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July
2020
HYDROCARBON
ENGINEERING
56
Broadening the base of the process safety
triangle
There are often company initiatives aimed at driving employees
to complete Incident Management System (IMS) observations.
This has the effect of broadening the base of the process safety
triangle, fromwhich metrics can be used to assess how close a
company may be from having an incident. But the effectiveness
of any such drive will be diminished if those raising the
observations do not see any resolutions to the issues that they
raise. The motivated people who are willing to raise the
observations will consider the leadership team as being unable
to address safety issues.
It is key that a company has engagement with their staff on
these initiatives. These workers have a vested interest in staying
safe, as they will be the ones (along with the sites contractors)
who will be involved in the process safety incidents that occur.
If a company lacks engagement from their employees
regarding safety observations, then they could choose to set
them a target to raise weekly safety observations. This
encourages employees to look for issues, thus broadening the
base of the process safety triangle. But when the companies
target becomes about volume, it can affect the quality of
results. To combat this, companies could issue an award for the
best observation. This sounds good in principle, but when things
become so contrived like this, they seem to be lacking a good
cultural basis and the system does not flourish as intended. It is
easy for a company to become focused on the wrong targets.
An appropriate measure?
The setting of safety targets can be a fickle science. Should an
organisation have a target on howmany people they can harm
before the key performance indicator (KPI) is deemed to be out
of control? Is one injured employee acceptable? Maybe two or
three? No organisation sets out to intentionally harm anyone,
and an employee should expect to be safe at their place of
work, so the target should be zero. And while this should be
theoretically possible, does a target of zero meet the achievable
element of a ‘smart’ objective? Organisations may set a more
achievable target, which they expect to improve upon each
year. The zero-harm target would become out of range with any
incident and would take a significant length of time to reset for
a rolling target. This is said to demoralise an organisation and
does not allow for the learnings post-incident to influence the
future performance measure.
However, there is a growing motion within organisations
that the bar should be raised for safety performance and that
this is to be delivered by challenging employees’ behaviour.
Following the Health and Safety at Work Act, there has been a
steady decline in injury rates in the workplace, which has been
attributed to the introduction of policy and procedures.
Unsafe behaviours against the companies’ rules, which
prevent zero-accidents from being achieved, can be deemed to
be the ‘choice gap’. That is, the accidents that are currently
happening within organisations that have safety policies and
procedures in place are accidents that employees and
organisations ‘choose’ to have. This choice may be behavioural,
subconscious, procedural, or cultural. These human choices are
impacting on the quality and effectiveness of a company’s
process safety policies and procedures.
For example, within large complex energy installations, it is
typical to see a reasonable template for the Permit toWork
(PtW) certificate that the company has probably purchased
from a consultancy (i.e. not developed in-house where the
fullness of the requirements may have been better understood
through its development). But having a reasonable template is
not enough. The true value is in the implementation. All too
frequently, gaps in these templates are evident as they have not
been completed by the authorised person. Gaps in a company’s
template designed to manage process safety also means that
there will be gaps in the process safety barrier that this
procedure is meant to fulfil. Human choices that have led to
substandard PtW certificates may be a combination of:
A cultural statement: ‘The PtW issuer approved this
document last time, so this is all that is required’.
Employees will often do the minimum requirement that
the system allows them. If the PtW authoriser is not
passionate about the quality of the PtW forms they
approve, then who else will be? An auditor? This is a too
long a feedback cycle and the latent gap in a process safety
barrier will have been evident for the duration of the
hazardous activity.
A time-based decision: ‘I do not have time to fill out all
these boxes’. The perceived savings in time is curious. If an
employee is performing a task at their place of work, then
it is assumed they are being paid for the task and will leave
their place of work at approximately the same time each
day. So who’s time are they saving, or what is the perceived
gain by cutting corners? From an employer’s point of view,
should the organisation not care more about getting their
prescribed tasks completed correctly and to the fullness of
the requirements, rather than getting something done
quickly?
A procedural based issue: ‘This form is too onerous for such
a simple task’. In this instance, a company may have made a
process too burdensome, so that employees are
discouraged from completing the task as they do not see
the value. Organisations should be reviewing the tasks that
they are asking their employees to complete and if there
are elements that add no value, then they should be
modified as appropriate, as the risk is that they lose the
buy-in from their staff, which results in an erosion of rules.
A slight variant of this is operator check lists for safety
equipment that are diligently completed in the field by
numerous operators over several months. However, the form
was printed in a small font with tiny boxes for recording
information, which effectively meant that the formwas
ineligible and hence the task had little value. The interesting
point was that none of the operators who so diligently
completed the form had suggested an improvement. Nor had
the audit team offered any feedback on the process.
Similarly, there are examples where good, experienced,
knowledgeable operators have worked in other companies that
have had examples of best practice but not looked to suggest
these practices to their current employers. While operators may
not necessarily be well placed to implement a change in
operating practice, improvement suggestions should always be
welcomed.
Meaningful analysis
So how can a company’s maturity with regards to process safety
culture be assessed? Organisations are moving towards