It is incredible to me how tenaciously old thinking clings to the safety community.  I continue to hear pundits assert that confrontation is a key skill of creating a safety culture.  Unless you want a confrontational culture, I couldn’t disagree more if they were twice as wrong.  So, why do you not want to make confrontation a common skill and a key part of your culture?  Because confrontation is a “stopping tool.”  If you cling to the old idea that safety is getting workers to “stop taking risks,” then you tend to think this way.  Workers get hurt because they take risks.  “Workers are the problem with safety.  Fix the workers and you will fix safety.”

However, if you can grasp the concept that workers don’t want to get hurt and that they are the customers of your safety programs, then you will think differently.  Accidents happen because of risks.  Safety needs to help management identify and remove or reduce risks where possible.  Safety needs to help workers identify and deal with remaining risks efficiently.  Workers need to help each other practice taking precautions around the remaining risks.  The key skill of safety is coaching, not confronting.  Safety is about starting excellence, not stopping stupid risk taking. 

If you continue to think the about safety the way you always have, you will do as you have always done and produce the same results you always have.  Get away from confrontational thinking and embrace the concepts of safety excellence.

-Terry L. Mathis

For more insights, visit 

www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).

The Center for Chemical Process Safety (CCPS) defines Management of Change (MOC) as:

“A temporary or permanent substitution, alteration, replacement (not in kind), modification by addition or deletion of critical process equipment, applicable codes, process controls, catalysts or chemicals, feed stocks, mechanical procedures, electrical procedures, safety procedures, emergency response equipment from the present configuration of the critical process equipment, procedures, or operating limits.”

Or as stated by the U.S. Chemical Safety and Hazard Investigation Board (CSB):

“In industry, as elsewhere, change often brings progress.  But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” 

On June 1, 1974, the Nypro cyclohexane oxidation plant in Flixborough, England was destroyed by an explosion. There was a release of 30 tons of cyclohexane to the atmosphere that formed a vapor cloud ignited by an unknown source about 45 seconds after the release. The resulting explosion destroyed the entire plant, resulting in the death of 28 people and 89 other serious injuries. The number of fatalities would have been much greater had the accident occurred on a weekday when the administrative offices would have been filled with employees. The damage extended beyond the plant to 1,821 nearby houses and 167 shops and factories; total property damage reached $63 million.

The Flixborough explosion was the result of an unwise plant maintenance modification. In short, there was no MOC process in place, and it was as a result of this incident that the regulators such as HSE introduced MOC as part of Plant Safety regulations (i.e. COMAH in the UK). If an MOC system has been in effect at the plant, the explosion might have been prevented. The MOC system would have called for a proper safety review, adequate approval at all stages of the change process, and a design created by trained professionals.

One of the main recommendations of the Flixborough inquiry was:

“Any modification should be designed, constructed, tested, and maintained to the same standards as the original plant.”

Many of our safety regulations, analysis methodologies, and technologies that we use today have evolved as a result of incidents such as Flixborough, Piper Alpha, Bhopal, and many more.

Thankfully, not all MOC related incidents are as severe as Flixborough, but these minor day-to-day infractions should be a big red flag, as they nevertheless have an impact on an organization.  If not resolved, they are likely to result in far more severe consequences.

MOC and related permit to work activities can be viewed as a burden on Operations and Maintenance personnel who are already working overtime on managing their daily activities of running the facility efficiently. However, MOCs must be implemented in a robust fashion and appropriate resources must be allocated.

