Accepting that incidents are inevitable can be considered a form of institutionalized normalization of deviance. Immense capital investment and human resources are dedicated to investigating incidents that have already created negative consequences. An entire industry has matured around this single process safety element, but is this really what is best for driving improvement?
Some companies may feel defensive about their investigation program. This article provides alternative views to allow a paradigm shift in process safety philosophies. If audit findings are considered as preventative predictive process safety maintenance (PP-PSM), then the proverbial glass is seen as full. When other process safety elements are enhanced for their preventative predictive attributes, then that glass will eventually fill and spill over. Other elements that possess PP-PSM attributes include:
* Employee participation
* Process safety information (PSI)
* Process hazard analysis (PHA)
* Operating procedures
* Management of change (MOC)
* Pre-startup safety review
* Mechanical integrity
* Hot work
* Compliance audits.
These elements wean industry off its normalized dependence on the investigation element, sustaining long-term improvement. A closer examination of these elements can help unlock their potential.
Employee participation. Employees must be involved in PSM programs at their respective worksites and should have representation at meetings where PSM-related issues are discussed. Worksites must ensure that the execution of employee participation is not just an exercise to satisfy the letter of the law.
An engaged, excited and empowered workforce that feels connected is an involved workforce. When the entire organization is invested in the ownership of process safety, then and only then will the glass begin to fill. Consider what miracles would be possible if humans utilized 100% of their brain, and then what an organization could do with the entire workforce participating in PSM.
This goal of 100% employee participation can only be achieved through trust, which revolves around a healthy workforce culture. Employee participation is critical to achieve a state where investigations are not required. Every element in PSM is affected by human reliability in some measure, and workforce behaviors are initiated by the site's safety culture.
Process safety information. Directives of this PSM element from Occupational Safety and Health Administration (OSHA) mandates include, "The employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard." This means that all workers have access to and understand the technical data regarding the high-consequence risks they face on the job.
Accurate and accessible PSI is the foundation for conducting a PHA. Inaccurate process and instrumentation diagrams have obvious consequential effects during a PHA. Maintaining PSI-required documentation in a facility provides the entire workforce another point of emphasis for employee participation opportunities.
PSI drives other PSM elements, such as mechanical integrity, operating procedures, training and MOC. An inaccurate PSI has a ripple effect, and when this element fails to deliver it has a direct impact on...