First, companies must appreciate that process safety information and PHAs are the foundation of effective PSM. PHA results will drive the design and implementation of the rest of the process safety requirements — SOPs and safe work practices; mechanical integrity and quality assurance; training of personnel including contractors; changes in technology, facilities and personnel; and dealing with emergencies (Figure 3).
This process addresses the fundamental "why" questions: Why is there an SOP? Why is equipment classified as process critical? Why can't a process temperature or pressure exceed a particular value? Why is there a need to conduct drills to prepare for specific types of emergencies? Asking why by itself is a way of demystifying PSM.
To further demystify PSM, DuPont follows some best practices that have helped improve and sustain good performance. For a start, we recruit an operations team at the project stage, so it can acquire familiarity with the results of the process safety information and PHA. The operations team studies the results of the PHA and develops the SOPs. In fact, the PHA results form the basis for designing the PSM system. In addition, for a high hazard operation, the PHA is reviewed every three years — the operating and maintenance teams always are engaged in this process to ensure ownership and reinforce the importance of following procedures.
Each of our plants also has a permanent PSM committee whose members represent various levels of the operating organization. Depending upon the number of personnel on the site and whether it houses a high hazard operation, subcommittees or champions may act as custodians of process-safety-program elements and report to the committee. Operators and technicians serve on subcommittees or as champions, ensuring operators' needs are considered when procedures are defined. Through a series of checks and balances — including periodic reviews, operator certification, job cycle checks and audits — all relevant personnel understand what they need to do and why it's important.
DuPont defines operational discipline as: "…the deeply rooted dedication and commitment by every member of an organization to carry out each task the right way every time." It reflects the safe behaviors and safety culture of everyone in the company. Success depends upon not only stringent management standards but also their effective implementation (Figure 4).
To illustrate the need for operational discipline, let's look at what happened at a trucking company that, for quality control, collected daily samples from almost 300 vehicles. The sampling required operators to climb every truck, exposing them to a falling hazard. Someone suggested that building a platform with railings would make gathering the samples easier and safer. Company leaders agreed and approved the resources to build the platform, which was inaugurated with a lot of fanfare plus an award to the person who had made the suggestion. Unfortunately, this isn't the end of the story. A week later, observers noticed the platform wasn't being used and the old way of sampling continued.
It's often assumed people automatically will follow any new procedure that reduces risk and improves safety. In reality, implementing any change requires supervision and a consistent and focused effort. This includes coaching and guidance beyond the confines of a classroom. It also demands continuous enforcement through both positive and negative measures to ensure employees really adhere to the change. This is where the role of management and supervision becomes critical in enforcing the expected standards every time to achieve and sustain a high level of operational discipline.