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
jerry.forest@lyondellbasell.com
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UNPUBLISHED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
jerry.forest@lyondellbasell.com
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.