How to Evaluate Process Safety Culture
GCPS 2010 __________________________________________________________________________ How to Evaluate Process Safety Culture Jerry J. Forest Lyondell Chemical Company a LyondellBasell company 2502 Sheldon Road, Channelview, TX [email protected] Prepared for Presentation at American Institute of Chemical Engineers 2010 Spring Meeting 6th Global Congress on Process Safety San Antonio, Texas March 22-24, 2010 UNPUBLISHED AIChE shall not be responsible for statements or opinions contained in papers or printed in its publications GCPS 2010 __________________________________________________________________________ How to Evaluate Process Safety Culture Jerry J. Forest Lyondell Chemical Company LyondellBasell Industries 2502 Sheldon Road, Channelview, TX [email protected] Keywords: Culture, Survey, Analysis Abstract At first glance it may seem that organizational culture is subjective and therefore difficult to measure. Indeed, even the definition of culture falls into the soft side of process safety. This paper will show that an objective approach can be taken to survey and define process safety culture. With this data gap analysis can be performed that compares survey data to CCPS essential elements of process safety. This gap analysis can be used to identify strengths and weaknesses so that process safety performance can be improved. The survey method used starts with the CCPS process safety pillars and categorizes questions according to the pillar elements, principles and essential features required for excellence. The appropriate data collecting technique is shown that will give statistically meaningful results. Examples are given of grouping results by safety pillar categories and demographics of the survey population. Finally, a gap analysis method is shown that compares the survey results to CCPS essential elements so that improvement plans can be made. GCPS 2010 __________________________________________________________________________ 1. Introduction Process safety is an encompassing term used to describe the activities that help prevent the catastrophic release of hazardous chemicals. These activities include: Collection of process safety information, process hazard analysis, management of change, pre-startup safety reviews, mechanical integrity and much more. There is a finite list of activities that describe process safety. Although these activities can be easily defined, process safety culture seems a bit more esoteric. The U.S. Chemical Safety and Hazard Investigation Board (CSB) has stated that organizational culture and structure can contribute as much to process safety events as immediate causes [5]. Indeed, the purpose of the Baker Panel Study of the Texas City event of 2005 was not to find root cause, but rather identify the values, beliefs and management assumptions that led to the event; their purpose was to evaluate process safety culture [1]. The term culture is often used to describe management systems, company behavior and process safety without really defining its meaning. How do we measure culture? How do we know if we have achieved a desired culture? This paper will provide a clear definition of culture in terms of a commonly held set of values, norms and beliefs. A method to objectively define process safety values and beliefs is given by benchmarking with published material from the Center for Chemical Process Safety (CCPS) is presented. A methodology to conduct a culture survey is then presented that allows for objective measurement of a company culture. This is followed by a description of how to analyze and interpret the results. 2. Definition of Culture Countries around the globe exhibit unique cultures. Groups of people within those countries sometimes have their own culture. Organizations are said to exhibit a culture. People hired into those organizations are often screened to ensure that they fit into the culture. Managers strive to develop a culture. We use this soft term frequently, but do we consider a definition when using it? Similarly, if the term isn’t defined, how can we develop it or measure our progress toward it? A useful definition that can be used to measure organizational culture is “a commonly held set of values, norms and beliefs that operate within the organization [4]”. Culture means that something must be held in common. This feels intuitively correct. People within a country are often identified with that country. They might look similar, talk similarly, and have common backgrounds. They are identified with that country. They may have physical traits and habits in common. Beyond these outward things, they may also have a common world view that has been shaped by similar personal, institutional, and historical perspectives. This background defines common beliefs and common values; it makes up the culture. GCPS 2010 __________________________________________________________________________ With this posit that culture is a commonly held set of values, norms and beliefs, what then is a process safety culture? How do we define a commonly held set of values and beliefs regarding process safety? 3. The Objective Benchmark Process safety professionals often deal with quantitative risk assessments that apply science, statistics and probability to determine if processes have acceptable risk based on an acceptance criterion. This is hard science and the results are knowable and repeatable. In order to develop the same repeatability with respect to development and measurement of culture, a methodology is required to convert the subjective definition of culture to something that can be objectively measured. CCPS categorizes activities for process safety into four broad groups that are useful as an objective measure: Commit to Process Safety, Understand Hazards and Risks, Manage Risks and Learn from Experience [3]. Each pillar is broken into various elements that must be in place to achieve excellence in process safety. Furthermore, the CCPS has defined underlying principles for each element and essential elements for each principle that represent objective actions that can be taken at a manufacturing site level so that process safety excellence is achieved. The process safety pillars, elements, principles and essential elements can be used to develop employee surveys that objectively measure values, norms and beliefs. Survey results are compared to the CCPS pillars to complete a gap analysis of process safety culture. 