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    Industrial Process Safety

    Lessons from major accidents and their application

    in traditional workplace safety and health

    Graham D. Creedy, P. Eng, FCIC, FEICFormerly Senior Manager, Responsible Care

    Canadian Chemical Producers Association

    (now Chemistry Industry Association of Canada)

    [email protected]

    System Safety Society Spring Event

    May 26, 2011

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    2

    Overview

    How I got into this

    The evolution of the philosophy of

    industrial safety and prevention of majoraccidents

    Some key insights and concepts

    How these apply to management ofworkplace safety in various sectors and at

    different levels of the organization

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    3

    Some history

    1984 Bhopal accident is wake-up call tochemical industry

    Industry responsibility to understand and

    control hazards and risks Responsible Care launched in Canada

    Principles, codes, commitment, tools, support,

    progress tracking, verification Major Industrial Accidents Council of

    Canada 1987-1999

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    4

    Source: US Bureau of Labor Statistics (www.bls.gov/iif)

    0.0 2.0 4.0 6.0 8.0 10.0 12.0

    ServicesFinance, insurance & real estate

    Wholesale & retail trade

    Transportation & public utilit ies

    Petroleum and coal products

    Chemicals and allied products

    Printing & publishing

    Pulp & paper

    Textiles & apparel

    Food & food products

    Transportation equipment

    Electronic and electrical equipment

    Industrial machinery & equipment

    Primary metal industriesConstruction

    Mining

    Agriculture, forestry & fishing

    Safety Performance by Industry SectorInjuries & illnesses per 200,000 hours worked (2002)

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    5

    Relative risks of fatal accidents in the work

    place of selected occupationsFishers (as an occupation) 35.1

    Timber cutters (as an occupation) 29.7

    Airplane pilots (as an occupation) 14.9

    Garbage collectors 12.9

    Roofers 8.4

    Taxi drivers 8.2

    Farm occupations 6.5

    Protective services (fire fighters, police guards, etc.) 2.7

    Average job 1.0

    Grocery store employees 0.91

    Chemical and allied products 0.81

    Finance, insurance and real estate 0.23

    Sanders, R.E, J. Hazardous Materials 115 (2004) p143, citing Toscano (1997)

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    6

    CIAC website

    www.canadianchemistry.ca

    Staff contact: Stephanie Butler

    613-237-6215 x 245

    Chemistry Industry

    Association of Canada

    Member Performance

    http://www.canadianchemistry.ca/http://www.canadianchemistry.ca/
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    Serious/Disabling/Fatalities

    Medical Aid Case

    Property Loss/1st Aid

    Treatment

    Near Misses

    Unsafe Behaviors/Conditions

    Incident Pyramid:

    1

    30

    10

    600

    10,000

    A proactive approach focuses on thesecategories, but be carefulyou may

    miss the really serious ones!

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    Terminology

    Process hazard

    A physical situation with potential to cause

    harm to people, property or the environment

    Risk (acute)

    probability x consequencesof an undesiredevent occurring

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    They thought they were safe

    Good companies can belulled into a false sense ofsecurity by theirperformance in personalsafety and health

    They may not realise howvulnerable they are to amajor accident until ithappens

    Subsequent investigationstypically show that therewere multiple causes, andmany of these were knownlong before the event

    BP Deepwater Horizon

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    Why and how defences fail

    People often assume systems work asintended, despite warning signs

    Examples of good performance are cited as

    representing the whole, while poor ones areoverlooked or soon forgotten

    Analysis of failure modes and effects

    should include human and organizationalaspects as well as equipment, physical andIT systems

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    Process safety management

    Recognition of seriousness ofconsequences and mechanisms of

    causation lead to focus on the processrather than the individual worker

    Many of the key decisions influencingsafety may be beyond the control of theworker or even the sitethey may bemade by people at another site, country

    or organization

    Causes differ from those for personnelsafety

    Need to look at the wholematerials,

    equipment and systemsand considerindividuals and procedures as part of thesystem

    Management system approach forcontrol

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    Scope(elements of process safety management)

    1. Accountability

    2. Process Knowledge and Documentation

    3. Capital Project Review and Design Procedures

    4. Process Risk Management

    5. Management of Change

    6. Process and Equipment Integrity

    7. Human Factors

    8. Training and Performance

    9. Incident Investigation

    10. Company Standards, Codes and Regulations11. Audits and Corrective Actions

    12. Enhancement of Process Safety Knowledge

    CCPS: Guidelines for TechnicalManagement of Chemical Process Safety

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    Functions of a management system

