. I think that's changing slowly. But it is a slow change, even convincing my European colleagues to start sharing common process safety performance indicators, has been a challenge that I've been battling for five, six years now. And we’ve still not achieved it.

Building on that, do you find companies that operate both in the UK and across Europe can behave in those different modes? Does that influence how they interact with the regulator as well? For instance, more open and connected in the UK, but more circumspect and cautious when talking to their local European regulator?

They will adopt the attitude that's demanded by the regulator in that geographical region. However, with respect to process safety programmes, and process safety management within those organisations, they tend to adopt a consistent model and standards across all their business areas, regardless of the country they are operating in. From my experience that's the UK model.

How do you think regulators could improve both in the UK and elsewhere?

Two words, clarity, and consistency. Therefore, I'm a big supporter of initiatives such as the UK Chemical and Downstream Oil Industries Forum, CDOIF. It's one mechanism that we all have to try and provide that consistency and clarity. We don't always get it right, but it really does promote understanding between both regulators and duty holders.

The regulators have a difficult job which is becoming increasingly more difficult with increased responsibilities such as UK REACH and acting as the new Building Safety regulator. This is a huge draw on resources and expertise. That is why working more collaboratively with industry and other stakeholders is the right way to go.

Put the shoe on the other foot. What do your colleagues in industry get wrong?

I see an ever-increasing reliance on third parties and consultants without sometimes the necessary background knowledge to act as an intelligent customer. With a whole series of important issues such as functional safety, cyber security, human factors companies may not have the expertise in-house. They rely on third parties and consultants, there is no problem with that, but they still have a responsibility for the outcome and approach. This comes back to my point about our capacity to overcomplicate things and why we need to simplify when it’s appropriate. Many of these topics are not difficult, and they shouldn't be. But unfortunately, sometimes people like to overplay what some of these things mean. We use far too much jargon when we just want to say a simple thing.

Also, regulators need to understand the challenges businesses face within specialist topics. It's fantastic having a specialist Inspector going to a site looking in great depth at say functional safety. But inspectors need to take a broad view as well in terms of what's actually important at a facility in managing the risk appropriately. That may not be a line by line understanding of for instance, IEC 615 11.

What's your big fix – what would you like to see improved?

I would like greater recognition by Government that our ways of working and management of risk is something that we should be proud of and that UK Government actively encourages. I think that would provide the incentive for far more people to become more engaged.

Let’s move off the technical issues and share something about you as an individual. What are your hobbies?

Fortunately, I'm standing in front of my whisky collection. I'm very much into Japanese whisky at the moment. I also still like my cars, my motor racing, of course my dogs and my secret hobby tropical fish!

I've always admired my dad who's no longer with us. He was head of instrumentation and control at British Gas. I always remember he had the same outlook as me, which is to make things as simple as you can and try and communicate things as clearly and concisely as you can. I try and live by those rules.

What advice would you give to yourself aged 18?

Listen more. There are periods in your life, whether that's in your personal life or in your business life, when you just need to shut up and listen and think about the response you're going to give to a particular question or a query. The more that we learn to do that, the better we will be at working closely with people.

What do you think the kind of big advances are going to be in risk management and risk thinking in the next 10 years?

More and more automation and artificial intelligence, including augmented reality in training and competency. The Coronavirus pandemic has accelerated this trend. There's no reason why this shouldn't be. The key point is being an intelligent customer for this technology. If you really don't understand your fundamental risks, that's a big worry - I don't have an issue with automation providing we don’t relinquish our responsibilities to manage those risks.

Any parting thoughts or insights that I should have maybe raised that you?

We need to have a conversation about the people. We often focus on graduates. When it comes down to safety on the ground, we rely on people who don’t have degrees, but who are nevertheless vital to safe operations. Sometimes we need to recognise that front line workers are just as important, if not more important, than the folks that are designing plant and processes in the office. I hope we are going to see apprenticeships as far more important in the future. I'd like to see a future in which people with front line experience can influence safety within organisations at all levels.

Peter thank you. As I anticipated some fantastic insights and thoughts from you. When it comes to process safety, consistency and clarity are key.