4. CCPS Pillars The first CCPS pillar, Commit to Process Safety, defines culture elements as: “Develop a process safety culture, compliance to process safety standards, develop a process safety competency, and involve the workforce”. Consider that by themselves the elements do not represent the whole of process safety activities and culture. Development of an objective process safety culture measurement considers all of the pillars as they represent the total of process safety management. A summary of the pillars, elements and principles is shown in table 1. Appendix 1 gives a more detailed version of the summary with essential activities shown for each principle. Please note that this summary deviates slightly from the principles and essential elements shown in the CCPS book, Guidelines for Risk Based Process Safety. In the development of an appropriate objective basis upon which to measure process safety, certain principles and essential elements have been eliminated or modified, as they were either redundant or were not applicable to my organization. However, the point should be clear. CCPS has gone beyond the traditional 14 elements of process safety suggested by OSHA in the 1910.119 regulation and grouped those elements, as well as others recognized by industry that contribute to success in process safety, into four categories or pillars. Each pillar has several elements and each element has several principles. The activities that we perform to ensure that the principles are in place and effective become the objective standard we can use to measure our process safety culture. These activities are compared to the essential elements to complete a gap analysis. Since culture is a set of commonly held values and beliefs, understanding the workforce’s thoughts and attitudes against this objective measure should provide a clear indication of the process safety culture. GCPS 2010 __________________________________________________________________________ Table 1 – CCPS Pillars, Elements and Principles CCPS Pillars & Elements Principles Commit to Process Safety Develop a Process Safety Culture Compliance with Process Safety Standards Process safety Competency Workforce Involvement PS as a core value; strong leadership; highperformance standards; zero tolerance for willful violations; reward PS performance Standard owners Improve knowledge; up-to-date PSI; apply learning’s Competent personnel; work activities Understand Hazards & Risks Process Knowledge Management Hazard Identification & Risk Analysis Catalog process knowledge; protect & update knowledge; use process knowledge ID hazards & evaluate risks; assess risks and make risk-based decisions; complete assessment results Manage Risk Operating Procedures Safe Work Practices Asset Integrity and Reliability Contractor Management Training Management of Change Operational Readiness Conduct of Operations Emergency Management ID procedures required; develop procedures; use procedures to improve human performance; ensure procedures are maintained Control non-routine work ID in-scope equipment; maintain knowledge, skills, procedures and tools; ensure continued fitness for purpose; address equipment failures, analyze data Conduct work activities; monitor contractor management system ID required training; provide effective training, monitor worker performance ID potential change; evaluate impacts; decide whether to allow the change; complete follow-up activities Conduct appropriate reviews; follow through on decisions, actions, and use of readiness data Control operations activities; control the status of systems and equipment; develop required skills & behaviors; monitor organizational performance Prepare for emergencies; periodically test the adequacy of plans and level of preparedness Learn from Experience Incident Investigation Metrics Audits Management Review & Improvement ID potential incidents for investigation; use appropriate techniques to investigate incidents Conduct metrics acquisition; use metrics to make corrective action decisions Conduct element work activities; use audits to enhance RBPS effectiveness Conduct review activities; monitor organizational performance GCPS 2010 __________________________________________________________________________ 5. Survey Considerations Before selecting the objective survey questions with the pillars as the basis, a few mechanical items regarding the survey should be addressed. These include the length of the survey, target audience, participation reminders, length of time for open response, method of delivery, how data is analyzed, anonymity of response and several others. A first consideration in the survey design is convincing the organization that the results will be meaningful, anonymous, shared, and action taken on the outcome if appropriate. How this is accomplished is a function of the size and scope of the survey. A common consideration is simple communication to effective parties that a survey is coming, the contents, and how the data will be used. Depending upon the size of the survey and population of the organization, a steering team might be considered that can then have influence over leaders in spreading the word. As engineers we sometimes default to gathering as much data as we possibly can so that we can analyze, trend, draw conclusions and make the best decisions. However, in a survey we must be considerate of the data source - people. If it takes too long to complete a survey, people either will not participate, or will not put a lot of thought into their answers. A good rule of thumb is to keep the survey length such that the average person can complete it in 20 – 30 minutes, with 45 minutes being the maximum. Depending upon the type of questions in the survey, consider that it may take the average person 30 seconds to 1 minute per question to complete. Of course, participants could be forced to participate, but that approach in itself might be a good indicator of process