Key points
If the last 12 months have taught us anything it is that life is not certain. Things can change in the blink of an eye and those changes could be within our control or imposed on us.
Responding well to those changes can mean the difference between thriving or becoming overwhelmed and for a business this can mean the difference between staying in business or shutting up shop. In this article I will document one key principle which could be applied to every day decision making to help make your risk management more resilient to avoid surprises coming from within.
Inherent safety is not just for concept selection
As a process safety engineer I use the inherent safety principles to almost every decision I make, and as a minimum to the most important ones. The application of these principles has stood me in good stead as well as the assets and projects I work on. Training yourself in these four questions as well as those who come to you for approval can help instil a basic drive within your organisation to ‘know what could happen’ and ‘how we manage it’.
Before you start on this journey the question you need to ask yourself is what is the worst that could happen? If it is that your pencil will fall off the table because you didn’t put it in the pen holder then perhaps you can live with that outcome.
If it is that someone could be prevented from returning to their family at the end of the day, then this is maybe something useful for you. When asking yourself what could go wrong make sure that all categories of risk are listed, not only the ones you normally talk about.
Eliminate
The first point is to ask yourself if the hazard could be eliminated. If hazard is an activity, you would ask yourself if this activity could be eliminated and the objective still achieved. If this is a hazardous substance, for example storage of a volatile intermediate, then you could ask yourself if the storage of the intermediate could be eliminated.
For example, by making the process continuous. Another great example of an opportunity to eliminate the hazard is by placing buildings (temporary and permanent) out of harm’s way. Thereby eliminating the potential that a process or industrial incident can impact the people in the building.
Minimise
Often it is impossible to eliminate the hazard or hazardous activity and still achieve the objective, we cannot produce oil and gas without drilling for example. In which case the next question is to ask if all measures have been taken to minimise the hazard or activity.
For example, if you are building a large offshore structure and the hazardous activity identified is working at height, has all effort been made to minimise the working at height? Is it possible to complete the construction in a different sequence which would minimise the risk to workers?
In the case of a hazard this is especially applicable to storage, and it would be easy to ask if storage capacity of hazardous materials has been minimised to only what is needed. Are you storing something which used to be used in your process but is no longer used, then ask if this could be minimised or even potentially eliminated?
When it comes to process equipment the best example of being able to minimise the hazard is to reduce the potential for overpressure. For example, when applying a pre-charge to a pulsation dampener the risk of rupture could be minimised by using a source which is no greater than 1.5 times the design pressure of the system.
Or in the design phase the suction and discharge pulsation dampeners could be designed to the same pressure to minimise the potential for rupture if there is an operator error when charging.
Control
Regardless of whether the hazard or hazardous activity has been minimised the remaining risk still needs to be managed. Therefore, it is critical to identify the ‘control’ barriers. Which activities, engineering controls or other physical barriers are going to be used to control the hazard. Once these have been identified question if they are actually in place, effective and maintained.
Mitigate
Even with best endeavours if there is a potential that something can go wrong then we should plan for that event and ensure that if it happens the impact is minimised. Therefore, for each of the activities or hazards questions should be asked as to what measures are in place to recover from the hazard being realised. These could range from gas detection to evacuation or shelter in place procedures. Again, question each barrier to ask if they are actually in place, effective and maintained.
At this stage you may think well I am not making decisions on engineering or procedures so this framework can’t be used in my situation. So here is an example of this framework could be applied to decisions.
The market price for your product drops by 50% and as a result senior management has asked you to review the running costs of the facility and cut up to 50% of costs to maintain margins. During this review one of the largest monthly outgoings are salaries so a decision is made to cut the teams by 25%.
During this decision process typically, decisions are made to ensure the key processes continue to happen and that those not directly involved in those are those who are cut. However other factors play into decision making including maintain gender balance and succession planning.
The thing that does not play into this decision-making process often enough in a systematic way is the process safety risk of the change. If we now use our 4 questions, we could start to identify how this could help make better process safety decisions:
Eliminate
Is it possible to eliminate any changes to personnel or support personnel who are directly responsible for safety critical tasks? The answer to this with a 25% cut is likely to be no.
Minimise
Is it possible to minimise any changes to personnel or support personnel who are directly responsible for safety critical tasks? The short answer is likely to be yes however the long answer is much more difficult. This required in depth knowledge of all the safety critical tasks in the organisation, which barriers they are linked to and who in the organisation possess the competency to complete these tasks.
Completing this mapping can really help understand which roles could be merged and then which people in the organisation are best placed to fill those roles. These tasks must not be limited to front line tasks (moving valves, responding to alarms etc) as there are other tasks such as engineering change or procurement which could also significantly increase the risk to the facility if the wrong people are in the roles. Finally, accountability needs to be managed and competence should be assured for those who are accountable for delivery of the safety critical tasks.
Control
We now know that changes will happen to the organisation which can impact the delivery of our safety critical activities or tasks. These are identified as those activities or tasks which would prevent major incidents at our facility and therefore it is critical that we put controls in place to minimise the potential impact. Some of the controls which could be put in place:
- Ensure that people who are leaving hand over their safety critical activities to someone who remains in the organisation
- Ensure that competency gaps which will open as part of the change are planned to be closed either through a hand over or training and that there are checks in place to make sure this has happened
- Ensure that there is absolute clarity about new responsibilities and accountabilities for safety critical tasks
- Given that there are less resources to deliver the objective of the facility review the processes, meetings, and other administration tasks to identify which items can be stopped. These could be distracting from delivery of safety critical activities and therefore may introduce increased risk during this transition period and in the new leaner organisation.
Mitigation
The risk we are trying to manage is the impact to the implementation of safety critical activities. In this process of changing the organisation we may have missed something (for example one role may be overloaded with tasks) or something else may change (someone may become unwell or elect to leave the organisation). Therefore, there need to be mitigations in place to recover from this before this leads to a process safety incident. Some examples of mitigations may be:
- Closer monitoring on the status of safety critical tasks throughout the organisation with remedial plan for increased resource or redirection of effort if a gap is identified.
- A short list of additional activities which could be stopped if pressures are observed on delivery of safety critical activities.
- A commitment from senior management to reverse some of the changes if predefined impacts are observed on safety critical activities.
- A commitment to those in safety critical roles that these will not be impacted in the future to reduce personal migration to other organisations.
- More structured development plans and training budget for the next 12-18 months to help close gaps
A contract to deliver key services which could be called on during busy times to manage workload of personnel left.
