© BB&A 2014

BB&A thoughts

Development and deployment of ‘Golden Rules’

20 March 2014

The challenge…

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Large organisation that are seeking to harmonise HS&E management across its different processes and sites are looking to, amongst other actions, deploy a set of rules – ‘Golden Safety Rules’ also sometimes entitled: ‘Fatal Risk Protocols’, ‘Life Saving Rules’, ‘Cardinal Rules’, Safety Non-negotiables’ etc. It is not an easy concept, considering we are all human and the last thing a company should be doing is taking away the ability or rights of people to think for themselves, identify and understand risk and use initiative. The process must be done properly and we believe in consultation, as for all effective safety interventions. But more about that in the following pages courtesy of ‘Management of safety rules and procedures’ A review of the literature by Prof A Hale, Dr D Borys and Prof E Else.

The challenge 3

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Things to think about rules…

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Failure to follow rules and accidents will happen

•  Studies off shore installations found that: –  ‘Failure to follow rules ‘ – is the third most important perceived cause of accidents –  after, not ‘thinking the job through’ and ‘carelessness’

•  Challenger – Normalisation of deviance from rules •  Deepwater Horizon – Lack of explicit procedures to govern changes to the well-drilling, -capping and - testing methods •  Dutch studies in chemical industry regarding Loss of containment:

–  50% relate to procedure –  10% non or unclear procedure, –  12% wrong procedure and –  28% the procedure was not followed.

•  Thus, rules and procedures are perceived in the whole as desirable and certainly unavoidable to allocate responsibilities and define behaviours in complex and conflicting environments and processes

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Categorisation of rules

•  Performance goals: –  They define only what has to be achieved and not how it must be done e.g. target levels of incidents – this type of rule

is only feasible if there is feedback of the results of actions •  Process rules/’General intent adherence’:

–  Which define the process by which the person or organisation should arrive at the way they will operate, but still leaves considerable freedom about what the that operation will be. E.g. Risk assessment – the effectiveness of both Process rules and Performance goals increases depending on the competence and experience of the people using the rules (e.g. less time)

•  Action rules/’Step by step’ adherence: –  Which specify in terms of ‘if…then’ statements, exactly how people should behave, or hardware should be designed

(e.g. wear seatbelts whilst driving)

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How effective are rules?

•  A study of safety rules in Dutch railways, showed that –  only 3% of workers used rules often, –  almost 50% never. –  47% of workers found rules to be unrealistic, –  29% that they were used only to point the finger of blame. –  95% thought that if they kept to the rules work couldn’t be completed in time –  79% thought there were to many rules –  70% that the rules were too complicated –  77% found some rules sometimes contradictory

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How effective are rules?

A survey of 400 operators and managers in the chemical industry sited the reasons for not following procedures: •  40% said they were unworkable in practice •  62% said that if followed to the letter the job couldn’t be done in time •  48% thought they were too restrictive •  44% said they were too time consuming From the same survey: •  57% thought that people were not aware that there were procedures laid down for the job they did •  70% expressed the view that people assume they know what’s in the procedure •  70% prefer to rely on their own experience •  19% felt that experienced people don’t need procedures •  34% resented being told how to do their job and saw rules as a restriction and a slur on their competence

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What do we want the rules to do?

•  ‘Encourage safe work, navigating within an ‘envelope’ demarcated by safety barriers and rules, which aim to prevent movement outside the envelope.’

•  Or in other words… ‘Defines the boundaries of the various ‘zones’ of normal operations, controllability and viability and supporting the process of manoeuvring to stay inside those boundaries.’

•  ‘Rules are part of the armoury of the operator to conduct a task successfully.’

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The Janus faces of safety rules

•  One is top-down, rational, optimistic view of rules •  The second is a bottom-up participative approach to rule emergence

•  Is the answer a compromise? •  Is the the use of the word ‘rules’ correct – how does it resonate with e.g. a skilled workforce?

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Two contrasting paradigms of rules

Paradigm 1 •  The classic, rationalist view of rules as constraints on the

behaviour of those at the sharp end of operations. •  The rules are imposed by experts situated higher in the

hierarchy and removed from the day-to-day work. •  Following rules is seen as the best way of behaving in all

situations that can be envisaged. •  Rules constitute constraints on the errors and mistakes

of fallible operators, who are portrayed as not having the time or competence to come up with those rules.

