The critical link: process safety leadership is essential to successful plant operation.

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In the twenty years since Process Safety Management (PSM) was adopted by leading chemical corporations worldwide, a lot of developments have occurred. While the benefits of a PSM framework should be obvious to seasoned safety professionals, major catastrophic incidents are still occurring, and these generally trace their roots to gaps in PSM. None of these gaps is more significant than the failure to provide clear leadership and support from the top of an organization. In today's global economy, the focus has shifted to asset integrity, profits, and shareholder value. Ironically, these outcomes are closely aligned to successful PSM, but the synergies in management processes are seldom recognized. An incident-free operation is a profitable one. Process safety must be managed consistently across corporate and geographic boundaries. This requires strong leadership and commitment from the top.

Senior plant management has a responsibility to communicate consistent priorities down through an operating organization and to ensure that those priorities are understood and followed by workers at all levels. Process safety is one of those priorities. Unlike occupational safety, process safety addresses loss of containment events that could harm large numbers of people and cause substantial economic, property, and environmental damage. Although process safety and occupational safety share common values, the two must not be confused. Process safety involves the prevention of leaks, spills, equipment failures, and other upset conditions and it must be supported with specialized resources. Furthermore, a high level of discipline is required if PSM initiatives are to achieve their intended purpose. PSM discipline is best achieved through strong leadership and trust rather than mere enforcement. On occasion, production cuts and other sacrifices may need to be taken when process safety concerns are evident. Too many companies are obsessed with low occupational injury statistics that do not necessarily reflect a safe operation. Inappropriate or misinterpreted metrics may undermine a company's efforts to continuously improve and this can set the stage for a major incident. Short-term successes in occupational safety must not be allowed to interfere with the goals of process safety excellence.

In Canada, PSM has not been applied in a prescriptive manner. It evolved in the late 1980s through the Responsible Care[R] initiative that was pioneered by the Canadian Chemical Producers' Association. Many companies adopted their own PSM practices based on successes elsewhere. Ultimately, in 2004, the Canadian Environmental Protection Act, 1999 (200) regulation took effect requiring plant operations to implement controls to deal with the accidental release of hazardous materials. This regulation, of course, is triggered by defined threshold quantities of specified substances.

While there are subtle differences between PSM frameworks, they all hinge upon the successful engagement of personnel within an organization to do certain things. Common PSM elements include:

1. leadership and accountability;

2. process safety information;

3. process risk management;

4. management of change;

5. operating procedures;

6. safe work practices;

7. training and competency;

8. process and equipment integrity;

9. emergency preparedness;

10. pre-startup safety review;

11. incident reporting and investigation;

12. process safety audits.

Despite its position at the top of the list, the requirements of leadership are not well defined. The Occupational Safety and Health Administration 1910.119 regulation in the U.S. merely cites the requirement to involve workers in all key PSM activities. Sometimes this happens without informing area managers of the challenges that lie ahead.

Given organization downsizing, redesign, and mergers that have occurred in recent times, coupled with the fact that responsibilities have increased, the requirements of good PSM leadership are more onerous than ever before. An organization chart should be drawn up with clear PSM responsibilities and accountabilities for all workers. Communication interfaces must he defined with established timelines for critical information exchange. Plant operating upsets and emergency contingencies should be tested against the organization structure to ensure that there are no gaps or inconsistencies. Finally, formal PSM audits must be conducted on a routine basis and should include a measure of the overall effectiveness of leadership. In today's business environment, senior leaders are sometimes given stock options and salary bonuses related to output. These incentives must not override the commitment to process safety. Over time, PSM will improve system integrity in many areas and will deliver strong financial results.

Leadership should not be confused with conventional management. While the two may co-exist, leadership is more of a desired behaviour than a set of skills. Management means doing things right; leadership means doing the right things.

Management tends to focus on logistics and financial priorities. Leadership, on the other hand, promotes excellence from within the work team. This requires getting into the trenches and learning about the important issues first hand. When trust and credibility are established, a leader can exert influence and move an organization to a new level of performance. Strong leadership believes in the mission and helps to achieve it. It focuses more on helping followers and subordinates than on impressing higher levels of management. Strong leadership does not collapse in the path of obstacles nor does it surrender to budget cuts which can have an adverse effect on safety. Leadership does not look for excuses; it looks for opportunities.

Leadership might reside at several levels within a large organization. Often, only one of those leaders carries a PSM designation in his or her job title. However, if PSM is to work, all leaders must be viewed as PSM leaders. They must work in harmony with one another and must convey a consistent message. All leaders are expected to take process safety considerations into account when making operating decisions.

Questionnaire

The following questionnaire is intended to stimulate the collection of information and help with an initial assessment of the leadership element:

1. Has a plant organization chart been developed that clearly shows reporting relationships between all persons on the plant site? Has it been widely distributed?

2. Does the organization chart recognize and address emergency and upset conditions?

3. Do formal job descriptions exist for all persons and do they reflect PSM activities?

4. Are roles and responsibilities clearly defined for all persons with respect to PSM activities and are they mutually supportive?

5. Are adequate resources available to support the PSM requirements? Are they consistent with the size and complexity of the plant?

6. Is there an edict that requires all personnel to follow established protocols, practices, and procedures? Is there a mechanism to enforce this compliance?

7. Is formal documentation and training available to support a successful PSM initiative?

8. Is there a formal system that communicates management expectations to the organization as well as results achieved from the field level? Does it reflect leading indicators?

9. Is there an initiative that encourages leaders and managers to visit the field on a frequent basis to interact with employees?

10. Is strong leadership recognized and rewarded within the organization?

The position of PSM within an operating organization may have a significant impact on its effectiveness. PSM activities should be closely aligned with operating functions and integrated into the job functions of plant personnel. However, leaders directly responsible for PSM should have a direct reporting relationship to the senior site manager to avoid priority conflicts with plant operations.

Some organizations have chosen to incorporate PSM into an existing health and safety function. This is a reasonable strategy given that both types of safety share a common set of values. Such integration will only work if PSM is supported with specialized technology and resources that address chemical process hazards. Among these are risk management and hazard evaluation. A strong leader will ensure that the activities within PSM are fully utilized and practiced for the benefit of all.

PSM must be reinforced by all leaders, especially when positive results appear imminent. PSM is not the end but only the beginning of how plants should be operated. Although the effort may appear overwhelming at the start, PSM will result in fewer spills, fewer fires, fewer plant upsets, and increased profits. PSM must reside high on the scale of priorities if large scale incidents are to be avoided and if the business is to remain successful.

Brian Kelly, MCIC, has over 34 years of engineering, operations, and process safety experience in the oil industry with Imperial Oil Ltd. and Syncrude Canada Ltd. He is currently the principal of BriRisk Consulting Ltd. in Calgary, AB, and continues his active involvement in the process safety community in both Canada arid the U.S. He is also a part-time project consultant for the Center for Chemical Process Safety of the American Institute of Chemical Engineers.