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In Search of “Perfect Process Safety”
How to Ensure Sustainable Continuous Improvement


Learning from the M
L    i f      th Macondo D
                      d Deepwater H i
                              t Horizon Bl
                                        Blow O t
                                             Out
                  August 21, 2012          Runcorn, UK

             Steve Arendt, Vice President, P.E.
                 North America Process Industries
            Organizational Performance Assurance Center
                        sarendt@absconsulting.com




 Steve Arendt, P.E.
 30+ years in process safety and risk assessment
 Vice President, ABS Consulting, NA Process Sector and
 Organizational Performance Assurance Center
 ABSC project manager for the Baker Panel PSM reviews
 Conducted 100s of PSM audits, incident investigations, and best
 practice reviews, including 20+ offshore facilities
 60+ articles and books on PSM and risk management
    Guidelines for Risk-Based Process Safety
    Guidelines for Management of Change
    A Compliance Guide for EPA’s Risk Management Program Rule
    Manager's Guide to Quantitative Risk Assessment
    Resource Guide to the Process Safety Code of Management Practices
                                        y             g
    Guidelines for Hazard Evaluation Procedures, Second Edition
    A Manager's Guide to Implementing and Improving MOC Systems
    Risk Communication Guide, Chemical Educational Foundation
    ProSmart - CCPS PSM Performance Metrics System
 Center for Chemical Process Safety Fellow
 Recipient of Mary Kay O’Conner PSC Merit Award
 Center for Offshore Safety work group member
                                                                        2




                                                                            1
“Perfect Process Safety”

 What is it?
 Is it possible?
 What are the barriers?




                                                      3




A Vision For “Perfect Process Safety”
 A culture based on proper ownership of HSE
 Risk-informed sensitivity that g
                          y     guides everything
                                           y    g
 Effective, fit-for-purpose management systems
 PS practices embraced and followed with good
 operational discipline at ALL levels
 Learning from ALL sources – internal, external and
 outside industry group
 Well-formed/visible performance pyramid; metrics
 at every level that drive intended behaviors
 Goals and actual performance that improves
                                                      4




                                                          2
Compliance with Existing
         Regulations Is Not Enough
            Regulations provide minimum framework, but
            industry practices have bypassed regulations
                     Minimum standards may not be enough for all facilities
                     We have not really learned from our experience
            Minimalistic compliance approach does not lead to
            robust future performance
                     Fragility due to economic cycles
                     Culture challenges
                     Organizational stresses
                     Aging assets and changing people


                                                                                              5




The Problem with Some Companies…
They Are Taught a Lot of Lessons, But They Never Seem to Sustain Learning


                                              Accidents               They either don’t see
                                                                         y
                                                                      hazards below the
         Or they don’t                                                waterline
         know how to                          Incidents
         identify and fix
         root causes
                                             Precursors


                                    Management System Failures
                                        g       y
                                                                           Their “fixes”
                                                                           don’t stay fixed
                                   Unsafe Behaviors and Attitudes


                          Culture – Individual and Organizational Tendencies


© ABSG Consulting, Inc.
                                                                                              6




                                                                                                  3
Seems to Be Four Types of Companies

 In theory, requirements and enforcement practices
 should be matched to these various “needs”
                                     needs
   Know what to do and do a pretty good job
   Know what to do, but don't do a consistent job
   Know what to do and "intentionally" don't do a good job
   Don't really know what to do – ignorant or confused
 Difficult to make happen. Seems like we want “one
                   happen                       one
 paint brush” and the “same type of painter” no
 matter what the need


                                                             7




Learning from Experience
 Outside your industry
 Inside your industry
 Inside your company

 One BIG problem in industry is that we get taught
 the same lesson over and over, but don’t truly
 LEARN so that the problems don’t repeat
                   p                  p

 A critical skill is to find something relevant to learn
 and improve on out of EVERY significant incident


                                                             8




                                                                 4
Simple Lessons Baker Panel-CSB Reports
                     Panel-
 Ineffective PSM system with weak performance
 evaluation, corrective action, and corporate oversight
    Lack of follow-up in ALL areas
                    p
    Huge backlogs in inspections and corrective actions
    Not following consensus standards – nor their own
    Poor risk awareness and assessment
    Superficial audits
    Inadequate metrics
    Poor management review at local level
    Not focused on process safety at corporate level
 Inadequate corporate safety culture – had symptoms
 in every PS culture problem area
    Blind spots
    Arrogant
    Complacent
    Superficial
    Glacial, non-agile
    In denial
                                                                9




Macondo – Lessons and Potential Impacts
  Classes of root causes - plenty to go around
     Inadequate process safety culture for DH
       adequate p ocess sa ety cu tu e o
     Inadequate GOM operating environment culture
     Complex offshore operating environment
     Process safety management system failures
     Inadequate GOM regulatory environment
  Potential influences for onshore regulations
                                     g
     Enhanced reporting and third-party audits
     Prescriptive independent verification of safety critical
     elements
     QRA and safety case
                                                                10




                                                                     5
Lessons from Major Learning Sources
 Failure to execute – primary lesson
 We are not taking advantage of all “internal”
                                     internal
 sources of learning opportunities
    In the U.S., we have incomplete value generation from
    20 years of regulatory PSM incidents - inadequate
    collective analysis, trending, sharing, and learning
 Failure to learn from other types of industry
 accidents
 Will process safety leading indicators suffer the
 same fate?
 We have a culture challenge
                                                              11




 Six Characteristics of a Learning Organization
 (Harvard Professor David Garvin)

   Supports discussion and evaluation of divergent opinions
   and data
   Provides timely feedback and flexibility in the means
   used to conduct work activities
   Stimulates new ideas to promote a step change in risk
   understanding and operational performance
   Maintains an external focus by not automatically
   discounted outside ideas and ways
   Treats errors/mistakes as investments. Learns from
   them. Encourages proper risk-taking
   Routinely updates a learning plan to increase
   competencies
                                                              12




                                                                   6
Characteristics of a Learning-Disabled Company
(Steve Arendt, Armchair Process Safety Psychologist)

   Dysfunctional safety culture
      People hide things and kill messengers
           p           g                  g
      Fail to question; procedures not followed without
      accountability
      Mixed/improper safety/production messages
      Complacency, low trust, silo mentality
      Misplaced safety ownership, invisible/ineffective
      leadership
   Superficial causal analysis of problems
   Things don't get fixed
   No company memory
   Add in your own…
                                                          13




Characteristics of Good Risk Management
Necessary, but Not Sufficient for Perfect PS
   Pervasive understanding of what risk is
   Consistent practices driven using fit-for-purpose
                                    g
   HSE management system
   Life-cycle wide and enterprise deep risk visibility
   Flexible tool set and relevant data sources
   Competent practitioners
   Appropriate risk tolerance concepts/tools employed
   Effective risk reduction issue management
   Regular executive review of risk register top issues
   Risk ownership throughout the organization
                                                          14




                                                               7
Definition of the Perfect PS Leading Indicator
The Perfect Risk Model                         Or…a “Live Risk” Model
                                             Evaluates the risk impact of day-to-day
                                             facility changes and circumstances:
                                                 User d fi
                                                 U    defines equipment th t i f il d
                                                                  i     t that is failed,
                                                 disabled, degraded etc.
                                                 Operational adjustments
                                                 External circumstances
                                                 Evaluates the increase in risk from
                                                 these changes
                                             Requires input from risk models
                                             (HAZOPsHAZIDs, LOPAs, BTs,
                                             QRAs) into risk model
                       Operator identifies
                       equipment that is
                       failed or out of
                       service




                                                                  LIVERISK shows you the
                                                                  increase in risk due to the known
                                                                  equipment failures/outages or
                                                                  operational circumstances
                                                                                                      15