•  This is an essentially top–down view of a static set of rules that should not be violated.

•  Not following the rules is seen as essentially negative and to be discouraged, or at most learned from and corrected.

•  Much, but not all of it, deals with relatively simple workplaces and actions.

Paradigm 2 •  According to this paradigm, rules are socially constructed

patterns of behaviour, deriving from experience with the diversity of reality.

•  Rules are local, situated and have many exceptions and nuances.

•  The experts in this paradigm are the operators, and this view is essentially bottom–up and dynamic.

•  This paradigm sees written rules as necessarily simplified abstractions of this complex reality, to be used as generic guidance, but adapted to each different situation in real life.

•  The imposition of externally derived rules are characteristically seen by the ‘expert operators’ as unwarranted limitations on their freedom of choice and slurs on their competence.

•  Violations of such rules are seen as inevitable and knowing how to violate safely is regarded as a badge of mastery of the activity.

•  Deals with predominantly complex, high-technology

operations.

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Your people - Rule breakers or rule takers? Sheep or wolves?

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People

Wolves 14% were not inclined to but had (in their eyes exceptionally) done so

30% were inclined to and had already done so

Sheep 22% of the workforce were not inclined to violate and had not done so

34% were comfortable with violation but had not (yet) had occasion to do so

People Sheep Wolves

Source: Hudson et al

vs

Involve the wolves in the defining process and the unthinking sheep need very clear procedures!

Why violations?

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Individual factors • Attitude to and habits of non-compliance • Intention to comply/violate • Previous accident involvement • Low level of knowledge/training/ experience • Sees way to make short cuts • High value on macho, exciting, quick, money- or energy-saving way to work • Self-image and status among peers favours risk and violation • Tiredness • Perceived low risk/threat/consequence • High self-efficacy/powerfulness • Does things on the fly/lack of planning • Sex (males in driving, not in other arenas) • Age (young in driving, not in other arenas) * Exposure time * Communication

Organisational or safety climate factors • Management turns a blind eye or is inconsistent in sanctioning • Poor supervisor–worker co-operation • Non-participative style of supervision • Poor (work) group cohesion • Not checking procedures • Site organisation failures • Conflicts between trades • Norm that: ‘A skilled person can violate this way with impunity’ • Time pressure • Conflicting demands, especially in relation to productivity • Subjective group norm to violate • Lack of trust • Workload and work pressure • Management commitment • Supervisory position * Participation in safety programme * Incentive pay vs. fixed hour rate

Hardware/activity factors • Unfamiliarity with design • Complicated, difficult or changed design • Design/layout makes violation necessary to achieve objectives • Use of incorrect materials • Compensate for poor equipment

Rule-related factors • Difficult to understand • Difficult to comply/work with • Violation needed to get job done • Outdated rule • Conflicting rules, no priorities given • Rule seen as not appropriate for the organisation/activity (rule-maker has no knowledge of reality of activity) • Too many rules

• = factors that were correlated; • = factors that were tested but found to be unrelated; * = conflicting findings from different studies

Pitching the communication to the different audiences

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Rules are key and so is to ensure people follow them… •  Safety rules and procedures form an essential part of a company’s risk control system •  Procedures form part of the written documentations required under OHSAS 18001 •  In the OHSAS 18002:2008 guidance to the 18001 Standard for Occupational Health and Safety Management Systems

procedure is defined as a ‘specified way to carry out an activity or process’ •  The guidance uses procedure to direct and control and to specify the activities of the safety management system (hazard id,

risk assessment, communication, participation, monitoring/auditing etc) •  Safety management system such as ISRS, TRIPOD, ARAMIS, Hearts and Minds’ identify the management of procedures as

one of their key functions. Procedures are in place to help humans operate in a complex reality