    Planning Organizing

    Leadership

    Controlling Implementing

    M

    easuremen

    t

    Results

    Structure

    Direction

    CCPS: Guidelines for Technical Management of Chemical Process Safety

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    Features and characteristics of a management

    system for process safety

    PlanningExplicit goals and objectives

    Well-defined scopeClear-cut desired outputsConsideration of alternative achievementmechanismsWell-defined inputs and resource

    requirementsIdentification of needed tools and training

    OrganizingStrong sponsorshipClear lines of authority

    Explicit assignments of roles andresponsibilitiesFormal proceduresInternal coordination and communication

    ImplementingDetailed work plansSpecific milestones for accomplishmentsInitiating mechanisms

    ControllingPerformance standards andmeasurement methodsChecks and balancesPerformance measurement and reporting

    Internal reviewsVariance proceduresAudit mechanismsCorrective action mechanismsProcedure renewal and reauthorization

    CCPS: Guidelines for TechnicalManagement of Chemical Process Safety

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    Examples of PSM management systems concerns at

    different organizational levels

    CCPS: Guidelines for TechnicalManagement of Chemical Process Safety

    Planning

    PlanningOrganizing

    Planning

    Organizing

    Organizing

    ImplementingImplementing

    ControllingControllingControlling

    Strategic Managerial Task

    Self assessment of Current Status

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    Self-assessment of Current StatusProcess Safety Management

    Requirements to Achieve the ESSENTIAL Level

    For each survey question, indicate the level of awareness and use at the site by marking the appropriate box, based

    on the following:

    A Widespread and comprehensive use wherever significant hazard potential exists.

    B Moderate use, but coverage is uneven from unit to unit or not comprehensive in view of potential

    hazards.

    C Appropriate personnel are aware of this item and its application, but little or no actual use.

    D Little awareness or use of this item.

    Mark the box labeled "Help" if this is an item where you are in urgent need of guidance. Well have a team member

    contact you with advice on how and where to get the information or help.

    Want Current Status

    Help A B C D

    1. Accountability: Objectives and Goals

    (a) Are responsibilities clearly defined and communicated, with thoseresponsible held accountable?

    (b) Is there a system for control of contractor operations? 2. Process Knowledge and Documentation

    (a) Are the safety, health and environmental hazards of materials on site

    clearly defined?

    (b) Is there current comprehensive documentation covering the process

    operating basis, including both normal and abnormal conditions?

    3. Process Safety Review Procedures for Capital Projects

    (a) Are all project proposals for new or modified facilities subjected to

    documented hazard reviews before approval to proceed?

    (b) Are systems established to ensure that the facility is built as designed? (c) Is there an effective link between design modifications and operating

    procedures?

    4. Process Risk Management

    (a) Is there a system, conducted by competent personnel, to identify andassess the process hazards from materials present at this site?

    (b) Are corrective actions defined and implementation followed up? (c) Are the above items formally documented?

    A page from theSite Self-

    Assessment Tool

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    0

    20

    40

    60

    80

    100

    120

    140

    160

    2002

    (137 sites)

    2003

    (141 sites)

    2004

    (134 sites)

    2005

    (143 sites)

    2006

    (139 sites)

    2007

    (145 sites)

    2008

    (129 sites)

    Excellent

    Enhanced

    Essential

    Almost at Essential

    "In Progress"

    Use of self-assessment tool for

    collective progress reporting and action

    As of August 29, 2008 compared with past five years

    (some site changes)

    Target for meeting Essential level: June 30, 2003

    P R l t d I id t M (PRIM) 2007

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    Process-Related Incident Measure (PRIM) 2007

    Findings: All Elements

    PRIM INCIDENT CAUSE ANALYSIS 1998/1999 TO 2007

    05

    1015

    2025303540

    1Acco

    untability:O

    bjectiv

    es&G

    oals

    2Proc

    essKnow

    ledge

    &Docu

    m.

    3Capital

    ProjectR

    eview

    &De

    sign

    4Proc

    essRisk

    Manag

    ement

    5Manage

    mento

    fChan

    ge

    6Proc

    ess&Eq

    uipme

    ntInte

    grity

    7Hu

    manF

    actors

    8Trainin

    g&Pe

    rforma

    nce

    9Incident

    Investiga

    tion

    10Co

    mpany

    Standards

    /Code

    s/Re

    gs.