LIVERISK Features

Dashboards for
   Different levels within the organization (
                                 g          (facility, Business Unit,
                                                    y
   Corporate etc.)
   Different departments (production, safety, inspection etc.)
Accounts for the impact of changes in management systems
   Mechanical integrity: testing & maintenance programs; Project Quality
   Management (PQM), etc.
   Health, Safety and Environmental: results of HSE audits, Class
   surveys, etc.
   surveys etc
   Integrate HSE/process safety metrics (leading indicators)
   Integrate safety culture issues
   Others
Accounts for operational profile and external events
                                                                                                      16




                                                                                                           8
Improvements in Process Safety/HSE
                                  Technology
                                  and standards

                                                    HSE management           Culture
               ate


                                                    systems                  • Organizational and
Risk/Incident Ra



                                                                               individual behaviour
                                                                               aligned with goals
                      Standards
                                                                             • “Felt” leadership
                      •   Engineering improvements
                                                                             • Personal accountability
                      •   Hardware improvements
                                                                             • Shared purpose & belief
                      •   Design review
                      •   Compliance        Management Systems                     Improved
                                            • Integrated HSE MS                    culture
                                            • R
                                              Reporting
                                                    ti
                                            • Assurance
                                            • Competence
                                            • Risk Management

                                                      Time
                                                  Adapted from Kiel Centre                               17




     Overview of U.S. Industry Process Safety
     Performance Improvement Activities
                     Center for Chemical Process Safety
                          Risk Based Process Safety Guidelines emphasis on Learning from
                          Experience
                          Leading indicator work in late 90’s culminating in new PS metrics
                          guidelines
                          Member benchmarking project and Vision 2020
                     API
                          RP 754
                          API/AFPM Advancing Process Safety Initiative
                     Center for Offshore Safety
                     Lessons from industry accidents and investigations
                     Industry is refocusing attention and leadership
                     away from PSM compliance to PS Performance
                                                                                                         18




                                                                                                              9
Current PSM/HSE Auditing and RCA
Practices Don’t Go Far Enough
PSM/HSE audits generally issue findings and areas
for improvement “at the element level” even though
the evidence used may point to deeper problems
Incident investigations identify PSM elements as root
causes but don’t address safety culture factors
Use of PSM leading indicators are just becoming
broadly accepted, but their use for performance
management is in the “infant stage”
Plenty of learning opportunities; need to adjust our
learning and performance improvement approaches
                                                          19




Center for Chemical Process Safety
Made Culture an Official SMS Element
                        Evaluated major organizational
                        accidents and prepared Safety
                        Culture Awareness tool
                        ABSC included Process Safety
                        Culture as an element in CCPS
                        Guidelines for Risk Based
                        Process Safety
                        Defined the twelve essential
                        features of a good culture
                        Created structure for a culture
                        management practice


                                                          20




                                                               10
21




What Is Safety Culture?
Our Company and Individual DNA

 Cu tu e is t e te de cy in a o us – a d ou
 Culture s the tendency all of         and our
 organization - to want to do the right thing in the right
 way at the right time, ALL the time – even when/if no
 one is looking – ABS Group definition
 Culture is the result of all the actions - and inactions -
 in institutional/workforce memory
 Individual and organizational safety culture is affected
 by ethnic culture and off-the-job behavior
 Culture is hard to measure and more difficult to change;
 it will be the “root cause of the decade”

                                                              22




                                                                   11
To Address Unsafe Acts, Some Companies
Have Implemented BBS Programs
Industry experience has varied
   Worked for some; did not work for others
   Worked for a while, but then floundered
   Some have not tried it because of the resource commitment and
   negative feedback
Problems with BBS programs
   LTA management commitment; LTA resources
   Perceived to be a program for employees to “fix themselves”
                        p g            p y
   Management not viewed as a part of the problem/solution
   Lack of employee ownership
   Trivial/ineffective observations - quotas, improper reward systems,
   program gets stale, gets nit-picky
   Employees unable to provide/accept constructive peer feedback

                                                                         23




Organizational Accidents and Culture
 Challenger & Columbia
 Piper Alpha
 L    f d
 Longford
 Chernobyl
 Flixborough
 Texas City
 Macondo




                                                                         24




                                                                              12
Process Safety Culture – Essential Features

1.   Establish safety as a core     7.    Defer to expertise
     value
       l                            8.    Ensure open and effective
2.   Provide strong leadership            communications
3.   Establish and enforce high     9.    Establish a
     standards of performance             questioning/learning
                                          environment
4.   Formalize the safety culture
     emphasis/approach              10.   Foster mutual trust
5.   Maintain a sense of            11.   Provide timely response to
     vulnerability                        safety issues and concerns
6.   Empower individuals to         12.   Provide continuous
     successfully fulfill their           monitoring of performance
     safety responsibilities

                                                                       25




 1. HSE/Process Safety As a Core Value
     Deeply ingrained sense of value for HSE/safety
         At all levels of the organization
         Promoted to an ethical imperative in really strong
         cultures
     Awareness of responsibility to:
         Self
         Co-workers
         Company
         Society
     Individual and group intolerance of those in
     violation of the norm

                                                                       26




                                                                            13
2. Strong Leadership

 Visible, active, consistent support from all levels
 of company management
    Through communications, actions, priorities,
    provision of resources, etc.
 Committed to what is right
 Visionary and inspiring
 Open and honest
 Firm b t fl ibl
 Fi but flexible
 Alert and responsive to modify strategies to
 meet safety goals
 HSE/safety as line responsibility
                                                       27




3. Consistent Accountability to High
   Performance Standards

 Individual d
 I di id l and organizational
                       i ti     l
 Standards established, reinforced, and updated in
 a controlled fashion
 Consistency in accountability and transparency at
 all organizational strata – no “double standards”
 Avoidance of normalization of deviance
 Zero tolerance for willful violations of safety
 standards, rules, or procedures

                                                       28




                                                            14
4. Formalize a Culture Approach

Culture cannot be designed or manufactured, but ...
Document key principles or activities that support or
maintain its safety culture
Record basic safety tenants, such as in a company
policy or mission statement
Formalize a culture evaluation, monitoring, and
learning activities that are expected to be carried
out by someone or some group on a periodic basis



                                                           29




5. Sense of Vulnerability

  Preoccupation with failure
  Constant vigilance for indications of system
  weaknesses
    Attention to “weak signals”
  Avoidance of complacency
    “Past performance not a guarantee of future success”
  Avoidance of putting excessive reliance on
  safety systems
    Awareness of need for resilience (multiple lines of
    defense)
  Burden of proof for safety rather than "un-safety

                                                           30




                                                                15
6. Individual Empowerment

  Clear delegation of, and accountability for,
  responsibilities
  Provision of requisite authority and resources to
  staff to allow success in assigned roles
  Management expectation and tolerance of
  disparate opinions
  Personal responsibility for safety




                                                      31




7. Deference to Expertise

  High value placed upon training and
  development of individuals and groups
  Authority for decisions migrates to proper people
  based upon their knowledge and expertise
     Rather than rank or position
  Independent and unassailable role for safety
  experts
  Imperative for maintaining the “critical mass” of
  expertise required for safe operations


                                                      32




                                                           16
8. Open and Effective Communications

  Vertical communications (both up and down)
    Management hearing as well as speaking
  Horizontal communications
    All have the information they need to identify and
    respond to the unexpected
  Emphasis on observation and reporting
  Redundant and/or non traditional
                   non-traditional
  communications channels
  Monitoring of communications for effectiveness


                                                         33




9. Questioning/Learning Environment

  Enhancing risk awareness and understanding as
  means to continuous safety improvement
    Appropriate and timely hazard/risk assessments
    Thorough and timely incident investigations
    Looking beyond site or company for applicable
    learnings
  Reluctance to simplify interpretations or seek the
                   p y        p
  simple solutions