safety culture! Another key consideration in survey participation is identification of the target audience. For which group do you want to measure perception of culture: management, office workers, craftsmen, union employees, contractors, other or all? In making this decision, a rule of thumb to consider is that a 20 – 30% participation rate should be expected. This brings up another survey design consideration – participation reminders and length of time that the survey should remain open for response. The survey should be held open long enough to ensure the target participation audience has a chance to participate, but not so long that it is perceived as not important or can be delayed (and forgotten about) until much later. Another rule of thumb is to keep the survey open for approximately three weeks. Weekly reminders should be sent to survey participants (and their supervisors) to ensure maximum participation. In recent corporate surveys, reminders have helped boost participation rates to >75%. Assuming that we are interested in understanding the perceptions of the entire demographic of the organization, the next decision is to identify who actually takes the survey. That decision is best left to your particular organization. However, there are a few things to consider. If the delivery method is electronic or web-based, opening the survey up to all employees may be feasible since all data is collected electronically. While this approach leads to the most data being collected, it may lead to different proportions of participation among the various demographic groups. Comparison of data among those groups to determine independence would GCPS 2010 __________________________________________________________________________ involve hypothesis testing. If your organization has a master black belt, they can help design the data collection and analysis. Another approach is to select a statistically meaningful sample of workers from each group to complete the survey. This approach may lead to a smaller sample size, but one that you might have a little more control over in terms of participation. A final word about method of delivery; consider that if paper ballots are used, people have a tendency toward illegible handwriting. Gathering paper ballots and consolidating to electronic media for analysis can be a huge task and may open up the process to error in transcription. A single webbased electronic database should be used if at all possible. The type of data analysis of the survey should be decided upon before the survey is designed. At the most basic level, descriptive statistics and graphical analysis is done in order to draw conclusions on the survey data. However, if your objective is to compare results across demographic groups, then inferential statistics must be used. A six-sigma black belt should be consulted in survey design and for the data interpretation. As indicated there are a number of mechanics questions that should be addressed in the survey design phase. The list briefly discussed here is not inclusive, but rather is presented to give you a few things to think about that might be unique to your organization. The main point here is that these items should be addressed before the survey is pushed to the participants. 6. Survey Question Design As with any good survey, the design is critical to data analysis. Therefore as Steven R. Covey states in 7 Habits, begin with the end in mind [4]. In this context, first define the objective of the survey and then define the questions. There are many process safety key process indicators that make up great data to describe the health of the process safety system. The CCPS has recently published Guidelines for Process Safety Metrics [2]. Examples include number of open PHA items, number of past due audit items, time involved for various MOC phases, and many, many more. If that data is valuable and part of your objective, then indeed by all means collect it. However, keep in mind that this type of objective data only infers the process safety culture by identifying gaps in the management system. In the first section of this paper process safety culture is defined as a set of values and beliefs about process safety. That is the primary objective of this survey. 7. Question Selection An objective basis from which to select questions are the CCPS process safety pillars. Appendix 1 summarizes the essential elements appropriate for an organization to use in order to test perceptions and beliefs about how the organization is performing in that area of process safety. It is a simple matter to develop questions based on the particular essential element/ principle being tested. For example, Figure 1 shows the elements underlying Commit to Process Safety as: “Develop a process safety culture, compliance with process safety standards, process safety competency, and workforce involvement.” Consider “develop culture”, for example; the principles CCPS defines are: “Establish process safety as a core value, provide strong leadership, establish and enforce high standards of performance, zero tolerance for willful violations of GCPS 2010 __________________________________________________________________________ process safety policies, and process safety is rewarded.” Finally, the essential elements for high standards are defined as “establish, communicate and monitor process safety goals and establish responsibility for process safety roles.” We might choose to test those essential elements to develop questions with a Likert1 scale such as “My site has clearly defined roles and responsibilities defined for process safety.” There is more detail about Likert scales below. Thus, by systematically addressing each essential element of the principles associated with each CCPS process safety element, an objective question bank can be developed. Figure 1 – Relating questions to essential element Survey Design Pillar Commit to Process Safety Understand Hazards & Risks Element Develop a PS Culture Compliance with PS Standards PS Competency Workforce Involvement | www.lyondellbasell.com | Global Process Safety Survey Manage Risk Learn from Experience Principle Essential Element Establish PS as a core value Establish , communicate & monitor PS goals Provide strong leadership Establish and enforce high standards of performance Zero Tolerance for willful violations of PS policies PS performance is rewarded Establish responsibilities for PS roles Question(s) 9. My site has clear roles and responsibilities defined for standard (procedure) owners 3 Appendix 2 is an example of one such bank of questions that surveys across each of the four pillars. The questions are clearly tied to essential elements, principles, elements and pillars for data analysis. Also note that the appendix shows the questions broken down into two sets of surveys in order to keep the length of each survey manageable. When measuring the process safety culture of your organization, the essential elements of each principle can be used to develop questions for analysis. 