    11Au

    dits&Corre

    ctiveA

    ctions

    12En

    hancem

    entProcessS

    afetyK

    nowled

    ge

    PSM Element Possibly Involved

    Incidents

    Analyzed

    98/9920002001

    200220032004200520062007

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    Assessing an organizations safety effectiveness

    What is the safety policy and culture (written,unwritten)?

    How are the following handled? Establishing what has to be done

    Benchmarking

    Communicating

    Assigning accountabilities

    Ensuring that it gets done

    Monitoring and corrective action

    Evidence (documentation) and audit process

    Resourcingnot only for ideal but for anticipatedconditions

    Balancing with other priorities

    How are exceptions handled?

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    Consider targets in groups

    Those who:

    Dont care

    Dont know (and perhaps dont know that theydont know)

    Did know, but may have forgotten or could

    have gaps in application (and perhaps dont

    realize it)

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    Excellent guidance

    existsbut how is it

    being used?

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    The New Product Introduction Curve

    Can be applied to adoption of new ideas

    Categories differ by ability and more importantly, motivation

    P

    ercent

    a

    doption

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    Accountability

    Management commitment at all levels

    Status of process safety compared to otherorganizational objectives such as output, quality andcost

    Objectives must be supported by appropriate resources

    Be accessible for guidance, communicate and lead

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    Management of Change

    Change of process technology

    Change of facility

    Organizational changes

    Variance procedures Permanent changes

    Temporary changes

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    Process and Equipment Integrity

    Design to handle allanticipated conditions, not just ideal

    or typical ones

    Make sure what you get is what you designed

    (construction, installation)

    Test to make sure the design is indeed valid

    Make sure it stays that way

    Preventative maintenance

    Ongoing maintenance Review

    Be especial ly careful of automatic safeguards

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    Consider operator asfallible humanperforming tasks inbackground

    Design for errortolerance, not justprevention

    detection correction

    Buncefield, UK

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    Realization of significance of sociocultural factors in

    human thought processes and hence in behaviours

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    Human behaviour aspects

    People, and most organizations, dont

    intend to get hurt (have accidents) To understand why they do leads useventually into understanding humanbehaviour, both at the individual andorganizational level, and involves:

    Physical interface Ergonomics

    Psychological interface

    Perception, decision-making, control actions

    Human thought processes

    Basis for reaching decisions Ideal versus actual behaviour

    Social psychology

    Relationships with others

    Organizational behaviour

    Familiarity to

    engineers

    More

    Less

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    Human behaviour modes

    Instead of looking at the ways in which people can fail, look at how they

    function normally:

    Skill-based

    Rapid responses to internal states with only occasional attention to

    external info to check that events are going according to plan

    Often starts out as rule-based Rule-based

    IF, THEN

    Rules need not make sensethey only need to work, and one has

    to know the conditions under which a particular rule applies

    Knowledge-based Used when no rules apply but some appropriate action must be

    found

    Slowest, but most flexible

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    Reasons Cheese Model

    James Reason, presentation to Eurocontrol 2004

    2

    SSThe Swiss cheese model of

    organisational accidents

    Some holes due

    To active failures

    Other holes due to

    latent conditions

    Successive layers of defences

    Hazards

    Losses

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    Active and latent failures

    Active

    Immediately adverse effect

    Similar to unsafe act

    Latent

    Effect may not be noticeable for some time, if at all

    Similar to resident pathogen. Unforeseen trigger conditions

    could activate the pathogens and defences could be undermined

    or unexpectedly outflanked

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    A Classic Example of a Latent

    Failure

    Hazard of material

    known, but lack of

    awareness of potential

    system failure modeleads to defective

    procedure design

    through management

    decision

    Epichlorhydrin fire,

    Avonmouth, UK

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    Danvers, MA, Nov 2006

    Solvent explosion at printing ink factory

    US Chemical Safety Board

    And another

    Hazards known, but defencescompromised by apparently benignchange

    Latent error in procedure designcreates vulnerability to likely

    execution error

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    And another

    Hazard of material

    not obvious (despite

    history)

    Latent error allowed

    dust to accumulate,creating conditions

    for subsequent

    events

    Scottsbluff, NE 1996

    Port Wentworth, GA 2007

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    Lessons from other fields

    Aerospace andnuclearshow how significanthuman and organizational aspects can be evenwhere the obvious signs of failure are technicalin nature

    Financeshows: Relevance of such factors without technical

    distractions

    How fast a system can deteriorate once controls are

    relaxed How wrong risk assessments can influence bad policy

    decisions

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    The relevance of organizational factors has also been

    graphically and tragically revealed in the inquiry reports of recentUK transportation and offshore oil disasters.