                                                         34




                                                              17
10. Mutual Trust

   Employees for managers
     Trust that managers will do the right thing in support
     of safety
   Managers for employees
     Trust that employees will shoulder their share of
     responsibility for safety performance
   Peers for peers
             p
   Confidence in a just system where honest errors
   can be reported without fear of reprisals


                                                              35




11. Responsiveness to Safety Concerns

   Awareness of safety as a dynamic non-event
   A “properly tuned controller”
      properly       controller
     Rapid, but not reckless, response to the unexpected
     in order to maintain the safety setpoint
   Timely response to implement learnings from
   audits and investigations
   Timely resolution of mismatches between
   practice and procedure t prevent normalization
        ti    d       d    to       t      li ti
   of deviance
   Timely reporting of, and response to, employee
   safety concerns

                                                              36




                                                                   18
12. Continuous Monitoring of
     Performance

   Curiosity/anxiety for ”How are we doing?
                          How        doing?”
   Sensitivity to operations
       Process
       Management system
       Interpersonal
   Pertinent, clear metrics addressing both leading
            ,                        g            g
   and lagging indicators
       Defined
       Created
       Tracked

                                                                 37




Examples of Culture Influencing Events

   A co-worker does not object when an operator writes an
   “armchair permit”
   Supervisors consistently support workers who shut down a
   process they believe to be unsafe – even if they were
   wrong
   An operations manager extends a unit shutdown to await
   definitive evidence that a thin-walled vessel is safe to
   operate
   A plant manager does not wear appropriate PPE when
   walking to the control room to eat lunch with a unit crew
   A corporate EHS Director persists in her efforts to justify
   staffing resource commitments to support process safety
   in spite of company cost-cutting edicts
   Red = Negative   Green = Positive
                                                                 38




                                                                      19
Examples of Culture Influencing Events

    A VP pressures the plant manager to defer the plant
    turnaround through the busy season
    A company SVP focuses on problem solving rather than
    affixing blame during a management review of a serious
    incident investigation
    A company Director eliminates corporate engineering
    and process safety staff positions without any
    management of organizational change
    A CEO makes an acquisition without addressing
    EHS/process safety in due diligence reviews
    A Board subcommittee spends significant time reviewing
    EHS/process safety performance metrics and questions
    the company’s 3rd-quartile performance
    Red = Negative        Green = Positive
                                                                                       39




Connecting the Dots – Process Safety
Performance Assurance Review (PAR)© Strategy
                                              Process Safety/ESH Culture
Mapping of ESH Technical                          Evaluation Sources
Performance and Culture                                                   PSM/EHS
                                             Surveys and   Work
Evidence to Process                          interviews    observations   leading
                                                                          indicators
Safety Culture Factors


                     Incidents and
                     investigation
Process              results                 Process Safety/ESH Culture
Safety/ESH
Performance          Audits and
                                                     Essential Features
Information          assessments                      Causal Factors
Sources              Action item                    Tenets of Operation
                     completion
                     history



                                                                                       40




                                                                                            20
PAR Process Safety Performance vs. Culture Map
                                        Culture survey results and other sources
                                        are sorted into the 12 essential features




   Analysis of all process safety
   performance data (e.g., audit actions)
   is sorted into the 12 essential features
                                                                                    41




Ranking of Cultural Causal Factors Present – Summary
of Study Results


   Cultural Causal Factor – Decreasing Frequency
1. Normalization of deviance
2. Non-responsiveness to safety concerns
3. Lack of a questioning/learning environment
4. No performance monitoring/pursuit of
   improvement
5. Lack of sense of vulnerability
6. Lack of trust – unsafe reporting environment


                                                                                    42




                                                                                         21
How to Change PS/HSE Culture
  Embracing the idea that YOU affect culture
  Understanding potential root causes
  Determining ways to improve culture weaknesses
  Follow-thru throughout an organization




                                                    43




How Leaders Influence Beliefs/Values

  What leaders pay attention to, measure, or
  control
  Reactions to critical incidents or crisis
  Criteria used to allocate scarce resources
  Deliberate attempts at role modeling, teaching,
  and coaching
  Criteria for reinforcement and discipline
  Criteria used to select, promote, or terminate
  employees

                                                    44




                                                         22
Small Group/Individual Mentoring and Coaching

Workshops and role play
   Examples of accidents that occurred due to safety culture problems
   CCPS 12 essential features of a good safety culture
   Taking personal responsibility for evolving your Process Safety and
   Occupational Safety (Total Safety) behavior and culture
   Understanding potential historical root causes for culture problems
   Soliciting ideas for improving culture
   Decide which culture elements you are going to address
   Decide who in management is needed to support your efforts
   Develop a plan for the next month, the next six months, the next
   year, and the next three years
   Determine what metrics will be used to monitor progress


                                                                         45




Some Culture Improvement Lessons
If you have poor culture, marked by mistrust or
needs large improvement, the worst thing y can
          g      p           ,                g you
do is too just start “talking” about it at the top
The “top” needs to first start “behaving” better to
address culture weaknesses
Then, the talk will build up from the bottom
If you survey, do it anonymous and voluntary; you
       survey
should commit to sharing the results – quickly
Any education/training, etc. should extend to ALL of
the workforce, including contractors
BUILD OWNERSHIP
                                                                         46




                                                                              23
Sense, Learn, and Fix at Every Level

                                 Put sensors, not censors, at every level




                                    Develop learnings at every level




                                    Take corrective action at every level




                                                                       47




 Strategy for Process Safety
 Performance Management
   Monitor PSM health
   For ALL PS learning opportunities:
      Evaluate PSM failure modes
      Determine PSM failure culture causal factors
      Ensure sustainable PSM/HSE performance
      improvement
   Avoid organizational warning signs
   Embrace critical success factors for PSM


                                                                       48




                                                                            24
Evaluating PSM Element Failure Modes
  Determine basic element steps
    Review element written program
    Identify life-cycle activities completed and current
    status
     •   Design and development
     •   Implementation and rollout
     •   Operation
     •   Monitoring and improvement
    Develop workflow diagram of element work process
    Review relevant incident root causes for element
    Review relevant element metrics - leading and
    lagging indicators
                                                                     49




Evaluating PSM Element Failure Modes
    Review previous two audit cycle results for element
    Assign incident, root causes, audit findings and
    observations, and metrics indicator performance to:
     • Life cycle phase during which the element performance issue
       occurred
     • Workflow process point where element breakdown occurred
  Highlight element life-cycle phase where
  performance issues are greatest
  Highlight work process point where most
  element performance issues have occurred


                                                                     50




                                                                          25
Evaluating PSM Element Failure Modes
 Determine corrective and preventive actions to
 reduce chance of element performance failure
                           p
 occurring again
   Implement/redo life-cycle phase in a more reliable fashion
   Improve element work process design
   Create better leading indicators to monitor element
   performance area
   Improve use of existing relevant metrics to monitor
   element performance
   Increase management review scrutiny on element
   performance area
 All of this may not be enough
                                                            51




 Evaluating PSM Element Failure
 Culture Causal Factors

  Map element performance issues to cultural
  features
  Compare performance to known culture
  weaknesses
  Identify which culture features appear to be
  contributing to element performance lapses




                                                            52




                                                                 26
Ensuring Sustainable PSM/HSE
  Performance Improvement

      Make technical corrections to PSM element
      performance
      Implement culture improvement activities to
      address culture weaknesses
      Monitor culture change and improvement




                                                                     53




  Guidelines for
  Management of Change for Process Safety
    Recognize
    Classify
    Evaluate hazards and risks
    Approve (or not) or modify
    Get ready for the change
       Communicate/train
       Update documentation
    200 pages. April 2008, US $95
    ISBN: 978-0-470-04309-7
http://www.wiley.com/WileyCDA/WileyTitle/productCd-0470043091.html