•  So… •  Vital for the success of rules, according to ‘Management of safety rules and procedures’, is the participation of rule users in

formulating the rules

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vs

Things to think about when defining rules…

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Defining them: •  Keep the number of ‘rules’ to as few as

possible. •  Make them personal i.e. “I will not”

rather than “Do not” •  They must be very relevant to the

actual workplace •  They should cover high risks and

situations or behaviours that can cause serious harm

•  Define not only what they are but also how to comply

•  The rules must be within an individuals control -achievable

•  Make them clear and concise •  Is it a ‘Golden rule’ or not? Is it serious

enough/impact big enough

Making them stick: •  Easy to remember •  Make sense •  Shows benefit •  Make you want to do it •  Consult, Communicate, communicate,

communicate, educate and ensure ALL understand

•  Responsibilities must be clearly defined •  The rules must apply to everybody •  Make the penalty fit the crime. •  Be fair and consistent in the application and

enforcement. •  Establish an out for when there is no way

forward identified without breaching the Golden Rules ie stop work and consult with Manager

•  Clearly communicate the punishment for breaches and who will determine – using words like “may result in disciplinary action or termination” will dilute the importance

Some Guiding principles

What other company’s have…

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In an industry that’s full of risks, it’s our aim to create a safe working environment for every one of our employees. The key to this is ensuring everyone accepts responsibility for personal safety. Our ‘Eight Golden Rules of Safety’ are based on analysis of the most common causes of accidents in our industry. By following these, our people are taking a big step towards reaching Horizon Zero

The Golden Rules for safety at work are intended to be shared across Total’s businesses and operations. They must be fully understood and obeyed by everyone. These rules are intended for the people who organize work, the people who carry it out and the people who inspect it. They are based on systematic processes for identifying, assessing and managing risks. They are one component of an appropriate identification and sanction policy

Safety is a legitimate personal expectation and a constant individual responsibility. Every member of staff should be able to go home at the end of the working day without having suffered or caused harm in any way

Golden Rules These three simple rules make it clear how Shell employees and contractors are expected to behave. You and I: • Comply with the law, standards and procedures • Intervene in unsafe or non-compliant situations • Respect our neighbours The rules emphasise individual responsibility while encouraging staff to intervene to help their colleagues and respect neighbours.

A few examples of ‘Golden safety rules’

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Safety RULES per company

1 2 3 4 5 6 7 8 9 10 11 12

PETROFAC Golden Rules

Confined space entry

Management of change

Ground disturbance

Lifting operations

Energy isolation

Permit to work

Driving safety Working at heights

TOTAL Golden Rules

High-risk situations

Traffic Body mechanics and tools

Protective equipment

Work permits Lifting Work on powered systems

Confined spaces

Excavation work

Work at height

Change management

Simultaneous operations or co-activities

BP (Korea)

Permit to work Energy isolation

Ground disturbance

Confined space entry

Working at heights

Lifting operations

Driving safety Management of change

Shell

Life saving rules

Work with a valid work permit when required

Conduct gas tests when required

Protect yourself against a fall when working at height

Obtain authorisation before entering a confined space

Obtain authorisation before overriding or disabling safety critical equipment

Protect yourself against a fall when working at height

Do not walk under a suspended load

Do not smoke outside designated smoking areas

No alcohol or drugs while working or driving

While driving, do not use your phone and do not exceed speed limits

Wear your seat belt

Follow prescribed journey management plan

Shell

Golden rules

You and I: Comply with the law, standards and procedures

You and I: Intervene in unsafe or non-compliant situations

You and I: Respect our neighbours

Various Valid Permit to Work when required

Install and verify energy isolations when required

Ensure gas testing and monitoring when required

No entry to confined spaces without a risk assessment

No removal or disabling of safety critical equipment without a risk assessment

Appropriate fall arrest to be used for work at heights

No walking or working below suspended loads

No smoking outside designated areas

No alcohol or other drugs affecting work performance

No use of mobile phone when operating vehicles

Always wear your seatbelt in vehicles

Use SLAM (stop, look, assess, manage) for managing hazards in every task

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The Anglo American Safety Golden Rules have been developed after a review of the fatal incidents in our business. Over 80% of the fatalities occurred in the areas covered by these Safety Golden Rules The Safety Golden Rules are a condition of employment and must be followed at all times. The Rules apply to everybody: employees, contractors, service suppliers and visitors Where you consider a task cannot be carried out safely, do not commence and do not continue to perform the task.

