Compliance-based and risk-based strategies for managing and enhancing organisational processes represent two distinct approaches. Each has its own set of principles, methodologies, and objectives, catering to different priorities and circumstances. However, it is important to note that the two approaches are not mutually exclusive, especially when it comes to process safety management.
Compliance-based Strategies
Compliance-based strategies focus primarily on adhering to established rules, regulations, and industry standards. Organisations following this approach prioritise meeting specific requirements and ensuring that their operations align with legal and regulatory frameworks. It is particularly prevalent in industries where strict guidelines govern operations, such as finance, healthcare, and information security.
Organisations invest significant resources in understanding regulations relevant to their sector, aiming to avoid legal consequences and reputational damage. The central tenet of a compliance-based strategy is the systematic adherence to predefined standards, where adherence to the standards serves to ensure compliance with the relevant laws.
One of the advantages of this approach is the clarity it provides. Organisations can point to specific regulations and standards, demonstrating their commitment to meeting these requirements.
But a singular focus on compliance may also lead to a checkbox mentality, where the goal is to fulfil requirements rather than to genuinely improve processes and mitigate risks. An important point to remember in this respect is that while regulations provide a necessary and important baseline, they should not be seen as the upper limit of what can be achieved. Regulations tend to lag issues and incidents in the real world, so embracing this approach may mean valuable lessons are not adopted by organisations, as quickly as they might be, were they taking the initiative themselves.
Risk-based Strategies
Conversely, risk-based strategies revolve around identifying, assessing, and managing risks that could impact an organisation’s objectives.
A Risk-based strategy acknowledges that not all risks are equal. It encourages organisations to allocate resources where they are most needed, concentrating efforts on mitigating high-impact, high-probability events. This dynamic approach fosters adaptability, enabling organisations to respond proactively to emerging threats and opportunities, improve performance, and even gain competitive advantage in the marketplace.
The core strength of a risk-based strategy lies in its holistic perspective. By continually assessing the risk landscape, organisations can make informed decisions that align with their strategic goals. It encourages a culture of risk awareness and resilience, preparing organisations to navigate uncertainties in a rapidly changing business environment.
In the hazardous process industries where the stakes for people and the environment are high, a risk-based approach is considered best practice, requiring appropriate and proportionate use of risk assessment to derive suitable engineering and procedural controls for preventing fires, explosions, accidental chemical releases, and structural collapses. The relevant process safety regulations in themselves advocate continuous improvement of the measures in place based on regular review of risk assessments. [1,2]
For those establishments regulated under COMAH [2], the underpinning Safety Management System (SMS) and associated practices and procedures must be proportionate to the hazards, industrial activities, and complexity of the organisation in the establishment. [3] Recognising that systems and procedures can degrade with time, they should also be subject to periodic and systematic assessment, to ensure that they remain effective. [4]
Balancing Act
Compliance-based and risk-based strategies represent distinct paradigms. Achieving compliance is crucial for legal and reputational reasons but coupling it with a risk-based approach enhances an organisation’s ability to navigate uncertainties and seize opportunities.
Striking this balance requires an understanding of the organisation’s tolerance for risk, strategic objectives, and the regulatory landscape. The integration of compliance requirements into a broader risk management framework ensures that regulatory adherence becomes a natural byproduct of proactive risk mitigation efforts.
The most successful organisations will integrate elements of both approaches, complying with internal standards aligned to regulations, industry standards and good practice guidance, while proactively managing risks to achieve long-term resilience and success. The same is true for those leading in process safety management.
All of this requires sound systems and procedures, a competent workforce, and measures in place to demonstrate that they are always working effectively. If you would like help on SMS design and the demonstration process, do get in touch today.
[1] DSEAR in detail – Fire and explosion (hse.gov.uk)
[2] A guide to the COMAH Regulations 2015 – L111 (hse.gov.uk)
[3] Gain tighter control over your own PSM programme. – OpenPSM
[4] PSM is about people, plant and systems, and what they do in real life – (openpsm.uk)