In Safety Moment #24: Where Then Shall (Process Safety) Wisdom Be Found? we suggested that an effective safety management system is built around three elements: Formal Systems/Education, Process Safety Management Systems and Practical Experience. When we combine these three elements we move toward Operational Excellence or Process Safety Wisdom, as shown in the sketch at the top of this page.
We further suggest that the sector which provides the greatest opportunity for improvement in the third of these: Practical Experience. So how do we capture practical experience in an organized and structured manner?
Consider the story that we told in Safety Moment #25: There’s No Substitute for Knowing What You’re Doing. In that story a highly experienced superintendent knows from experience immediately what to do to solve a problem. How do capture his experience in a structured manner? How do we transfer that experience to someone who is new to the facility? After all, the superintendent himself may not know why his actions work — he just "knows".
Organizing Practical Experience
To address this question as to how to capture and organize practical experience it is useful to look at an analogous situation: the introduction of a process safety management (PSM) program into a company or facility that does not have such a program.
The first step is to in the development of such a program is to structure the program into management elements. In the late 1980s when the United States Occupational Safety and Health Administration (OSHA) faced this challenge they put forward a system organized around the following 14 elements.
- Employee Participation
- Process Safety Information
- Process Hazards Analysis
- Operating Procedures
- Pre-Startup Safety Review
- Mechanical Integrity
- Hot Work Permits
- Management of Change
- Emergency Planning
- Incident Investigation
- Trade Secrets
Once the structure has been established the second step is to carry out an audit in order to establish a baseline, to identify gaps and deficiencies and to provide the basis for the development of a PSM program.
With this idea in mind we are developing an Operational Excellence Assessment system to address opportunities to do with capturing practical experience. The system consists of hundreds of questions, along with expert guidance, to help you evaluate the quality of your process management systems.
We have developed an Operational Excellence Assessment System to help address the challenge of capturing practical experience, and we decided to follow a similar thought process, i.e., first structure a system and second create a means of establishing a baseline.
The structure is organized around the 18 elements shown below. It is based on the traditional PSM elements but it also incorporates features directed toward field experience.
- Compliance and Standards
- Risk Analysis
- Safety in Design
- Information Management
- Hazard Identification
- Written Procedures
- Safe Work Practices
- Asset Integrity/Reliability
- Training and Performance
- Management of Change
- Human Factors/Health
- Emergency Response
- Incident Investigation
- Operational Readiness
The second step in the development of this system was to create a means of assessing (not auditing) a facility (the crucial distinction between assessments and audits is discussed in Safety Moment #27: Audits and Assessments).
This challenge was addressed by developing hundreds of questions organized according to the elements shown above. But, unlike an audit system, there is no single Yes/No response to the questions. Instead a numerical response to each question is provided in which the numbers have the following meanings:
- Missing/Not Acceptable
N/A Not Applicable
To illustrate this concept let us look at Element #17. Operational Readiness (equivalent to OSHA's Pre-Startup Safety Review).
Currently this system has 128 questions. (The thought of answering so many questions appears to be daunting. But it really isn’t; there is no need to address every question — after all, assessment questions are not audit questions. There is no requirement that every question be answered in detail; we are looking for means of improving operability and safety — not for meeting an external requirement. It could be that thinking through the response to just a handful of questions can provide useful insights.)
The first question in the Operational Readiness family of worksheets is,
126.96.36.199 Do the operations and maintenance managers understand that they are the customers and that the review gives them full authority not to accept the facility in its current condition?
A typical response could be to give it a score of ‘1’ (Poor) supplemented by the following note:
Discussions indicate that managers in operations and maintenance do not always realize that they have the authority to stop a facility from being started if they think that it could be unsafe, even though regulations, such as the Pre-Startup Safety Review rule from OSHA, back up the managers with the force of law.
When comparing process safety management with operational excellence we said that there were two steps: (1) Develop the organization, and (2) Create an audit protocol. For the operational excellence program there is actually a third step: provide guidance and commentary. It is not enough just to ask questions — some guidance in the form of a Commentary is needed. For question 188.8.131.52 the following commentary is provided.
This is the single most important question in the Operational Readiness workbook. Those responsible for operating and maintaining the changed facility have full authority not to accept the modifications if they feel that, to do so, would create unacceptable safety problems.
A system such as this does not provide the “right answers”, nor does it offer complete answers. And it never calls for a compliance-style “Yes/No” response. Instead it provides a means of capturing experience, providing guidance and encouraging discussion as to what actions can be taken in this facility to improve safety and operability.
Copyright © Ian Sutton. 2018. All Rights Reserved.