Clear accountability for performance against specific goals for continual improvement
Everyone who has process safety responsibilities, from senior management to process operators, must exercise appropriate authority and judgment and understand and submit to being accountable for their process safety performance. 21 Establish specific process safety related goals to use in determining whether
continual improvement is being made.
• Use industry information to establish injury and incident rate targets. Include process-related fatalities.
• Use company experience to set targets for reducing the frequency of process safety-related accidents, incidents, near misses, reportable releases, etc. Develop incentives and systems to encourage complete reporting.
• Define goals (i.e., short- and long-term) for reducing accidental releases, property losses and business interruption. 2.2 Uniformly enforce codes, standards and procedures that promote process safety.
• Provide resources to stay informed of the evolving legal and regulatory climate relating to process safety. • Ensure that company standards are followed and that any exceptions are properly authorized.
• Verify compliance with applicable consensus standards (e.g., ASME, NFPA, ANSI, AS'1'M) through a project safety review program (MP13).
2.3 Define a mechanism for reviewing management accountability for process safety.
• Include specific process safety goals in yearly personal objectives. Ensure that there is a performance rating inspection during periodic performance appraisals.
• Encourage creative goal setting methods in promoting personal achievement in continual improvement of process safety.
• Provide incentives to encourage individuals to make the correct "safetyfirst" decisions in the face of production or other competing needs.
2.4 Establish a management system to ensure compliance with the Process Safety Code of Management Practices. • Define a plan for verifying that the commitment to process safety through the Responsible Care program is being
met.
• Establish management criteria for periodic review of conformance with these Management Practices. • Identify deficiencies and develop strategies and plans for expeditiously correcting them.
PITFALLS AND CONSIDERATIONS
Specific process safety goals are difficult to define. Avoid vague prescriptions in performance goals, such as "operate unit safely." Instead, start deliberately by choosing a few very specific, measurable targets (e.g., complete annual process safety audit of five facilities per month, achieve 90% attendance at shift process safety seminar, implement/ resolve all recommendations from the last periodic process hazard review of the facility). React appropriately (e.g., recognition, promotion, letters of reprimand) to improved/ inadequate process safety performance.
Management Practice 3: Performance Measurement
Measurement of performance, audits of compliance, and implementation of corrective actions.
Accountability for one's commitment (or lack thereof) to the Guiding Principles of Responsible Care that address process safety cannot be achieved unless management measures and reacts to the process safety performance of the affected individuals. Once measurement systems are in place, management can perform periodic audits, prescribe corrective actions for areas that need improvement and support awards for people who have achieved their performance goals. (See Tab 8 for more information on process safety performance evaluations.)
PROCESS SAFETY ACTIVITIES
3.1 Establish a program to verify operating facilities' compliance with proem safety objectives. • Define the physical and organizational scope of the program.
• Commit adequate personnel for performing audits.
• Coordinate Process Safety Code audits with other regular audits (e.g., loss prevention, boiler, environmental) to avoid duplication.
• Establish a system to measure the effectiveness of the audit program. • Develop lists of corrective measures.
3.2 Verify that corrective actions have been implemented in a timely fashion. • Assign specific responsibilities for correcting identified deficiencies. • Establish target completion dates along with a resource plan.
• Require documentation of actions that resolve audit recommendations.
• Establish a system to track corrective action efforts. For example, how many were completed last quarter? How many are in progress? How many are behind schedule? How many are under study?
• Establish a priority authorization system for approving resources (i.e., capital items, staff, etc.) for process safety-related items.
PITFALLS AND CONSIDERATIONS
Measurement systems ultimately fail when the gathered data do not match reality. Management must ensure that audits are not carried out in a perfunctory manner. Another pitfall is that of inadequate follow-up. Once an audit is complete, resolution of all items must be vigorously pursued. The importance of establishing appropriate process safety priorities must be promulgated throughout the company and then reinforced in performance appraisals. Just as company accountants monitor accounts payable, so too must process safety specialists track the status of corrective actions to improve process safety performance.
Management Practice 4: Incident Investigation
Investigation, reporting, appropriate corrective action and follow-up of each incident that results or could have resulted in a fire, explosion or accidental chemical release
Process safety-related incidents are unplanned events that result in undesired consequences such as fires, explosions or releases of toxic/hazardous materials. Incidents of interest include not only those that propagate to a fully developed catastrophic result, but also precursor events, those near misses that by circumstance or design were terminated before a more severe consequence resulted.
Major incidents may recur in the same unit, at the same facility, within the same company and within the industry unless forceful measures are taken to prevent them. Thus, in order to continually improve process safety performance, a company should have an aggressive and persistent program for investigating incidents, ferreting out causes, and determining effective corrective measures. Periodically reviewing the circumstances of previous accidents and determining whether similar circumstances have evolved again is an especially effective process safety assurance activity.