The number of MOC a typical plant processes can be summarized in the following statements by Ian Sutton Ref (Process Risk and Reliability Management June 2009 http://www.stb07.com/):

• 250 MOCs per year for a medium-sized site of say 140 employees
• 1,000 MOCs per year for a large site of say 2000 employees
• 1,400 MOCs for a world scale Refinery

How good is your MOC system, and can you safely and efficiently handle the MOCs in your facilities? Take into consideration the following questions:

1. Can your MOC system provide the following Key Performance Indicators (KPIs)?
   • Percentage of MOCs past due date
   • Percentage of MOCs properly executed
   • Percentage of audited changes that used MOC prior to making the change
   • Number Temporary changes still to be MOC-ed
   • Number MOC performed per month, and monthly average
   • Percentage of work requests classified as a change
   • Percentage or variation in the number of changes processed on an emergency basis
   • Average backlog of MOCs/active MOCs
   • Average time taken between MOC origination & authorization
   • Percentage of work orders/requests that were misclassified as replacement-in-kind (RIK) but should have been MOCs
   • Ratio of identified undocumented changes to number of changes processes by MOC
   • Percentage of changes that were MOC-ed but reviewed incorrectly
   • Percentage of MOCs that were not documented properly
   • Percentage of MOCs for which drawings and procedures were not updated
   • Percentage of temporary MOCs where the temporary conditions were not corrected/restored to original state by the deadline
   • (#MOCs/#MOCs+#changes that by-passed MOC) *100% 

2. Can you conduct a complete and thorough impact assessment to show all related data and information that needs to be reviewed and re-validated as a result of the proposed MOC (e.g. trip and alarm setting, procedures, LOTO, cause and effect diagrams, etc.)?

If you can confidently answer yes to these questions, you have a robust system in place and are in control. If not, we recommend reevaluating your MOC processes to help ensure your MOC system can effectively and safely process the large volume of MOCs that may flow through your facilities.

This has been a guest contribution by Clive Wilby.

Clive, Oil & Gas - Expert Practitioner Consultant at North Highland, has forty years of experience working for Owner Operators and Engineering Procurement Contractors in the Petrochemical sector fulfilling engineering, maintenance and project management roles. His passion is helping EPCs and Owner Operators with information and data management for new and existing assets involving operational excellence, integrity management, and process safety.

Have you ever looked into the eyes of workers in a safety meeting?  In some meetings the eyes light up, in some they gloss over, and in others they roll.  If you are creating gloss and/or rolling eyes, you have a great opportunity!  Think about it - you already dedicate time to safety meetings.  Why not get the maximum return for that time invested?

I know a lot of meetings are mandatory.  I know that being forced to do something can take the fun and motivation out of it.  But it doesn’t have to be a boring case of grudging compliance.  Meetings can be an opportunity to discuss upcoming issues, share expertise from experienced hands to new hires, discuss best practices, or plan an upcoming project.  It doesn’t have to be a lecture or sermon on thinking before you act.  It can be interactive and engaging with just a little effort and pre-planning.

The key aspects to creating bright-eyed meetings are practicality and participation.  Topics that don’t readily apply to real work get eyes rolling.  Boring speech-giving presenters or shallow attempts to involve workers make the eyes gloss over.  Remember this formula:  Practical topics + Engaging delivery = Bright eyes. 

-Terry L. Mathis

For more insights, visit 

www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).

The Huffington Post article, “America’s Disastrous History of Pipeline Accidents Shows Why the Keystone Vote Matters” highlighted the pipeline industry’s incident record and stated that on average one significant pipeline incident occurs in the country every 30 hours. The key question to ask is – what is the pipeline industry doing to reduce the number of incidents and lower the risk of harm to the environment and surrounding communities where they operate.

After the 2010 San Bruno pipeline explosion in California and per National Transportation Safety Board’s recommendations, midstream industry leaders in coordination with the American Petroleum Institute (API) gathered and collaborated to develop a recommended practice (RP) for the industry. Known as, API RP 1173 Pipeline Safety Management System (PSMS), it provides guidance for developing and maintaining a comprehensive management system to improve operational safety and decrease the rate of releases and incidents.  The PSMS framework defined in API 1173 shares common principles with safety management systems found in other industries such as nuclear, aviation, offshore oil and gas, and refinery and chemical plants. These safety management programs have demonstrated reductions in operational risk, reduced occurrences of incidents, and provided a platform for continuous improvement to achieve operational excellence. Large, integrated energy companies already have such overarching management systems in place that cover pipeline safety, such as an operations management system. However, the standards in API RP 1173 will likely require effort and executive commitment to enhance existing operations management/safety management system to fully meet the API RP 1173 requirements.