                                                                     54




                                                                          27
MOC Program Life-Cycle Phases
   Design and development
   Implementation and rollout
   Operation
   Monitoring and improvement




                                                             55




MOC System Design/Development Failure Modes

   Inadequate workforce involvement
   Inadequate design basis - wrong change types
                                            types,
   inadequate review/authorization protocols
   MOC use rate not considered when establishing MOC
   resources
   Inadequate MOC resources designated
   MOC protocol complexity inappropriate for change types,
   resources, or workforce culture
   MOC system roles and responsibilities inadequate
   Scope of application of MOC program inadequate


                                                             56




                                                                  28
MOC System Rollout Failure Modes

  Inadequate workforce involvement
  Inadequate awareness training of workforce
                                    workforce,
  including contractors
  Inadequate detailed training of MOC system
  participants
  Insufficient MOC system tools/forms/resources
  provided
  Insufficient pilot-testing



                                                           57




MOC System Operation Failure Modes
Failure to identify a proposed change - system circumvented
Change classified as an emergency change when it did not
meet established criteria
Mistakenly included a RIK in the MOC review process
Proposed change improperly classified - type or review path
MOC origination information inadequate
MOC initial review not completed or inadequate
Inadequate MOC reviewers
Wrong MOC review method used
MOC hazard review path step missed, out of order, incomplete
MOC hazard evaluation inadequate - hazards missed or risks
improperly evaluated

                                                           58




                                                                29
MOC System Operation Failure Modes
Emergency MOC review procedure not finished
MOC authorization inadequate - wrong, missing or risks
accepted are inappropriate
PSI not updated based upon change
Personnel not informed of change
Personnel not trained on change
Wrong communication or training provided to personnel
Temporary change left in place too long without further review
Failure to restore system to original condition after a
temporary change
MOC review records inadequate or missing
MOC delayed or lost in the system
                                                             59




MOC System Monitoring Failure Modes

 MOC metrics not properly developed or used
 Inadequate management review/oversight of
 MOC system
 MOC not addressed sufficiently in PSM audit




                                                             60




                                                                  30
Top MOC Operating Phase Failure Modes % of MOC
                                            Issues
   Failure to identify a proposed change
                                             61 %
   - system circumvented
   Temporary change left in place too        43 %
   long without further review or failure
   to restore system to original
   Personnel not informed of change g        35 %
   MOC delayed or lost in the system         23 %
   MOC hazard evaluation inadequate -
   hazards missed or risks improperly        18 %
   evaluated
                                                     61




  MOC Failure Example –
  Offshore Gas Compressor Module




                                                     62




                                                          31
Unrecognized Change Led to Release




  Original position     Modified position




                                              63




Gas Release Resulted in a “Lucky Explosion”




                                              64




                                                   32
Company PS Metrics Related to Incident

     Number of open MOCs
     MOC action item aging
     Process piping inspection aging

     None of these metrics addressed monitoring
     the technical performance aspects of MOC
     that
     th t contributed to the incident
             t ib t d t th i id t




                                                                            65




Top MOC Cultural Causal Factors

1.   Establish process safety as a       7.    Defer to expertise
     core value
            l                            8.    Ensure open and effective
2.   Provide strong leadership                 communications
3.   Establish and enforce high          9.    Establish a
     standards of performance                  questioning/learning
                                               environment
4.   Formalize the process safety
     culture emphasis/approach           10.   Foster mutual trust
5.   Maintain a sense of                 11.   Provide timely response to
     vulnerability                             safety issues and concerns
6.   Empower individuals to              12.   Provide continuous
     successfully fulfill their safety         monitoring of performance
     responsibilities

                                                                            66




                                                                                 33
MOC Failure Was a Root Cause

 Several MOC failures occurred
   Development – failure to account for change type
   Rollout – precursors occurred during period
   Operation – failure to recognize, failure to evaluate
 Several safety culture issues were uncovered
 that contributed to the MOC system failures
   Lack of a sense of vulnerability
   Failure to empower individuals
   Lack of a questioning/learning environment
   Normalization of deviance

                                                           67




Conclusions from Example
 MOC is a critical PSM element
 MOC performance management (audits) often
 don't provide sufficient improvement information
 We must examine MOC failure modes to support
 continuous improvement
 MOC failure prevention must consider "life-cycle
 improvements
 Culture and behavior issues MUST be addressed
 for sustainable improvement
 Leading indicators supported by frequent
 management review are needed
                                                           68




                                                                34
Strategy for Process Safety
 Performance Management

  Evaluating PSM failure modes
  Determining PSM failure culture causal factors
  Ensuring sustainable PSM/HSE performance
  improvement
  Avoiding organizational warning signs
  Critical success factors for PSM




                                                   69




How Does a Company Tell If It Is:
  In a process safety ditch
  On th d
  O the edge of a ditch
                 f dit h
  Getting closer to a ditch
  Moving away from a ditch
  Maintaining proper distance from a ditch

   AVOID loss of visibility or fidelity in
performance evidence sources – maintain
  a well-shaped and complete pyramid
                                                   70




                                                        35
Example of a Faulty Pyramid

                    Accidents


                     Incidents


                    Precursors


          Management System Failures


          Unsafe Behaviors and Attitudes


  Culture – Individual and Organizational Tendencies


                                                                       71




                            Recognizing Catastrophic
                            Incident Warning Signs in
                            the Process Industries

                            ISBN: 978-0-470-76774-0
                            264 pp
                            December 2011
                            US $125.00
                               $125 00
                            http://www.wiley.com/WileyCDA/WileyTitle/pro
                            ductCd-047076774X.html




                                                                       72




                                                                            36
Monitor Warning Signs – Company
           Organizational change/stress without sufficient HSE
           impact evaluation and mitigation
             p                       g
                     External-induced
                      • Regulations, enforcement, economics, disasters, M&A
                        target, etc.
                     Internal-induced
                      • Competency, memory, resources, focus loss, initiative
                        overload, M&A,
                        overload M&A leadership instability demographics
                                                    instability,
                        shift, turnover, absenteeism
           Loss of visibility/fidelity in performance evidence
           sources – maintain a good pyramid
                     Poor reporting, trending, sharing, monitoring
                                                                                                73




         Metrics Layered within the Pyramid

                                 # of PS incidents                         Accidents

                                 # of first aids
                                    f fi t id
                                 Severity rate                             Incidents

                          Number of Near Misses Reported
                                                                          Precursors
                          HSE/PSM audit score
                          Number of Overdue Action Items
                          Corrective Actions Generated               Management System
                          Safety Meeting Attendance, %
                          Training Completed, %
                                                                          Failures

                          RC Contacts
                          Safety Inspections Completed, %      Unsafe Behaviors and Attitudes
                          BBS at-risk observations

                                 Trend incident and                Culture – Individual and
                                management system                 Organizational Tendencies
                               technical and cultural
                              root causes as learning       Conceive of cultural
                                opportunities occur         weakness metrics to
                                                              collect across
© ABSG Consulting, Inc.                                         company                         74




                                                                                                     37
Process Safety Metrics – Arendt Suggestions
1. Process Safety incidents – ANSI/API RP 754 Tiers 1 and 2
2.
2 Process Safety incident precursors – RP 754 Tier 3
3. Failure to follow procedures/SWPs – BBS at-risk
   observation rate
4. Failure to fix identified process safety problems – action
   item backlogs or aging, equipment deficiencies backlogs
5. Failure to identify process safety deficiencies– inspection
   (all sources) backlog, failure to identify/report incidents or
   do adequate RCA
6. Failure to assess risk– MOC circumvention or low quality,
   PHA schedule backlog, PHA quality review
7. Safety culture weaknesses – Map RCs of incidents to
   cultural causal factors

