4.1 Establish an incident investigation policy.
• Define internally reportable incidents and develop reporting criteria.
• Develop an environment where employees feel empowered and obligated to report incidents, and feel safe from retribution.
• Create an incident review committee or other structure, with senior management involvement, to ensure incident reports are acted upon by the company. Highlight recommendations from previous incidents that have yet to be implemented. • Plan for dealing with incidents in advance. This will help maximize the safety benefits of lessons learned.
• Define lines of authority and priorities when dealing with incidents (e.g., securing the site to prevent further harm, site preservation for collection of data and evidence, cleanup and reconstruction). Ensure proper coordination with emergency response personnel
42 Develop an incident investigation program. • Create incident investigation guidelines.
• Establish investigation team criteria and lists of company resources and sources of special expertise. • Provide the necessary tools and guidance for team members.
• Establish a mechanism for tracking incident reports. Ensure that it follows the life cycle of incidents as they occur, as they are investigated and as results are acted upon.
• Provide criteria for intracompany involvement. Define appropriate roles for legal, public relations and labor relations departments. Sometimes it will be appropriate to perform an investigation under attorney-client privilege.
• Provide resources for enlisting third-party participation by outside experts and specialists needed because of unavailability of company personnel.
• Ensure the separation of the investigation activity (e.g., data gathering) from follow-on efforts (e.g., disciplining of employees).
4.3 Communicate lessons learned to all appropriate company groups.
• Maintain an incident log and frequency monitoring system. Ensure that incident investigation reports become a part of the process hazards information package (MP8).
• Provide guidelines for writing investigation reports, having them reviewed for other considerations (e.g., legal and public relations) and distributing them to appropriate personnel within the company.
• Develop recommended actions from the results of an investigation. Assign responsibilities and schedules for implementing corrective measures.
• Provide results and lessons learned (MP5) to appropriate authorities and to other company divisions that could be affected (e.g., other company units with similar processes). Coordinate information sharing using CAER outreach (MT6).
• Provide feedback, from the investigation program, on ways to improve company response to incidents. Periodically review the results from past investigations with new employees.
PITFALLS AND CONSIDERATIONS
Lack of adequate planning is a major cause of failure to properly investigate and learn from incidents. Local responsibility must be assigned for site preservation. Ultimately, the success of a company's program is dependent upon how thoroughly and quickly the results are communicated and acted upon within operating facilities. If legal issues and boundaries have not been agreed upon in advance, then the information flow is stymied and valuable time may be lost.
Management Practice 5: Information Sharing
Sharing of relevant safety knowledge and lessons learned from such indents with industry, government and the community.
Communicating important process safety information to other companies may help prevent accidents and save lives. Responsible sharing of information can be an important factor in maintaining credibility with the local government and communities surrounding a facility.
PROCESS SAFETY ACTIVITIES
5.1 Establish a formal policy for timely publication of process safety related information.
• Prepare a written internal clearance procedure involving appropriate corporate departments (e.g., legal, public relations, technical).
• Encourage in-house legal counsel to establish prerelease approval criteria for generic information, protecting confidential/proprietary data.
• Identify communication media with which information should be routinely shared.
• Encourage publication of process safety papers and presentation of talks to process safety-related conferences and industry groups.
5.2 Establish a formal policy for employee participation with outside groups to foster information sharing- Identify local groups that should receive company information and support.
5.3 Coordinate information sharing policies with tent investigation practices (MP4) and emergency management (MP16) for publication of accurate information during prolonged emergency situations.
• Designate a room with a telephone for the media to use during an emergency.
• Designate specific plant personnel to interact with local media until corporate staff support arrives.
PITFALLS AND CONSIDERATIONS
Companies that perfunctorily restrict sharing of information hurt themselves and the industry in the long-run. An uninformed public promotes suspicion, not trust. Companies should proactively encourage sharing of appropriate information that could improve industry's overall process safety performance. However, special training of company technical spokespersons may be required for "media" events. Plants must be prepared to supply facts and cooperate with the media during emergencies to avoid incorrect and damaging speculation that inevitably occurs in the absence of timely information sharing. Technical papers or press releases should be reviewed to prevent disclosure of inaccurate or inflammatory information.
Management Practice 6: CAER Integration
Use of the CAM process to assure that public comments and concerns are considered in design and implementation of the facility's process safety system
The CAER Code of Management Practices provides for reliable emergency response to facility events that could have "beyond-the-fenceline" effects and promotes public dialogue through outreach to responsible community organizations. The Process Safety Code of Management Practices supports the objectives of the CAER Code; companies should use the process already set up through CAER to consider public concerns in the safe operation of process facilities. Companies should take advantage of opportunities to share appropriate technical information and relevant results from internal process hazard reviews with Local Emergency Planning Committees (LEPC).
PROCESS SAFETY ACTIVITIES
6.1 Implement the proactive features of CAER that relate to process safety outreach to the public. • Review the commitment stated in the CAER Code.
• Establish coordination between company CAER representatives and those responsible for process safety issues. • Use existing CAER outreach mechanisms to advise the public of company development and process expansion plans. • Use the CAER process to open a dialogue with the community to receive their concerns about plant activities connected with process safety.
• Act on the community's advice and provide feedback concerning company decisions and their impact on process safety to the community within a reasonable time.
• Encourage company employees to be process safety ambassadors within the community (e.g., giving talks and
distributing information concerning process safety provisions that exist to limit community risk, being a member of an LEPC).
• Use opinion surveys to perform periodic evaluations of the effectiveness of process safety outreach.
PITFALLS AND CONSIDERATIONS
Don't attempt to implement this Management Practice without coordinating it with the existing CAER framework set up within your company. Carefully select information that is appropriately presented for layperson review - don't just distribute lengthy technical reports. On the other hand, don't overly restrict the furnishing of pertinent process safety data because you think it's too complex for the public to understand. Try to avoid the appearance of hearing, but not listening; respond to public concerns in a timely fashion.