While many midstream companies have various programs that address risk management, asset integrity and management of change, a safety management system will provide an integrated management system that cuts through organizational and functional silos to achieve greater transparency and awareness which leads to better decision making and safer operations. Recognizing the significance of leadership accountability and communications to achieve a sustainable and meaningful operations/safety management system, the API RP 1173 devotes significant content to framing the role leadership at all levels plays in ensuring safe and reliable operations.

The final release of API RP 1173 is anticipated next month and is expected to change the way leaders think about their business decisions to a more holistic, systematic approach. For example, the draft version of API RP 1173 states, “Managing the safety of a complex process, as well as simpler systems, requires coordinated actions to address multiple, dynamic activities and circumstances. Pursuing the industry-wide goal of zero incidents requires comprehensive, systematic effort. While process-related incidents are relatively infrequent but can lead to serious consequences.”

While not mandatory to adopt API RP 1173, an operator risks being found negligent for not adopting and following a PSMS consistent with RP 1173 in the event of an incident as it will be considered an industry standard for which pipeline operators to follow.

This has been a guest contribution by Katherine Molly.

Katherine, Principal of Northhighland, works with executive management and project teams to improve organization processes for safety and reliability, reduce capital program and business process risks, and resolve program/ project crisis and disputes in the energy industries. Supporting owners, contractors, engineers, their legal counsel and sureties, she has led assessment and improvement organization and project programs, enhanced project execution, coalesced conflicting parties, and participated in the settlement/litigation of business and project disputes ranging from $1 million to multi-billion dollars.

It is amazing how many workers view safety as a form of Voodoo.  They know they can do a job hundreds of times accident-free, then suddenly get injured.  What is the difference, and how can you prevent such random events? 

To begin de-mystifying safety, you must first define it.  Safety has three parts:  1. Identifying and recognizing risks, 2. Addressing risks through conditional changes or behavioral precautions, and 3. Developing consistency in risk control.  In short, workers have to know what can hurt them, know how to keep these things from hurting them, and consistently do those things.

Internalizing such a definition tends to take the mysticism out of safety.  Each time an accident happens, workers analyze which of the three steps didn’t happen, and understand the causation of accidents.  There is no Voodoo, only cause-and-effect.

-Terry L. Mathis

For more insights, visit 

www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).

Since the beginning of time, successful people around the world have shared similar personality characteristics.

Martin Luther King inspired a movement with his ability to instill emotion in his fellow people. Winston Churchill made a war-torn nation stand up with confidence and fight a seemingly unstoppable enemy. Mahatma Ghandi used civil disobedience to change the world for Indians, at home and in South Africa. Steve Jobs inspired a technological revolution with creativity and an uncanny knack for capturing an audience.

Behavioral science will tell you that these great people had specific personality characteristics that led them to behave in the way they did. Research into psychology and personality will provide evidence that they were great because they were born great.

But what about the rest of us?

Chances are, you may consider yourself a bit more “ordinary” than the leaders of history. However, you have the potential to achieve your own personal greatness.

Through self-awareness, we can learn how to interrupt our natural default behaviors that keep us from behaving in a way that is productive, efficient, and safe. By taking control of our own self-awareness and truly understanding who we are underneath it all, we can achieve our own greatness in our own lives. The only thing holding us back is ourselves.

Take one of my friends for instance. He was not a social person by birth; he has consciously developed the skills of communication and education to a point that those who meet him would describe him as a talkative and very pleasant person. Little do they know that he exerts a significant amount of energy in social situations - far less than people like him who naturally derives great pleasure from social interaction.

How did he do it? Through a heightened sense of self-awareness.

If my friend recognized that he was uncomfortable in a situation, he would remind himself of why it’s important that he develops these skills. In times of stress or confusion, when his natural default personality was at its strongest, he learned to be in control, behave in the way he wanted to, and ignore his sometimes risky gut reactions.