                                                                    75




 Emerging Challenges with PS Metrics
   Don’t pick too many
   Make sure they roll up properly
   Make sure they add value
   Don’t just pick things you can measure; make
   certain they affect accident risk
   Think through how you will use them; anticipate
   unintended behaviors
   Make them visible – positive culture influence


                                                                    76




                                                                         38
Characteristics of Good Process
Safety Companies
Not blind or arrogant – willing to look into the mirror
Safe questioning/learning environment
Proper safety ownership and leadership
Effective, fit-for-purpose management systems
Disciplined in execution - low/decreasing backlogs
Effective action - prevention not just correction
                    prevention,
   Action at multiple levels of the pyramid
   Builds better ownership and fosters a better culture


                                                          77




Characteristics of Good Process
Safety Companies (cont’d)
Learns lessons cheaply taught from all sources -
                      py     g
avoids repeat teaching
Pursues effective continuous improvement – seeks
out better practices
High quality incident investigations
Proper process safety metrics and discerning
audits
Effective management review


                                                          78




                                                               39
Keys to Future Process Safety Success
 To pursue zero or perfect PS – you’ve got to change the
 ways you are doing some things that served you okay to
 get you to where you are at
 Fit-for-purpose PSM/HSE system that is well-executed
 Nurture culture and operating discipline
 Create an effective learning organization
    Apply root cause thinking to everything
    Maintain an effective corrective action process
    High quality incident investigations
    Proper process safety metrics
    Discerning audits
    Effective management review


                                                           79




Teaching, Learning, and Remembering

 Go back to your plant, company, or organization
 and pick a notable incident and find out:
    What was done to keep it from happening again
    Do people remember it and the lessons
    What have you done to embed it in your "lore"
    What effective approaches still exist to prevent it
    What do you have to protect against PS Alzheimers
 Pick a notable event from another company or
 industry - and do the same
 Go up your chain-of-command and see how far
 the “remembering” goes
                                                           80




                                                                40
“Perfect Process Safety”

   Is a worthy and valuable goal
   Can only be pursued by highly reliable
   organizations that embody effective learning
   patterns
   Sustainable process safety does not allow
   learning to evaporate or “retire”
   Should be the stretch goal for all companies and
   organizations



                                                      81




Swiss Cheese Model for Accident Causation




                                                      82




                                                           41
Time for Questions




                     sponsored by




In Search of “Perfect Process Safety”
How to Ensure Sustainable Continuous Improvement


Learning from the M
L    i f      th Macondo D
                      d Deepwater H i
                              t Horizon Bl
                                        Blow O t
                                             Out
             August 21, 2012      Runcorn, UK

         Steve Arendt, Vice President, P.E.
              North America Process Industries
         Organizational Performance Assurance Center
                  sarendt@absconsulting.com




                                                       42

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My Hashitalk Indonesia April 2024 Presentation
 