Sims way Safety Golden Rules Golden Rules reflect our core SHEC values. Breaking a Golden Rule is a serious offense that will attract disciplinary action.

The golden rules incorporate all the experience and learning gained by three companies in over ten years of performing millions of safe crane transfers

A few more examples of ‘Golden safety rules’

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Safety RULES per company

1 2 3 4 5 6 7 8 9 10

Anglo American Safety Golden Rules

The Fundamentals E.g. Be competent and authorised Fit for work and unaffected of drugs and alcohol etc.

Underground and surface mining

Mobile equipment & Light vehicle

Confined spaces Working at heights

Energy & Machinery isolation

Lifting & Mechanical Handling

Water bodies & Liquid handling

Chemicals & Hazardous substances

Arcellor Mittal I will come to work in a “fit and able” condition

I will use fall protection or prevention whenever and wherever required according to our standards

I will follow the lockout/isolation procedure when working on equipment

I will follow the confined space entry procedure before entering as well as during the full duration of the task

I will respect all the rules of load handling at all times and never stand under a suspended load

I will respect all the traffic rules

I will respect rail priority and stay out of close clearance areas without proper precautions being taken

I will respect the rules for entering and/or working in hazardous gas areas

I will not disable safety devices

I will respect all the H&S basic rules, standards and signals and I will wear the required PPE

SIMS Recycling solutions

(US)

PPE Log Out/Tag Out Fall prevention Vehicle/Mobile Equipment Safety

Machine Guarding

Lifting operations Modification of Equipment/Safety Systems

Permit to work Housekeeping – Fluids, Spills & Releases

Courtesy and Respect

Reflex Marine (US) Understand your risks Be familiar with your conditions

Know your vessels

Know your cranes

Know your transfer device

Be familiar with your crews

Plan your lift If in doubt ,stop Recognise complex operations

Emergency planning

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•  Do not operate any mobile plant unless I have been assessed and Authorised in writing by the Site Manager or the Site Managers representative.

•  Prior to working on any equipment, it must be isolated and de-energised. •  All work at height above 2.0 meters must use fall protection/fall restraint equipment. •  Do not stand under a suspended load. •  I will not enter a Confined Space or Restricted Area unless Authorised. •  Look after each other, health and safety is a team game •  Think before you start work, do a TAKE 5 – know the risks •  Report ALL accidents and near misses •  Wear all PPE as required by signage •  Only undertake work for which you are trained and competent •  Do not work under the influence of drugs or alcohol •  Use the correct equipment for the task •  No cutting of corners •  Must have a Permit to Work when required •  Use energy isolations when required, do not tamper with or remove unless you installed or are authorised •  No removal or disabling of safety equipment, devices or signage •  No walking or working below suspended loads •  No smoking outside designated areas •  No use of mobile phone when operating vehicles or walking at any time in production areas •  Do not bring a weapon on site (other than a necessary tool of trade for work)

Typical ‘Golden safety rules’

Examples of collateral

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Animation

Booklet/cards

Intranet

Icons/posters

Illustrations

How we think you should develop your

rules…

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Through a series of workshops discussing these types of things 26

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What are rules? •  What they do/are? •  Characteristics

What makes good ones? How many? Retention/cynicism

What’s the best thing to call them? Why? Golden, Essential, Life saving etc

Learning from others •  Mapping, examples, learning/

like/don’t like

Our business •  What we have •  What we like •  What engages us? •  What makes us switch off?

What do we want them to do? •  Sackable offence/compliance •  How strict are they? •  What’s their role? •  Influence and meaning?

What do we want our rules to actually be? Basics •  Essentials Benefits •  Life savers Aspiration •  Zero harm Rule words •  Regulation •  Standards •  Instructions •  Must `Dos

How to communicate & engage with rules?

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How to communicate & engage rules

Face-face – large groups Environment Campaigns

Videos

E-learning

Safety rooms (pop-up or permanent)

Face-face – small groups toolbox talks (per ‘rule’)

Cartoons Or a combination…

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Thank you!

For further information, please contact: Gideon Bernto t: +44 1252 820812 m: +44 7918 737472 gideon.bernto@bbanda.co.uk

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