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.