Steve Arendt runcorn uk presentation 8 21-12 final

  • 1. sponsored by In Search of “Perfect Process Safety” How to Ensure Sustainable Continuous Improvement Learning from the M L i f th Macondo D d Deepwater H i t Horizon Bl Blow O t Out August 21, 2012 Runcorn, UK Steve Arendt, Vice President, P.E. North America Process Industries Organizational Performance Assurance Center sarendt@absconsulting.com Steve Arendt, P.E. 30+ years in process safety and risk assessment Vice President, ABS Consulting, NA Process Sector and Organizational Performance Assurance Center ABSC project manager for the Baker Panel PSM reviews Conducted 100s of PSM audits, incident investigations, and best practice reviews, including 20+ offshore facilities 60+ articles and books on PSM and risk management Guidelines for Risk-Based Process Safety Guidelines for Management of Change A Compliance Guide for EPA’s Risk Management Program Rule Manager's Guide to Quantitative Risk Assessment Resource Guide to the Process Safety Code of Management Practices y g Guidelines for Hazard Evaluation Procedures, Second Edition A Manager's Guide to Implementing and Improving MOC Systems Risk Communication Guide, Chemical Educational Foundation ProSmart - CCPS PSM Performance Metrics System Center for Chemical Process Safety Fellow Recipient of Mary Kay O’Conner PSC Merit Award Center for Offshore Safety work group member 2 1
  • 2. “Perfect Process Safety” What is it? Is it possible? What are the barriers? 3 A Vision For “Perfect Process Safety” A culture based on proper ownership of HSE Risk-informed sensitivity that g y guides everything y g Effective, fit-for-purpose management systems PS practices embraced and followed with good operational discipline at ALL levels Learning from ALL sources – internal, external and outside industry group Well-formed/visible performance pyramid; metrics at every level that drive intended behaviors Goals and actual performance that improves 4 2
  • 3. Compliance with Existing Regulations Is Not Enough Regulations provide minimum framework, but industry practices have bypassed regulations Minimum standards may not be enough for all facilities We have not really learned from our experience Minimalistic compliance approach does not lead to robust future performance Fragility due to economic cycles Culture challenges Organizational stresses Aging assets and changing people 5 The Problem with Some Companies… They Are Taught a Lot of Lessons, But They Never Seem to Sustain Learning Accidents They either don’t see y hazards below the Or they don’t waterline know how to Incidents identify and fix root causes Precursors Management System Failures g y Their “fixes” don’t stay fixed Unsafe Behaviors and Attitudes Culture – Individual and Organizational Tendencies © ABSG Consulting, Inc. 6 3
  • 4. Seems to Be Four Types of Companies In theory, requirements and enforcement practices should be matched to these various “needs” needs Know what to do and do a pretty good job Know what to do, but don't do a consistent job Know what to do and "intentionally" don't do a good job Don't really know what to do – ignorant or confused Difficult to make happen. Seems like we want “one happen one paint brush” and the “same type of painter” no matter what the need 7 Learning from Experience Outside your industry Inside your industry Inside your company One BIG problem in industry is that we get taught the same lesson over and over, but don’t truly LEARN so that the problems don’t repeat p p A critical skill is to find something relevant to learn and improve on out of EVERY significant incident 8 4
  • 5. Simple Lessons Baker Panel-CSB Reports Panel- Ineffective PSM system with weak performance evaluation, corrective action, and corporate oversight Lack of follow-up in ALL areas p Huge backlogs in inspections and corrective actions Not following consensus standards – nor their own Poor risk awareness and assessment Superficial audits Inadequate metrics Poor management review at local level Not focused on process safety at corporate level Inadequate corporate safety culture – had symptoms in every PS culture problem area Blind spots Arrogant Complacent Superficial Glacial, non-agile In denial 9 Macondo – Lessons and Potential Impacts Classes of root causes - plenty to go around Inadequate process safety culture for DH adequate p ocess sa ety cu tu e o Inadequate GOM operating environment culture Complex offshore operating environment Process safety management system failures Inadequate GOM regulatory environment Potential influences for onshore regulations g Enhanced reporting and third-party audits Prescriptive independent verification of safety critical elements QRA and safety case 10 5
  • 6. Lessons from Major Learning Sources Failure to execute – primary lesson We are not taking advantage of all “internal” internal sources of learning opportunities In the U.S., we have incomplete value generation from 20 years of regulatory PSM incidents - inadequate collective analysis, trending, sharing, and learning Failure to learn from other types of industry accidents Will process safety leading indicators suffer the same fate? We have a culture challenge 11 Six Characteristics of a Learning Organization (Harvard Professor David Garvin) Supports discussion and evaluation of divergent opinions and data Provides timely feedback and flexibility in the means used to conduct work activities Stimulates new ideas to promote a step change in risk understanding and operational performance Maintains an external focus by not automatically discounted outside ideas and ways Treats errors/mistakes as investments. Learns from them. Encourages proper risk-taking Routinely updates a learning plan to increase competencies 12 6
  • 7. Characteristics of a Learning-Disabled Company (Steve Arendt, Armchair Process Safety Psychologist) Dysfunctional safety culture People hide things and kill messengers p g g Fail to question; procedures not followed without accountability Mixed/improper safety/production messages Complacency, low trust, silo mentality Misplaced safety ownership, invisible/ineffective leadership Superficial causal analysis of problems Things don't get fixed No company memory Add in your own… 13 Characteristics of Good Risk Management Necessary, but Not Sufficient for Perfect PS Pervasive understanding of what risk is Consistent practices driven using fit-for-purpose g HSE management system Life-cycle wide and enterprise deep risk visibility Flexible tool set and relevant data sources Competent practitioners Appropriate risk tolerance concepts/tools employed Effective risk reduction issue management Regular executive review of risk register top issues Risk ownership throughout the organization 14 7
  • 8. Definition of the Perfect PS Leading Indicator The Perfect Risk Model Or…a “Live Risk” Model Evaluates the risk impact of day-to-day facility changes and circumstances: User d fi U defines equipment th t i f il d i t that is failed, disabled, degraded etc. Operational adjustments External circumstances Evaluates the increase in risk from these changes Requires input from risk models (HAZOPsHAZIDs, LOPAs, BTs, QRAs) into risk model Operator identifies equipment that is failed or out of service LIVERISK shows you the increase in risk due to the known equipment failures/outages or operational circumstances 15 LIVERISK Features Dashboards for Different levels within the organization ( g (facility, Business Unit, y Corporate etc.) Different departments (production, safety, inspection etc.) Accounts for the impact of changes in management systems Mechanical integrity: testing & maintenance programs; Project Quality Management (PQM), etc. Health, Safety and Environmental: results of HSE audits, Class surveys, etc. surveys etc Integrate HSE/process safety metrics (leading indicators) Integrate safety culture issues Others Accounts for operational profile and external events 16 8
  • 9. Improvements in Process Safety/HSE Technology and standards HSE management Culture ate systems • Organizational and Risk/Incident Ra individual behaviour aligned with goals Standards • “Felt” leadership • Engineering improvements • Personal accountability • Hardware improvements • Shared purpose & belief • Design review • Compliance Management Systems Improved • Integrated HSE MS culture • R Reporting ti • Assurance • Competence • Risk Management Time Adapted from Kiel Centre 17 Overview of U.S. Industry Process Safety Performance Improvement Activities Center for Chemical Process Safety Risk Based Process Safety Guidelines emphasis on Learning from Experience Leading indicator work in late 90’s culminating in new PS metrics guidelines Member benchmarking project and Vision 2020 API RP 754 API/AFPM Advancing Process Safety Initiative Center for Offshore Safety Lessons from industry accidents and investigations Industry is refocusing attention and leadership away from PSM compliance to PS Performance 18 9
  • 10. Current PSM/HSE Auditing and RCA Practices Don’t Go Far Enough PSM/HSE audits generally issue findings and areas for improvement “at the element level” even though the evidence used may point to deeper problems Incident investigations identify PSM elements as root causes but don’t address safety culture factors Use of PSM leading indicators are just becoming broadly accepted, but their use for performance management is in the “infant stage” Plenty of learning opportunities; need to adjust our learning and performance improvement approaches 19 Center for Chemical Process Safety Made Culture an Official SMS Element Evaluated major organizational accidents and prepared Safety Culture Awareness tool ABSC included Process Safety Culture as an element in CCPS Guidelines for Risk Based Process Safety Defined the twelve essential features of a good culture Created structure for a culture management practice 20 10
  • 11. 21 What Is Safety Culture? Our Company and Individual DNA Cu tu e is t e te de cy in a o us – a d ou Culture s the tendency all of and our organization - to want to do the right thing in the right way at the right time, ALL the time – even when/if no one is looking – ABS Group definition Culture is the result of all the actions - and inactions - in institutional/workforce memory Individual and organizational safety culture is affected by ethnic culture and off-the-job behavior Culture is hard to measure and more difficult to change; it will be the “root cause of the decade” 22 11
  • 12. To Address Unsafe Acts, Some Companies Have Implemented BBS Programs Industry experience has varied Worked for some; did not work for others Worked for a while, but then floundered Some have not tried it because of the resource commitment and negative feedback Problems with BBS programs LTA management commitment; LTA resources Perceived to be a program for employees to “fix themselves” p g p y Management not viewed as a part of the problem/solution Lack of employee ownership Trivial/ineffective observations - quotas, improper reward systems, program gets stale, gets nit-picky Employees unable to provide/accept constructive peer feedback 23 Organizational Accidents and Culture Challenger & Columbia Piper Alpha L f d Longford Chernobyl Flixborough Texas City Macondo 24 12