You too can rise to new heights by first learning why you act the way you do. Through this self-reflection you can leverage your innate strengths to improve your decision making and behavior both at work and at home.

This has been a guest contribution by Greg Ford.

Greg is the co-founder and CEO of TalentClick Workforce Solutions and an adjunct professor at Simon Fraser University in Vancouver, Canada. Greg holds a degree in Psychology and a Master’s degree in Workplace Learning. He is the co-author of the safety book “Before It Happens” and has spoken at conferences across North America.

You can discover the power of Safety Self-Awareness with a free 30 day unlimited subscription of TalentClick’s full suite of safety solutions, including self-study, online training, and personalized coaching by going to http://www.talentclick.com/gb-trial/.

Human nature involves risk taking; every human takes calculated risks on a daily basis.  Safety is about removing risks, and thus competes with human nature.  We can address this by trying to change human nature or by increasing the capacity to calculate risks more accurately. Very few people know even the approximate probability of the risks they take or which risks are more likely to result in an accidental injury. 

Organizations should analyze their accident data, not by body part most injured or injury category most common, but by which precaution has the potential to prevent the most injuries.  This data should be methodically shared with every employee to shape their perceptions of risks and focus their safety activities.  If this does not happen, individual perceptions of risks will vary by personal experience and knowledge of accident data, and will not result in maximum focus and directed effort.

-Terry L. Mathis

For more insights, visit 

www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).

During a safety observation, workers were observed using the wrong tool for a job, which created a risk.  When a safety committee saw the report, they petitioned management to buy the proper tool for the work station.  The committee member who received the tool took it to the work station and presented it to the worker on shift with an explanation of what had happened and the action taken.  The worker admitted that he really had not been taught what the proper tool was for the job and had used the home-made tool since he began his job.

The next month’s observations reported that workers were still using the wrong tool for the job.  Follow-up revealed that workers on the other shifts had not received the communication and were not aware of the new tool.  The safety committee made sure that every worker was made aware of the proper tool in safety and tool box meetings and felt sure the next month’s data would show the problem solved.

The next month, the observations showed the workers were STILL not using the right tool. Follow-up revealed that workers had formed the habit of using the wrong tool and that the habit was not changed.  The safety committee developed a plan to remind workers and, within the next few months, the problem was truly solved.

Lessons learned: 

•             Safety problems can be multi-layered and require multiple fixes.

•             Solving problems requires follow-up.

•             Influences need to be addressed in order to change the behavior.

-Terry L. Mathis

For more insights, visit 

www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).

When new safety programs or processes are rolled out unsuccessfully, there has almost always been a failure to determine either the factors necessary for success, the factors that can contribute to failure, or some combination of both.  Without a list of the key factors of success and failure, a project launch is a blind affair.  This blindness seems more logical if the project appears to be well constructed and has been successful at other organizations or sites in the same organization.  Sadly, imitation of success is no guarantee of success. 

The reasons for the imitation failing are basically the differences in sites and cultures.  A good fit for one site might be a recipe for disaster at another.  That is why an analysis of success and failure factors is so necessary.  Such an analysis is unique to each culture.  It should include a review of past successes and/or failures and the factors that contributed to those; but it should also include simply asking a representative cross-sample of people what they think of the project and what it would take to make it work.  Good implementers and change agents have usually learned a lot about such analysis, but can almost always be more thorough if they simply list critical factors to success and failure, and address them in their implementations.

-Terry L. Mathis

For more insights, visit www.ProActSafety.com

Terry L. Mathis is the founder and CEO of ProAct Safety, an international safety and performance excellence firm. He is known for his dynamic presentations in the fields of behavioral and cultural safety, leadership, and operational performance, and is a regular speaker at ASSE, NSC, and numerous company and industry conferences. EHS Today listed Terry as a Safety Guru in ‘The 50 People Who Most Influenced EHS three consecutive times. He has been a frequent contributor to industry magazines for over 15 years and is the coauthor of STEPS to Safety Culture Excellence (2013, WILEY).