We continue our series featuring some of the items in the book that we are writing, Process Safety Management.
Process safety is not a program that is handed down by management to their employees and contract workers; it is a program that involves everyone: designers, operators, maintenance technicians, managers and senior executives. The key word is involvement — which is much more than just communication. All managers, employees and contract workers are responsible for the successful implementation of the program. Management must organize and lead the initial effort, but the employees must be fully involved in its implementation and improvement because they know the most about how a process really operates, and it is they who will have to implement recommendations and changes. Specialist groups, such as staff organizations and consultants can provide help in specific areas, but process safety is fundamentally a line responsibility.
A generation ago, OSHA published the fourteen elements of its process safety standard. The significance of putting Employee Participation at the top of the list cannot be over-stated. And note that they called it Employee Participation, not Employee Communication.
Employee Participation
Process Safety Information
Process Hazards Analysis
Operating Procedures
Training
Contractors
Prestartup Safety Review
Mechanical Integrity
Hot Work Permit
Management of Change
Incident Investigation
Emergency Planning and Response
Compliance Audits
Trade Secrets
(In recent years there has been a tendency to talk about ‘Culture’. But the fundamental message has not really changed.)
The subsidiary nature of the other elements can be illustrated with the following vignette.
An operator working by himself at two o’clock in the morning is about to open a valve connecting two tanks, but before doing so he pauses for a moment, and says to himself:
“You know, opening this valve could lead to reverse flow, which could lead to wrong chemicals mixing with each other, and . . . you know what — before opening the valve, maybe I should take a break, make a cup of tea, and talk over what I’m planning to do with my colleagues and supervisor.”
When an employee thinks and acts in this manner, the hazards analysis program is working very well indeed because it has become a subset of Employee Participation.
Very good example of how not to fall in complacency. In industries and process that operators have a long time working, complacency could be the most difficult state to recognize and to avoid.