8. Question Design A simple question design uses a five-point Likert scale: strongly agree, agree, neither agree nor disagree, disagree, or strongly disagree. Participants are asked to rate their level of agreement with the question. While question selection allows us to objectively organize the data into process safety elements, the Likert scale allows us to objectively analyze subjective notions such 1 A Likert scale is commonly used in questionnaires to measure level of agreement or disagreement with subjective data. Level of agreement is measured by selection of phrases such as: Strongly agree, agree, disagree, and strongly disagree. GCPS 2010 __________________________________________________________________________ as perception of agreement with process safety. In designing Likert scale questions, mixing question types is not recommended. As stated above, you may also wish to collect a second class of data such as process safety metrics. A third type of data to collect is open-ended questions. Many people prefer to give their opinion, so when faced with rigid questions in Likert format they can become frustrated because they have not been given the opportunity to say what they really think. There may be value in adding three open-ended questions: What should we start doing that we presently are not, what should we stop doing and what should we continue to do? These questions originate from Steven R. Covey quality seminars given in 1990. The questions are straightforward, to the point, and tell us much information about trends in thinking. Analysis of this data is discussed below. A final category of data is demographic data. Again, beginning with the end in mind, we need to know how we’ll use demographic data in the analysis so that we ask the right questions. But also note, asking too much demographic data might give the appearance that the survey isn’t anonymous (if that is your intent.) This type of data usually isn’t a problem and is quite valuable in comparing group perceptions. 9. Data Analysis – Likert Scale Questions An objective analysis of the data can be made by summing the number of responses in each category and converting to a percentage by category. Subsequent graphical analysis of the percentages will then be a fair representation of degree of agreement for each question. Graphical analysis can be done by demographic segment, for each question, process safety principle, element and pillar. Table 2 is an example table that sums the data and calculates percentage. Table 2 – Data Analysis of Likert Scale Commit to Process Safety: Process Safety Culture: Core Value 1. My Site has a documented process safety vision, mission, and strategic plan Disagree Neither Agree nor Disagree Agree Strongly Agree Total Strongly Disagree Disagree Neither Agree nor Disagree Agree Strongly Agree Percent of Response Strongly Disagree Sum of Responses 4 7 15 26 8 60 7% 12% 25% 43% 13% This is done for each question. Since each question is already categorized by principle, element and pillar, the data can be rolled-up for each level of analysis. Herein demonstrates the value of a database. Responses are categorized by demographic group and questions are categorized by principle, element and pillar. A well-designed database can easily manipulate the responses to calculate the percentages, convert to descriptive statistics, and graph results. Note, even Microsoft Excel can be used with pivot table or force table manipulation to accomplish the same result. GCPS 2010 __________________________________________________________________________ Once pivot or data tables are created, graphical analysis can be done. For a Likert scale, simple 100% stacked bar charts visually represent percent agreement of questions by demographic grouping rolled-up to whatever objective level of the pillars is desired. Appendix 3 shows examples of stacked bar charts for these various data groupings. 10. Data Analysis – Open Ended Questions Analysis of the open-ended survey questions is a bit more difficult, but can be done. When asking the Steven R. Covey survey questions, the responses can typically be categorized into groups. Read the responses a few times until obvious groupings can be made. Count the number of responses in each group. The number of responses in each group represents a frequency that can be graphed. Table 3 is an example of the group roll-up and Figure 2 shows an example graph of that data. Table 3 – Open Ended Question categorization Group/ Category # Responses in this category Metrics 1 HSEQ Integration 2 Mechanical Integrity 2 Audits 2 Training 2 Process Safety Systems Safety Critical Variables Incident Reporting Leadership 3 3 3 4 Awareness MOC PHA Other 5 5 6 7 Employee Participation 14 GCPS 2010 __________________________________________________________________________ Figure 2 Example of open-ended graphic Of course, with the Likert questions in tabular format descriptive statistics such as mean, mode, median, standard deviation and others can easily be calculated by CCPS group or demographic, or any combination thereof. As mentioned above, inferential statistics such as Chi-squared tests could also be performed to determine independence among group perceptions regarding process safety culture. The inferential statistical discussion is beyond the scope of this paper. 