The OSHA (Occupational Health & Safety Administration) process safety management (PSM) rule is 26 years old on June 1st. That’s 26 years — that’s a long time. The standard is older than people now entering the process and energy industries.
The achievements of the standard are well known. Words and phrases such as HAZOP, Management of Change and Prestartup Safety Review are now part of the lectionary. But maybe it is time for some fresh thinking. (This thought lies behind some of our earlier Safety Moments such as Safety Moment #24: Where Then Shall (Process Safety) Wisdom Be Found?)
Let’s take the manner in which we organize and run a HAZOP as an example. The traditional HAZOP is led by a Facilitator and a Scribe. The team typically consists of around half a dozen members, with each person representing a different discipline or department. The Facilitator, who often comes from an outside organization, leads the HAZOP discussion — primarily by calling out guideword phrases such as “Reverse Flow” or “Contamination” and then encouraging the team members to think of:
- Potential causes for the event;
- The likelihood of its occurrence;
- The overall risk of the event; and
- The nature of the safeguards that prevent or mitigate the event.
The Scribe, meanwhile, is taking notes and making sure that the discussion has been recorded in a thorough, but not too rambling, manner. If the hazard is considered to be significant it is risk ranked and a Finding (not a Recommendation) is recorded.
This approach has, of course, been highly successful. But maybe it is running out of steam. Most process safety standards require that the HAZOP (or other hazards analysis technique) be refreshed every few years (the OSHA interval is five years). This means that an older facility will have been analyzed as many as five times since the PSM standard was introduced. If the facility itself has not undergone major changes during that time, and if the Management of Change system is working effectively, then it is unlikely that the refresher HAZOPs will uncover major issues. The low hanging fruit has already been plucked.
It also means that any major issues that do remain are likely to be subtle and even somewhat weird. In the early HAZOPs it was possible to find single cause, high consequence hazards. Such simple situations arise far less frequently now.
One response to this maturity of the HAZOP technique is to use different analysis techniques such as LOPA (Layer of Protection Analysis). But it is also useful to consider how a HAZOP meeting might be restructured in order to inject it with fresh thinking and vitality.
Leaders, Facilitators and Scribes
Consider, for example, the roles of the Facilitator and Scribe.
One possibility would be for the Scribe to become the Facilitator. He or she would organize the discussion, call out the guidewords and basically direct traffic. The personider who, up until this point, has been called the Facilitator, now becomes a Leader and has a different role. He or she understands that the key word in the phrase Process Safety Management is Management. Therefore, while the team is considering a single situation, such as high pressure in a specific vessel, the Leader will be wondering how the company management systems allowed high pressure to occur at all — regardless of the specific equipment item.
During the hazards analysis a team member may make a comment such as, “That problem doesn’t exist any more”, the Leader will pounce on the words “any more” and ask questions such as,
- What was the problem in the past?
- How and when did it get fixed?
- Could it occur again?
Jokes and Laughter
Jokes and laughter can also open up new lines of inquiry because they are often indicative of a deep-seated or endemic problem; it is the truth that lies behind a joke that makes it funny. For example, if a team member laughingly makes a comment such as, “Management would never pay for this”, the Leader may want to probe more deeply. He may ask the person who made the joke what events in the past led him to that conclusion, and whether such an attitude is still justified.
Throw Away Remarks
Related to jokes and casual comments are throwaway remarks such as the following:
- We already tried that, and it didn’t work.
- It’s not our policy.
- It’s not in our budget.
- Use common sense
A good Leader will pick up on these remarks and try to determine what management problems that they are pointing toward.
A qualified leader will also relate to incidents that have occurred in the past and that bear some similarities to what he is observing now. Indeed, experienced leaders may even use the names of major incidents to summarize the state of a facility. For example, one leader once described a certain facility to another leader as containing “many little Flixboroughs.” Those three words told the second leader that Management of Change was a problem at the location in question.
An effective HAZOP Leader — as distinct from a Facilitator — possesses the following attributes:
- Able to see problems in terms of management systems.
- Able to pick up on body language and throw away comments that may point to fundamental causes; and
- Able to relate what he or she sees to the larger picture of incidents elsewhere.
You are welcome to use this Safety Moment in your workplace. But there are restrictions — please read Use of Safety Moments.
Copyright © Ian Sutton. 2018. All Rights Reserved.