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Are You Building an Incident-Proof Reputation?
Posted on November 27th, 2017 by Kenneth Bloch in Chemical Manufacturing Excellence
Many good reputations have forever been tarnished by a single incident, and companies that have established a relationship built on trust suddenly lose their neighbors’ confidence and support. All too often, a history of satisfactory Process Safety Management (PSM) performance camouflages an impending disaster that can threaten the company’s future. How can a company with a solid record of regulatory compliance become an object of contempt without any apparent precedent? What must a company do to preserve its license to operate indefinitely?
Answering these questions requires first defining the problem. Without exception, the problem will originate with a process safety event. Therefore, it is generally accepted that solving the problem involves eliminating any unstable operating condition that could result in a process safety event.
The commendable goal of incident elimination is embraced by most companies representing the Chemical and Oil & Gas Industries. In fact, most manufacturing industry employees would agree that process safety regulations strive to achieve this global vision. Examining how industry regulations are designed to function provides useful insight into what companies can realistically expect from maintaining regulatory compliance.
Although PSM regulations may vary according to specific location, they all have something very important in common – PSM regulations are “performance-based.” This terminology might suggest that regulatory compliance enhances system performance, which can only increase one’s resistance to a process safety event. However, the impression that performance-based regulations are designed to enhance system performance is not exactly true. Performance-based regulations simply provide an incentive for companies to demonstrate acceptable results. The incentive for PSM compliance, as many companies have learned at considerable expense, involves avoiding punitive action consisting of monetary fines and legal distractions.
Performance-based regulations are flexible. This non-prescriptive approach to regulatory compliance allows a company to select its own implementation method. The options for compliance are virtually unlimited when the choice depends on the company’s practices, values, and priorities. Therefore, good performance can easily be equated with regulatory compliance even when serious defects are present. But when an incident raises public concern, persistent areas of regulatory non-compliance become readily apparent. How can the image of regulatory compliance exist when a process safety event is possible?
The “Swiss-Cheese” model ensures that regulatory compliance and noncompliance can coexist unnoticed for extended periods of time. According to this model, holes (weaknesses) in protective barriers (management systems) can persist without consequence until holes in other barriers align. Until this alignment occurs, satisfactory results are demonstrated. Performance-based regulations are not designed to detect this disparity until unsatisfactory results are demonstrated.
Illustration of the “Swiss-Cheese” model of accident causation
By Davidmack (Own work) [CC BY-SA 3.0 (https://creativecommons.org/licenses/by-sa/3.0)], via Wikimedia Commons
The weaknesses we are speaking about provide warning signals prior to more serious incidents. Companies sensitive to this fact remain vigilant on detecting any difference between actual and expected process performance, which they interpret as warning signals. An aggressive approach to investigating these differences leads to making necessary adjustments before a more serious incident can occur. Progressive companies seek to learn from others’ mistakes so that adjustments can be made without experiencing unsatisfactory results. Best-in-class performers devour the contents of comprehensive failure documentaries such as Rethinking Bhopal (ISBN: 978-0128037782), which I wrote to help companies like yours secure their license to operate, maintain a competitive advantage, and protect their reputation.
Experience shows that the fear is an inferior incentive compared to the prospect of achieving a common desirable condition. In other words, motivating an enterprise to achieve satisfactory results requires providing an incentive that commits all members without scaring them into submission. Perhaps industry’s universal vision is to develop an incident-proof reputation. Working together to create an incident-proof reputation involves preventing incidents that could threaten the future of our license to operate. Therefore, building an incident-proof reputation requires eliminating incidents that could spoil a good reputation. And when there are no incidents, you have an incident-proof reputation.
All opinions shared in this post are the author’s own.
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