11. Gap Analysis & SWOT Once the descriptive statistics are complete, a second type of analysis can be done with the data that helps management draw conclusions and make action plans for improvement. The second analysis is an objective gap analysis of survey responses to CCPS pillars, followed by a strategic planning tool called SWOT, an acronym that stands for Strengths, Weaknesses, Opportunities, Threats. Since we have grouped our questions by principles, elements and pillars, the gap analysis is very straight forward. The first step is to add and order the percent positive responses defined as the sum of strongly agree and agree, and sort the answers ascending. In the sorting of the data, be sure to include each questions attribute of CCPS pillar, element and principle. When this sorting exercise is complete, the data can then be grouped by quartile or percentage, or individual principle to determine the perceived gap in process safety culture. When doing this type of analysis, the data will logically group by element and principle clearly showing management direction for improvement. Table 4 shows a hypothetical gap analysis of survey response to CCPS essential feature. In this example, the survey responses have the lowest percent positive response from essential features underlying commit to process safety pillar. Table 4 – Gap Analysis Essential Feature Develop, document, and communicate vision and principles Question %Positive Gap Response 1.1 30 Sites don’t have consistent documented vision and GCPS 2010 __________________________________________________________________________ Training/ communication to front line supervisors 1.15 37 Establish and administer reward system Educate managers in process safety culture 1.7 1.2 45 48 principles Demographic group 1 response is more negative than demographic group 2 No consistent reward system Demographic group 1 response is more negative than demographic group 2. No corporate training Appendix 4 shows an expanded hypothetical simplified summary of a gap analysis completed for the CCPS pillars, elements, and principles done by sorting the most negative responses of the essential feature survey response questions. It’s clear that the majority of responses in this hypothetical example came from the pillar Commit, indicating cultural gaps in management commitment to process safety culture. 12. Conclusion Culture is a soft term used to describe an organization’s commonly held values, norms and beliefs. While values and beliefs may seem subjective in nature, objective descriptions can be defined for the various elements and principles of process safety that are widely recognized by industry. An objective benchmark is the CCPS process safety pillars of: Commit to process safety, Understand Hazards & Risks, Manage Risks, and Learn from Experience. Each pillar has defined elements and each element has defined principles. Underlying each principle are various essential features to achieve excellence in process safety. In order to measure people’s views on culture the CCPS essential feature activities associated with each process safety pillar can be used as a basis to develop survey questions. Survey questions designed with a Likert scale that measures degree of agreement to the question produce objective data. These numbers can then be used to obtain descriptive statistics and graphical analysis. Since the basis of the objective questions is industry-recognized activities from CCPS pillars, gap analysis of the responses to essential features can be performed. Data is organized by sorting survey responses by most positive to least positive. The least positive responses indicate that the organization perceives gaps in those areas of process safety. These responses become a basis for continuous improvement in process safety. GCPS 2010 __________________________________________________________________________ 13. References [1] The B.P. U.S. Refineries Independent Safety Review Panel, Baker et al, The Report of the BP U. S. Refineries Independent Safety Review Panel. January, 2007 [2] Center for Chemical Process Safety, Guidelines for Process Safety Metrics. American Institute of Chemical Engineers, 2010 [3] Center for Chemical Process Safety, Guidelines for Risk Based Process Safety. American Institute of Chemical Engineers, 2007 [4] Covey, Steven R, The 7 Habits of Highly Effective People. Simon & Schuster, New York, 1990 [4] Lawyer, John W., John J. Lawyer, A Systems Approach for Ministers. Loyola’s Institute for Ministry, New Orleans: 1986 [5] U. S. Chemical Safety and Hazard Investigation Board, Investigation Report Refinery Explosion and Fire. Report No. 2005-04-I-TX, March 2007 GCPS 2010 __________________________________________________________________________ 14. Appendix 1 – Summary of CCPS Pillars, Elements, Principles, & Essential Elements Pillar Element Commit to Process Safety: Organization fully supports Develop Process Safety Culture Principle Establish PS as a core value Develop, document, and communicate vision, CSF's, and principles Provide Strong Leadership Educate managers in PS culture w/ formal training program Zero tolerance for willful violations of PS policies Share PS responsibilities among managers - provide standard owners Establish, communicate & monitor PS goals Establish responsibilities for PS roles Establish formal policy deviation procedures PS performance is rewarded Establish & administer reward system Develop standard owners Develop procedures list & document management system Establish and enforce high standards of performance Compliance with PS Standards Essential Feature Assign & educate procedure owners on roles & responsibilities Conduct periodic performance-based audits and annual system audits. Report to management PS Competency Continuously improve knowledge Create technology stewards Document tech manuals including process history, incident learning, process reports PSI available & up to date Consistently apply learning’s Create PSI matrix, ID gaps, and close. Hyperlink with operating manuals Unit specific training for managers & superintendent/ supervisors on Hazards & Controls Evergreen Incident Learning periodic review GCPS 2010 __________________________________________________________________________ Pillar Element Workforce Involvement Principle Involve Competent Personnel Work Activities Understand Hazards & Risks Process Knowledge Management Hazard identification & Risk Analysis Maintain a Dependable Practice Catalog Process Knowledge Protect & Update Process Knowledge Use Process Knowledge Maintain a Dependable Practice Identify Hazards and Evaluate Risks Assess Risks and make riskbased decisions Follow through on the assessment results Essential Feature Tailgates: Present incident review, incident learning review, PHA risk review Senior people involved in PHA Training/ Communication to PSM supervisors Performance Based PSM inspections PSM/ PHA scenario based drills Web -based PS survey Formal written policy for governing knowledge element Standardize & catalog PSI Periodically review PSI Manage Change to PSI Train, insure PSI awareness Document the intended risk system Involve competent personnel Select appropriate risk methods Ensure reviewers have expertise Document & report Apply the risk tolerance criteria Select appropriate risk control measures Communicate results to management Document the residual risk Resolve recommendations and track completion of actions Communicate results internally Communicate results externally Maintain risk assessment records Manage Risk Operating Procedures Identify What Operating Procedures are Needed Develop Procedures Address all operating modes Appropriate format GCPS 2010 __________________________________________________________________________ Pillar Element Principle Essential Feature Address safe operating limits and consequences of deviation from safe operating limits Address limiting conditions for operations Supplement procedures with checklists Make Effective use of pictures and diagrams Address non-routine or temporary operations Validate procedures Use the Procedures to Improve Human Performance Use Procedures when training Hold the organization accountable for consistently following procedures Ensure procedures are available Ensure the Procedures are Maintained Safe Work Practices Control non-routine work activities Asset Integrity and Reliability Identify equipment that is in scope Maintain knowledge, skills, procedures and tools Ensure continued fitness for purpose Manage Changes Correct errors Periodically review Develop safe work procedures Train Employees and contractors Performance Based safe work audits Identify the PM program Develop procedures for inspection, test, repair, and other critical maintenance activities Train Employees and contractors Ensure inspectors hold appropriate certifications Provide the right tools Conduct initial inspections and tests as part of plant commissioning GCPS 2010 __________________________________________________________________________ Pillar Element Principle Essential Feature Conduct test and inspections during operations Execute calibration, adjustment, preventive maintenance, and repair activities Plan, control, and execute maintenance activities Ensure the quality of repair parts and maintenance materials Address Equipment Failures and Deficiencies Analyze data Contractor Management Conduct Element work activities Ensure overhauls, repairs and tests do not undermine safety Promptly address conditions that can lead to failure Examine results to identify broader issues Investigate chronic failures using a structured methodology Plan maintenance and repair activities Collect and analyze data Adjust inspection frequencies and methods Conduct additional inspections or tests as needed Plan replacements or other corrective actions Archive data Appropriately select contractors Establish expectations, roles, and responsibilities for safety program implementation and performance Ensure contractors are trained Training Monitor the Contractor Management System for Effectiveness Identify What Training is Needed Audit the contractor selection process Conduct a job/task analysis GCPS 2010 __________________________________________________________________________ Pillar Element Principle Provide Effective Training Monitor Worker Performance Management of Change Identify Potential Change situations Essential Feature Determine minimum requirements for job candidates Determine what training is needed Group training into logical programs Manage Changes Develop or procure training materials Interweave related topics Qualify workers initially Test workers periodically Define scope of MOC system Manage all sources of change Evaluate Possible Impacts Provide appropriate input information to manage changes Apply appropriate technical rigor for the MOC review process Ensure that MOC reviewers have appropriate expertise and tools Decide whether to allow the change Authorize changes Ensure that change authorizers address important issues Complete follow-up activities Operational Readiness Conduct Appropriate Readiness Reviews as Needed Make Startup Decisions Based on Readiness Results Conduct of Operations Follow through on Decisions, Actions, and Use of Readiness Results Control Operations Activities Update PSI Communicate changes to affected personnel Ensure appropriate elements are in PSSR Document PSSRs ID & Communicate risk based analysis of startup decisions Enact risk control measures Follow safe work practices Use qualified workers GCPS 2010 __________________________________________________________________________ Pillar Element Principle Essential Feature Assign adequate resources Formalize communications between workers Formalize communications between shifts Formalize communications between work groups Adhere to safe operating limits and limiting conditions for operation Control the Status of Systems and Equipment Develop Required Skills/ Behaviors Control access and occupancy Formalize equipment/asset ownership Monitor equipment status Maintain good housekeeping Maintain labeling Maintain lighting Maintain instruments and tools Emphasize observation and attention to detail Promote questioning/ learning attitude Train workers to recognize hazards Train workers to self-check and peer-check Establish standards of conduct Monitor Organizational Performance Emergency Management Prepare for Emergencies Maintain accountability Strive to improve Maintain fitness