  • 13. Process Safety Culture – Essential Features 1. Establish safety as a core 7. Defer to expertise value l 8. Ensure open and effective 2. Provide strong leadership communications 3. Establish and enforce high 9. Establish a standards of performance questioning/learning environment 4. Formalize the safety culture emphasis/approach 10. Foster mutual trust 5. Maintain a sense of 11. Provide timely response to vulnerability safety issues and concerns 6. Empower individuals to 12. Provide continuous successfully fulfill their monitoring of performance safety responsibilities 25 1. HSE/Process Safety As a Core Value Deeply ingrained sense of value for HSE/safety At all levels of the organization Promoted to an ethical imperative in really strong cultures Awareness of responsibility to: Self Co-workers Company Society Individual and group intolerance of those in violation of the norm 26 13
  • 14. 2. Strong Leadership Visible, active, consistent support from all levels of company management Through communications, actions, priorities, provision of resources, etc. Committed to what is right Visionary and inspiring Open and honest Firm b t fl ibl Fi but flexible Alert and responsive to modify strategies to meet safety goals HSE/safety as line responsibility 27 3. Consistent Accountability to High Performance Standards Individual d I di id l and organizational i ti l Standards established, reinforced, and updated in a controlled fashion Consistency in accountability and transparency at all organizational strata – no “double standards” Avoidance of normalization of deviance Zero tolerance for willful violations of safety standards, rules, or procedures 28 14
  • 15. 4. Formalize a Culture Approach Culture cannot be designed or manufactured, but ... Document key principles or activities that support or maintain its safety culture Record basic safety tenants, such as in a company policy or mission statement Formalize a culture evaluation, monitoring, and learning activities that are expected to be carried out by someone or some group on a periodic basis 29 5. Sense of Vulnerability Preoccupation with failure Constant vigilance for indications of system weaknesses Attention to “weak signals” Avoidance of complacency “Past performance not a guarantee of future success” Avoidance of putting excessive reliance on safety systems Awareness of need for resilience (multiple lines of defense) Burden of proof for safety rather than "un-safety 30 15
  • 16. 6. Individual Empowerment Clear delegation of, and accountability for, responsibilities Provision of requisite authority and resources to staff to allow success in assigned roles Management expectation and tolerance of disparate opinions Personal responsibility for safety 31 7. Deference to Expertise High value placed upon training and development of individuals and groups Authority for decisions migrates to proper people based upon their knowledge and expertise Rather than rank or position Independent and unassailable role for safety experts Imperative for maintaining the “critical mass” of expertise required for safe operations 32 16
  • 17. 8. Open and Effective Communications Vertical communications (both up and down) Management hearing as well as speaking Horizontal communications All have the information they need to identify and respond to the unexpected Emphasis on observation and reporting Redundant and/or non traditional non-traditional communications channels Monitoring of communications for effectiveness 33 9. Questioning/Learning Environment Enhancing risk awareness and understanding as means to continuous safety improvement Appropriate and timely hazard/risk assessments Thorough and timely incident investigations Looking beyond site or company for applicable learnings Reluctance to simplify interpretations or seek the p y p simple solutions 34 17
  • 18. 10. Mutual Trust Employees for managers Trust that managers will do the right thing in support of safety Managers for employees Trust that employees will shoulder their share of responsibility for safety performance Peers for peers p Confidence in a just system where honest errors can be reported without fear of reprisals 35 11. Responsiveness to Safety Concerns Awareness of safety as a dynamic non-event A “properly tuned controller” properly controller Rapid, but not reckless, response to the unexpected in order to maintain the safety setpoint Timely response to implement learnings from audits and investigations Timely resolution of mismatches between practice and procedure t prevent normalization ti d d to t li ti of deviance Timely reporting of, and response to, employee safety concerns 36 18
  • 19. 12. Continuous Monitoring of Performance Curiosity/anxiety for ”How are we doing? How doing?” Sensitivity to operations Process Management system Interpersonal Pertinent, clear metrics addressing both leading , g g and lagging indicators Defined Created Tracked 37 Examples of Culture Influencing Events A co-worker does not object when an operator writes an “armchair permit” Supervisors consistently support workers who shut down a process they believe to be unsafe – even if they were wrong An operations manager extends a unit shutdown to await definitive evidence that a thin-walled vessel is safe to operate A plant manager does not wear appropriate PPE when walking to the control room to eat lunch with a unit crew A corporate EHS Director persists in her efforts to justify staffing resource commitments to support process safety in spite of company cost-cutting edicts Red = Negative Green = Positive 38 19
  • 20. Examples of Culture Influencing Events A VP pressures the plant manager to defer the plant turnaround through the busy season A company SVP focuses on problem solving rather than affixing blame during a management review of a serious incident investigation A company Director eliminates corporate engineering and process safety staff positions without any management of organizational change A CEO makes an acquisition without addressing EHS/process safety in due diligence reviews A Board subcommittee spends significant time reviewing EHS/process safety performance metrics and questions the company’s 3rd-quartile performance Red = Negative Green = Positive 39 Connecting the Dots – Process Safety Performance Assurance Review (PAR)© Strategy Process Safety/ESH Culture Mapping of ESH Technical Evaluation Sources Performance and Culture PSM/EHS Surveys and Work Evidence to Process interviews observations leading indicators Safety Culture Factors Incidents and investigation Process results Process Safety/ESH Culture Safety/ESH Performance Audits and Essential Features Information assessments Causal Factors Sources Action item Tenets of Operation completion history 40 20
  • 21. PAR Process Safety Performance vs. Culture Map Culture survey results and other sources are sorted into the 12 essential features Analysis of all process safety performance data (e.g., audit actions) is sorted into the 12 essential features 41 Ranking of Cultural Causal Factors Present – Summary of Study Results Cultural Causal Factor – Decreasing Frequency 1. Normalization of deviance 2. Non-responsiveness to safety concerns 3. Lack of a questioning/learning environment 4. No performance monitoring/pursuit of improvement 5. Lack of sense of vulnerability 6. Lack of trust – unsafe reporting environment 42 21
  • 22. How to Change PS/HSE Culture Embracing the idea that YOU affect culture Understanding potential root causes Determining ways to improve culture weaknesses Follow-thru throughout an organization 43 How Leaders Influence Beliefs/Values What leaders pay attention to, measure, or control Reactions to critical incidents or crisis Criteria used to allocate scarce resources Deliberate attempts at role modeling, teaching, and coaching Criteria for reinforcement and discipline Criteria used to select, promote, or terminate employees 44 22
  • 23. Small Group/Individual Mentoring and Coaching Workshops and role play Examples of accidents that occurred due to safety culture problems CCPS 12 essential features of a good safety culture Taking personal responsibility for evolving your Process Safety and Occupational Safety (Total Safety) behavior and culture Understanding potential historical root causes for culture problems Soliciting ideas for improving culture Decide which culture elements you are going to address Decide who in management is needed to support your efforts Develop a plan for the next month, the next six months, the next year, and the next three years Determine what metrics will be used to monitor progress 45 Some Culture Improvement Lessons If you have poor culture, marked by mistrust or needs large improvement, the worst thing y can g p , g you do is too just start “talking” about it at the top The “top” needs to first start “behaving” better to address culture weaknesses Then, the talk will build up from the bottom If you survey, do it anonymous and voluntary; you survey should commit to sharing the results – quickly Any education/training, etc. should extend to ALL of the workforce, including contractors BUILD OWNERSHIP 46 23
  • 24. Sense, Learn, and Fix at Every Level Put sensors, not censors, at every level Develop learnings at every level Take corrective action at every level 47 Strategy for Process Safety Performance Management Monitor PSM health For ALL PS learning opportunities: Evaluate PSM failure modes Determine PSM failure culture causal factors Ensure sustainable PSM/HSE performance improvement Avoid organizational warning signs Embrace critical success factors for PSM 48 24
  • 25. Evaluating PSM Element Failure Modes Determine basic element steps Review element written program Identify life-cycle activities completed and current status • Design and development • Implementation and rollout • Operation • Monitoring and improvement Develop workflow diagram of element work process Review relevant incident root causes for element Review relevant element metrics - leading and lagging indicators 49 Evaluating PSM Element Failure Modes Review previous two audit cycle results for element Assign incident, root causes, audit findings and observations, and metrics indicator performance to: • Life cycle phase during which the element performance issue occurred • Workflow process point where element breakdown occurred Highlight element life-cycle phase where performance issues are greatest Highlight work process point where most element performance issues have occurred 50 25