    Prior to ..., senior managers in all the organizationspropounded the pre-eminence of safety. They believed in theefficacy of the regulatory system, in the adequacy of their existing

    programs, and in their confidence of the skills and motivation oftheir staff.

    The inquiry reports reveal that their belief in safety was amirage, their systems inadequate, and operator errors andviolations commonplace.

    The inquiry reports stated that ultimate responsibility laywith complacent directors and managers who had failed to ensurethat their good intentions were translated into a practical andmonitored reality. Moreover, the weaknesses so starkly revealedwere not matters of substantial concern to the regulatory

    authorities before the accidents. HSC, 1993

    Relevance of organizational factors

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    Factors that can influence

    likelihood of failure

    Organizational culture

    the way we do things around here when no-one is

    looking

    increasingly being recognized as one of the mostimportant factors in major accidents

    perceived balance between output, cost and safety is

    heavily dependent on this culture, and influences

    whether personnel work in a certain way because

    they believe the company and their co-workers feel it

    is the right way to do things, or whether they are

    simply going through the motions.

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    Standard

    of Safety

    Time

    In general, safety gets better as society learns more

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    Standard

    of Safety

    Time

    But the rate of improvement is not steady

    x 10

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    Standard

    of Safety

    Time

    In fact, the curve can be one of periodic rapid gains

    followed by gradual but increasing declines

    x 100

    Note how the rate

    of decay can be

    expected to

    increase due to

    normalization ofdeviance

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    People

    Systems

    Tribal

    Chaotic

    Operational

    Excellence

    Bureaucratic

    Strong

    Weak Strong

    Organizational Culture ModelJames W. Bayer, Senior VP Mfg, Lyondell Chemical Company

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    Demographic effects Less staff

    Experienced cohort leaving or left

    Skills transfer senior > (middle)> junior

    Replacements understand the way something isdone, but not why it is done that way, the potentialconsequences of doing it differently and how to detectand recover from undesired actions

    We are starting to see lowered standards ofdesign and supervision that fifteen years agowould have been unthinkable in the chemicalindustry (Challenger, 2004)

    Preservationor lossof corporate memory

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    Knowledge

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    Knowledge Never realized problem could occur (benchmarking error)

    was it treated as a unique deficiency?

    was there a broader review of the benchmarking process to find if there areother areas where knowledge could be deficient?

    Policy Thought situation would be acceptable but didnt realize full implications

    until it happened Does it appear to be acceptable now?

    Was review of policy and accountability limited or broad in scope?

    System design Even if everything had been done as intended, problem would still have

    occurred How comprehensive was analysis of system deficiencies and practicality of

    solutions?

    How effective is action plan and follow through?

    Was review of system design limited or broad in scope? System execution (management system error)

    Problem occurred because someone or something did not perform asintended

    Did analysis consider why execution not as intended?

    Was corrective action appropriate and balanced?

    Was review of system execution limited or broad in scope?

    D li ith S f t ( E i i ) P bl

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    Dealing with a Safety (or Engineering) Problem

    Finding out who youre dealing with

    Where is the organization on the curve? (generally, and re the specific issue orproblem)

    Where are the people youre dealing with on the curve? (generally, and re the issueor problem)

    Finding out what to do

    Benchmark dont try to reinvent the wheel unless youre sure there isnt onealready (or youve time and its fun to do so)

    Find out what others are doing about it

    Read the instructions Identify/define the issue

    If its likely to be regulated, check with government agencies, trade associations,web, internet

    If not regulated but likely good industry practice, check suppliers, other users ofsame material or item, other users of similar items, other industry contactsbuttest the info!!!(cross-check, ask if it makes sense)

    Check standard reference works, (Lees, CCPS, etc)

    Doing it

    Try to think of all situations that are likely to occur (process, eqpt, people)

    KISS, keep it user-friendly, show basis for decisions if practical to do so

    Follow up afterwards to see how its working

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    Questions?