Process safety studies are a widely used method for identifying risks and recommending improvements. They generate valuable insight, but they also generate actions, and managing those actions effectively is often more challenging than conducting the study itself.
Action tracking is meant to ensure that HAZOP recommendations are owned, completed and verified. When it goes well, risks are reduced and compliance is strengthened. When it goes poorly, actions drift, accountability blurs and opportunities to prevent incidents are lost.
Understanding the common challenges in HAZOP action tracking helps organisations build stronger systems, improve follow-through and close the loop between risk identification and risk control.
Why Action Tracking Is the Weakest Link in Process Safety Studies
Most organisations invest significant time and expertise in process safety studies: HAZOPs, PHAs, LOPAs, SIL assessments, bow-tie analyses, audits, and risk assessments. Workshops are carefully facilitated, hazards are debated in depth, and action lists are produced with the best of intentions.
And then the study ends.
What happens next is often far less rigorous, even though it is arguably the most important phase of all: action tracking. Time and again, incidents show that the failure is not a lack of hazard identification, but a failure to implement, sustain, and verify the actions that were agreed.
This problem is not unique to HAZOP. It is systemic across almost all types of safety and risk studies.
The illusion of “study completion”
In many organisations, a study is considered “complete” once the report is issued. In reality, that report is little more than a structured risk register. The real safety outcome depends entirely on whether the identified actions are clearly defined, owned by the right people, implemented as intended, and kept valid over time.
Without robust action tracking, even the best studies become static documents that describe risk rather than control it.
A shared problem across study types
While HAZOP often receives the most attention, the same weaknesses appear across other study types.
HAZOP and PHA actions are frequently vague, mixing analysis tasks with design changes, and are often closed based on statements rather than evidence. Over time, the original intent of an action is easily lost.
LOPA actions are tightly linked to assumptions: operator response times, proof test intervals, alarm performance, and independence of protection layers. If these assumptions are not actively tracked and verified, the claimed risk reduction quietly erodes.
SIL and functional safety studies generate actions spanning design, hardware, software, procedures, testing, and competency. Weak action tracking leads to safety functions that exist on paper but do not achieve their required integrity in practice.
Bow-tie and barrier studies are excellent for visualising controls, but actions to maintain barrier effectiveness are often poorly integrated into operational systems, leaving degradation unmanaged.
Audits and incident investigations suffer the same fate. Findings are duplicated, ownership drifts, and similar issues resurface years later under new reports.
Common failure modes in action tracking
Across all of these study types, the same challenges appear again and again.
Actions are poorly defined, using vague language with no clear acceptance criteria. Ownership is ambiguous, assigned to departments rather than individuals, making actions vulnerable to organisational change.
Actions are often separated from their original hazard, consequence, or risk scenario, so future reviewers cannot judge whether closure is appropriate. Many actions require design or procedural change but are not properly linked to Management of Change systems.
Long action lifecycles mean that assumptions, standards, and operating conditions change while actions remain open. Closure is frequently based on assertion rather than objective evidence, and prioritisation rarely reflects the level of risk being controlled.
The hidden role of tools
Many of these problems are made significantly worse by the tools used to manage actions.
Despite the high governance expectations placed on process safety actions, they are commonly tracked using Excel spreadsheets, Word documents, or static PDFs. These tools are familiar and flexible, but they were never designed for safety-critical governance.
They offer no inherent audit trail, weak version control, limited access control, and poor linkage between actions, risk scenarios, and evidence. Overdue or high-risk actions rely on manual follow-up rather than systematic escalation. Files are copied, emailed, renamed, and locally modified, fragmenting the single source of truth.
Using low-governance tools for high-governance risks creates a fundamental mismatch. Dedicated action management or risk governance systems can enforce ownership, maintain traceability, integrate with Management of Change, and require objective evidence before closure. Without this, even well-run studies are undermined by fragile follow-through.
Why this matters
From a regulatory perspective, weak action tracking is increasingly indefensible. Regulators expect clear traceability from hazard to risk, from risk to action, and from action to verified safeguard.
From a safety perspective, poor action tracking creates a dangerous illusion of control. Risks are believed to be managed when controls are incomplete, degraded, or misunderstood.
From a business perspective, it leads to inefficiency: repeated studies, repeated findings, and repeated discussions about issues that were supposedly addressed years earlier
Reframing action tracking as a safety-critical process
Action tracking should not be treated as administrative follow-up. It is a core element of risk management, equal in importance to the study itself.
Good practice means writing actions that are specific and testable, assigning single-point accountability, linking actions to risk ranking and timescales, integrating with Management of Change and operational systems, requiring objective evidence for closure, and periodically revalidating long-lived actions and assumptions.
When action tracking is done well, safety studies become living controls that actively reduce risk. When it is done poorly, it quietly erodes even the most sophisticated process safety frameworks.
An Embedded HSE tool
When implemented well, a good action tracker ensures that actions from HAZOPS (or any other high-governance study) translate into real safety improvements. When it falters, actions languish, visibility is lost and risks persist.
Common challenges such as unclear ownership, disconnected systems, poor definitions and weak follow-up aren't unique to any one organisation, although they will present in different ways. They reflect the complexity of managing change, priorities and risk in dynamic work environments.
Addressing these challenges requires clarity of roles, realistic planning, leadership support and continuous learning.