  • 26. Evaluating PSM Element Failure Modes Determine corrective and preventive actions to reduce chance of element performance failure p occurring again Implement/redo life-cycle phase in a more reliable fashion Improve element work process design Create better leading indicators to monitor element performance area Improve use of existing relevant metrics to monitor element performance Increase management review scrutiny on element performance area All of this may not be enough 51 Evaluating PSM Element Failure Culture Causal Factors Map element performance issues to cultural features Compare performance to known culture weaknesses Identify which culture features appear to be contributing to element performance lapses 52 26
  • 27. Ensuring Sustainable PSM/HSE Performance Improvement Make technical corrections to PSM element performance Implement culture improvement activities to address culture weaknesses Monitor culture change and improvement 53 Guidelines for Management of Change for Process Safety Recognize Classify Evaluate hazards and risks Approve (or not) or modify Get ready for the change Communicate/train Update documentation 200 pages. April 2008, US $95 ISBN: 978-0-470-04309-7 http://www.wiley.com/WileyCDA/WileyTitle/productCd-0470043091.html 54 27
  • 28. MOC Program Life-Cycle Phases Design and development Implementation and rollout Operation Monitoring and improvement 55 MOC System Design/Development Failure Modes Inadequate workforce involvement Inadequate design basis - wrong change types types, inadequate review/authorization protocols MOC use rate not considered when establishing MOC resources Inadequate MOC resources designated MOC protocol complexity inappropriate for change types, resources, or workforce culture MOC system roles and responsibilities inadequate Scope of application of MOC program inadequate 56 28
  • 29. MOC System Rollout Failure Modes Inadequate workforce involvement Inadequate awareness training of workforce workforce, including contractors Inadequate detailed training of MOC system participants Insufficient MOC system tools/forms/resources provided Insufficient pilot-testing 57 MOC System Operation Failure Modes Failure to identify a proposed change - system circumvented Change classified as an emergency change when it did not meet established criteria Mistakenly included a RIK in the MOC review process Proposed change improperly classified - type or review path MOC origination information inadequate MOC initial review not completed or inadequate Inadequate MOC reviewers Wrong MOC review method used MOC hazard review path step missed, out of order, incomplete MOC hazard evaluation inadequate - hazards missed or risks improperly evaluated 58 29
  • 30. MOC System Operation Failure Modes Emergency MOC review procedure not finished MOC authorization inadequate - wrong, missing or risks accepted are inappropriate PSI not updated based upon change Personnel not informed of change Personnel not trained on change Wrong communication or training provided to personnel Temporary change left in place too long without further review Failure to restore system to original condition after a temporary change MOC review records inadequate or missing MOC delayed or lost in the system 59 MOC System Monitoring Failure Modes MOC metrics not properly developed or used Inadequate management review/oversight of MOC system MOC not addressed sufficiently in PSM audit 60 30
  • 31. Top MOC Operating Phase Failure Modes % of MOC Issues Failure to identify a proposed change 61 % - system circumvented Temporary change left in place too 43 % long without further review or failure to restore system to original Personnel not informed of change g 35 % MOC delayed or lost in the system 23 % MOC hazard evaluation inadequate - hazards missed or risks improperly 18 % evaluated 61 MOC Failure Example – Offshore Gas Compressor Module 62 31
  • 32. Unrecognized Change Led to Release Original position Modified position 63 Gas Release Resulted in a “Lucky Explosion” 64 32
  • 33. Company PS Metrics Related to Incident Number of open MOCs MOC action item aging Process piping inspection aging None of these metrics addressed monitoring the technical performance aspects of MOC that th t contributed to the incident t ib t d t th i id t 65 Top MOC Cultural Causal Factors 1. Establish process safety as a 7. Defer to expertise core value l 8. Ensure open and effective 2. Provide strong leadership communications 3. Establish and enforce high 9. Establish a standards of performance questioning/learning environment 4. Formalize the process safety culture emphasis/approach 10. Foster mutual trust 5. Maintain a sense of 11. Provide timely response to vulnerability safety issues and concerns 6. Empower individuals to 12. Provide continuous successfully fulfill their safety monitoring of performance responsibilities 66 33
  • 34. MOC Failure Was a Root Cause Several MOC failures occurred Development – failure to account for change type Rollout – precursors occurred during period Operation – failure to recognize, failure to evaluate Several safety culture issues were uncovered that contributed to the MOC system failures Lack of a sense of vulnerability Failure to empower individuals Lack of a questioning/learning environment Normalization of deviance 67 Conclusions from Example MOC is a critical PSM element MOC performance management (audits) often don't provide sufficient improvement information We must examine MOC failure modes to support continuous improvement MOC failure prevention must consider "life-cycle improvements Culture and behavior issues MUST be addressed for sustainable improvement Leading indicators supported by frequent management review are needed 68 34
  • 35. Strategy for Process Safety Performance Management Evaluating PSM failure modes Determining PSM failure culture causal factors Ensuring sustainable PSM/HSE performance improvement Avoiding organizational warning signs Critical success factors for PSM 69 How Does a Company Tell If It Is: In a process safety ditch On th d O the edge of a ditch f dit h Getting closer to a ditch Moving away from a ditch Maintaining proper distance from a ditch AVOID loss of visibility or fidelity in performance evidence sources – maintain a well-shaped and complete pyramid 70 35
  • 36. Example of a Faulty Pyramid Accidents Incidents Precursors Management System Failures Unsafe Behaviors and Attitudes Culture – Individual and Organizational Tendencies 71 Recognizing Catastrophic Incident Warning Signs in the Process Industries ISBN: 978-0-470-76774-0 264 pp December 2011 US $125.00 $125 00 http://www.wiley.com/WileyCDA/WileyTitle/pro ductCd-047076774X.html 72 36
  • 37. Monitor Warning Signs – Company Organizational change/stress without sufficient HSE impact evaluation and mitigation p g External-induced • Regulations, enforcement, economics, disasters, M&A target, etc. Internal-induced • Competency, memory, resources, focus loss, initiative overload, M&A, overload M&A leadership instability demographics instability, shift, turnover, absenteeism Loss of visibility/fidelity in performance evidence sources – maintain a good pyramid Poor reporting, trending, sharing, monitoring 73 Metrics Layered within the Pyramid # of PS incidents Accidents # of first aids f fi t id Severity rate Incidents Number of Near Misses Reported Precursors HSE/PSM audit score Number of Overdue Action Items Corrective Actions Generated Management System Safety Meeting Attendance, % Training Completed, % Failures RC Contacts Safety Inspections Completed, % Unsafe Behaviors and Attitudes BBS at-risk observations Trend incident and Culture – Individual and management system Organizational Tendencies technical and cultural root causes as learning Conceive of cultural opportunities occur weakness metrics to collect across © ABSG Consulting, Inc. company 74 37
  • 38. Process Safety Metrics – Arendt Suggestions 1. Process Safety incidents – ANSI/API RP 754 Tiers 1 and 2 2. 2 Process Safety incident precursors – RP 754 Tier 3 3. Failure to follow procedures/SWPs – BBS at-risk observation rate 4. Failure to fix identified process safety problems – action item backlogs or aging, equipment deficiencies backlogs 5. Failure to identify process safety deficiencies– inspection (all sources) backlog, failure to identify/report incidents or do adequate RCA 6. Failure to assess risk– MOC circumvention or low quality, PHA schedule backlog, PHA quality review 7. Safety culture weaknesses – Map RCs of incidents to cultural causal factors 75 Emerging Challenges with PS Metrics Don’t pick too many Make sure they roll up properly Make sure they add value Don’t just pick things you can measure; make certain they affect accident risk Think through how you will use them; anticipate unintended behaviors Make them visible – positive culture influence 76 38
  • 39. Characteristics of Good Process Safety Companies Not blind or arrogant – willing to look into the mirror Safe questioning/learning environment Proper safety ownership and leadership Effective, fit-for-purpose management systems Disciplined in execution - low/decreasing backlogs Effective action - prevention not just correction prevention, Action at multiple levels of the pyramid Builds better ownership and fosters a better culture 77 Characteristics of Good Process Safety Companies (cont’d) Learns lessons cheaply taught from all sources - py g avoids repeat teaching Pursues effective continuous improvement – seeks out better practices High quality incident investigations Proper process safety metrics and discerning audits Effective management review 78 39
  • 40. Keys to Future Process Safety Success To pursue zero or perfect PS – you’ve got to change the ways you are doing some things that served you okay to get you to where you are at Fit-for-purpose PSM/HSE system that is well-executed Nurture culture and operating discipline Create an effective learning organization Apply root cause thinking to everything Maintain an effective corrective action process High quality incident investigations Proper process safety metrics Discerning audits Effective management review 79 Teaching, Learning, and Remembering Go back to your plant, company, or organization and pick a notable incident and find out: What was done to keep it from happening again Do people remember it and the lessons What have you done to embed it in your "lore" What effective approaches still exist to prevent it What do you have to protect against PS Alzheimers Pick a notable event from another company or industry - and do the same Go up your chain-of-command and see how far the “remembering” goes 80 40
  • 41. “Perfect Process Safety” Is a worthy and valuable goal Can only be pursued by highly reliable organizations that embody effective learning patterns Sustainable process safety does not allow learning to evaporate or “retire” Should be the stretch goal for all companies and organizations 81 Swiss Cheese Model for Accident Causation 82 41
  • 42. Time for Questions sponsored by In Search of “Perfect Process Safety” How to Ensure Sustainable Continuous Improvement Learning from the M L i f th Macondo D d Deepwater H i t Horizon Bl Blow O t Out August 21, 2012 Runcorn, UK Steve Arendt, Vice President, P.E. North America Process Industries Organizational Performance Assurance Center sarendt@absconsulting.com 42