for duty Conduct field inspections Correct deviations immediately Identify accident scenarios based on hazards Provide facilities and equipment Determine when unit operator response is appropriate Train ERT members Plan communications Inform and train all personnel GCPS 2010 __________________________________________________________________________ Pillar Element Principle Periodically Test the Adequacy of Plans and Level of Preparedness Essential Feature Conduct emergency evacuation and emergency response drills Conduct tabletop exercises Practice crisis communication Learn from Experience Incident Investigation Identify Potential Incidents for Investigation Use Appropriate Techniques to Investigate Incidents Metrics Conduct Metrics Acquisition Audits Use Metrics to Make Element Corrective Action Decisions Maintain a Dependable Practice Conduct Element work activities Critique exercises, drills and actual responses Monitor all sources of potential incidents Ensure all incidents are reported Initiate investigations promptly Collect appropriate data during the investigation Interface with the emergency management element Use effective data collection methods Use appropriate techniques for data analysis Investigate causes to an appropriate depth Demand technical rigor in the investigation process Provide personnel with appropriate expertise and tools Develop effective recommendations Implement appropriate element metrics Collect & refresh metrics Summarize & communicate metrics in a useful format Use the metrics to improve process safety Ensure consistent implementation Involve competent personnel Identify when audits are needed Prepare for audits Determine audit scope & schedule GCPS 2010 __________________________________________________________________________ Pillar Element Principle Management review & Improvement Use Audits to Enhance RBPS Effectiveness Maintain a Dependable Practice Conduct Review Activities Monitor Organizational Performance Essential Feature Assemble the team Assign responsibilities Gather advanced information Plan onsite activities Conduct audits Document the audit Address audit findings and recommendations Share best practices Define roles and responsibilities Establish standards for performance Validate program effectiveness Determine scope of review Conduct & document reviews Strive to continuously improve Conduct field inspections GCPS 2010 __________________________________________________________________________ 15. Appendix 2 – Sample Survey Questions 15.1 Survey No. 1 – Commit, Understand, Learn & Open Element Principle Essential Element Question Pillar: Commit to Process Safety PS Culture Core Value 1. My site has a documented process safety vision, mission, and strategic plan Leadership 2. Leaders at my site receive initial and periodic Process Safety Training 3. Leaders at my site have defined Process Safety Responsibilities Performance Standards 4. My site has established Process Safety goals Zero Tolerance of violations 5. My site has formal written Process Safety Policies. 6. My site has a formal policy deviation process Compliance with Standards PS is rewarded 7. A formal reward system is in place to recognize process safety accomplishments, goals, and performance Standard Owners 8. My site has Process Safety standard (procedure) owners 9. My site has clear roles and responsibilities defined for standard (procedure) owners PS Competency Improve knowledge 10. My site has a defined technology steward(s) 11. Processes at my site have written technology manuals Workforce involvement PSI 12. Process Safety information is defined, controlled, and up to date Learning’s Competent Personnel 13. Learning’s from incidents are archived and periodically reviewed with operators, technicians, craftsmen, and contractors 14. What is the average experience level in years of your sites PHA participants GCPS 2010 __________________________________________________________________________ Element Principle Essential Element Question 15. At my site, all personnel are trained in all aspects of process safety Pillar: Understand Hazards & Risks Hazard Identification & Risk Management Identify Hazards and Evaluate Risks 16. A risk based approach is used for my site's PHA's. (Risk based = defining frequency and magnitude of consequence in order to mitigate to acceptable frequency/ magnitude) 17. My site uses a HAZOP, Fault-Tree, OSS, or more rigorous methodology for PHA 18. PHA's are redone or revalidated every 5 years PHA Results 19. Residual risk from the PHA are documented 20. PHA results are communicated to all affected personnel. Pillar: Learn from Experience Incident Investigation Identify incidents 21. At my site, all near misses and incidents are reported Investigate incidents 22. Regarding incident investigation, at my site: Metrics Metrics 23. My site has defined process safety metrics, collects data and periodically reports results to management for corrective action Audits Work activities 24. My site keeps a multi-year schedule of process safety audits and follows that schedule 25. Process Safety audit findings are documented. Each recommendation has an owner and assigned due date. 26. Management periodically reviews progress toward completion of audit recommendations Management Review & Improvement Review Activities 27. Management at my site conducts a formal periodic review of all process safety activities GCPS 2010 __________________________________________________________________________ Element Principle Monitor Organizational Performance Essential Element Question 28. Periodic field inspections of process safety systems are in place “Steven R. Covey” Open-ended questions 29. The most positive thing about my sites process safety system is: 30. The single thing I would stop doing or change about my sites process safety systems is: Demographic & Misc Information 34. Site 31. How is Process Safety Defined at your site? 32. This site has defined knowledge and experience requirements for line management positions reporting to the site (plant) manager in operations, technical, and maintenance functions 33. This site has a process in place to check that work orders not requiring a process safety review are simply repairs or "replacement in kind." 35. Enter the number of full time process safety resources at your site: 36. Enter the number of full time equivalent process safety resources at your site: 37. Estimate percent of time part-time process safety resources spend on process safety: 15.2 Survey No. 2 – Manage Risks Element Principle Essential Element Questions Pillar: Manage Risks Operating Procedures ID What procedures are needed 1. My sites operating procedures address all operating modes including: startup, shutdown, normal operation, emergency operation, startup from turnaround, etc. (Answer Strongly Disagree if your site does not have operating procedures) Develop procedures 2. Safe operating limits and consequences of deviation from safety operating limits are defined in operating procedures. 3. Non-routine and transient operating conditions are addressed in the operating procedures. 4. The content of my sites operating procedures is validated annually for correct content. GCPS 2010 __________________________________________________________________________ Asset Integrity & Reliability Human Performance 5. Operating procedures are used for operator/ technician training Procedures are maintained 6. Changes to operating procedures are included as part of the MOC and PHA process. Maintain KSA 7. My site has written procedures for inspection, test, repair and other critical maintenance activities Continued Fitness 8. My site performs and documents initial inspections of new equipment as part of commissioning 9. My site conducts a structured test and inspection program during operations Contractor Management Work Activities 10. Contractors are treated like our employees with regard to process hazard analysis, management of change, access to process safety information, and incident reporting and investigation Management of Change Identify changes 11. All changes at my site are managed through a process safety management of change system Evaluate Impacts 12. An appropriate level of risk assessment is always done for management of change (e.g., HAZOP, etc) Follow-up 13. Process Safety information is updated in a timely manner as a result of management of change 14. All affected personnel are notified and trained on changes Operational Readiness PSSR 15. A Pre-Startup safety review is required for all management of change Conduct of Operations Control of Operations Activities 16. My site has a formalized communication process between operating shifts 17. There is a process to adhere to safe operating limits Control the Status of Systems and Equipment 18. Our site has a formal effective housekeeping program 19. All equipment at my site is clearly labeled Develop skills/ behaviors 20. There is a formal hazard recognition program at my site GCPS 2010 __________________________________________________________________________ Emergency Management Monitor performance 21. There is a formal fitness for duty program at my site. Prepare for Emergencies 22. Emergency drills are based on scenarios identified in the process hazard analysis 23. My site has a fully staffed emergency response team Periodically test preparedness 24. Emergency evacuation and response drills are periodically performed at my site. 25. Tabletop exercises are routinely performed at my site. 26. There is a formal critique system of emergency drills and exercises GCPS 2010 __________________________________________________________________________ 16. Appendix 3 – Example Bar Charts 16.1 High Level Responses by Pillar 16.2 Second Level Responses by Element GCPS 2010 __________________________________________________________________________ 16.3 Third Level Response by Principle 16.4 Fourth Level Response by Essential Element Question GCPS 2010 __________________________________________________________________________ 16.5 Responses by Demographic GCPS 2010 __________________________________________________________________________ 17. Appendix 4 – Survey Gap Analysis Pillar Commit to Process Safety: Organization fully supports Commit to Process Safety: Organization fully supports Commit to Process Safety: Organization fully supports Commit to Process Safety: Organization fully supports Commit to Process Safety: Organization fully supports Learn from Experience Element Develop Process Safety Culture Essential Feature Develop, document, and communicate vision, CSF's, and principles 1.7 1.2 Demographic group 1 sites are more negative than Demographic group 1. No corporate training. Develop Process Safety Culture Provide Strong Leadership Educate managers in PS culture w/ formal training program Manage Risk Understand Hazards & Risks Emergency Management Hazard identification & Risk Analysis Sites don't have consistent documented vision, CSF's, and principles 1.15 Establish & administer reward system Develop Procedures Prepare for Emergencies Periodically Test the Adequacy of Plans and Level of Preparedness Identify Hazards and Evaluate Risks 1.1 Gap/ Comment Demographic group 1 response is more negative than group 2 response on PS training This question has the largest negative response indicating that rewards are not attached to process safety PS performance is rewarded PSI available & up to date Conduct Review Activities Complete follow-up activities Question Training/ Communication to PSM supervisors Develop Process Safety Culture Manage Risk Manage Risk Establish PS as a core value Workforce Involvement PS Competency Management review & Improvement Management of Change Operating Procedures Emergency Management Manage Risk Principle Create PSI matrix, ID gaps, and close. Hyperlink with operating manuals Conduct & document reviews 1.27 Update PSI 2.13 Validate procedures Identify accident scenarios based on hazards 2.4 Conduct tabletop exercises Select appropriate risk methods 12 2.22 2.25 1.16,1.17,1.18 Demographic group 1 response is much more negative than group 2. Site management review of PS activities ~50% of sites reporting PSI not updated in a timely manner ~50% of sites not validating procedures PHA results used as emergency scenarios Low tabletop drill participation 30% of sites are not validating PHA's in 5yr period or less.
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