Introduction
Management by exception is a well known business philosophy adopted by managers who wish to empower their subordinates to take full ownership of operations within their responsible areas. The underlying assumption is that if there are no exceptions, all is well and senior management can focus on other matters.
However, unless the frequency and severity of the exceptions are directly linked to the underlying health of the business, this assumption can be fundamentally flawed. When considering process safety a severe incident can be a rare event, the occurrence of which immediately places the business in trouble.
While management by exception may have its place in some areas, it would be extremely reckless to apply the same philosophy to the safety of complex, hazardous operations, such as: mining operations or petrochemical plants.
Life-cycle considerations
In modern plants and on mines, severe accidents occur at a frequency that is too low to predict using most of the traditional statistical indicators, ie, disabling injury and fatality rates. Much more needs to be considered and an integrated view of safety should be adopted to cover the design and engineering of the plant throughout its life-cycle, including human behavioural aspects.
During the early design stages, risk assessment techniques may include hazard and operability studies (HAZOP) and defining design safety integrity levels (SIL), based on the inherent process risks. In these scenarios a team of experts work through systematic methodology to determine risk, and to ensure that appropriate safety standards are applied in the design.
During commissioning, the design meets the real world and engineering challenges are usually well managed during this time. This is because the design engineers are invariably involved in commissioning, and project disciplines are still well enforced. Therefore, a process change that has a safety impact is very likely to be properly assessed and the necessary standards applied to the implementation.
As the plant moves out of the commissioning phase and is handed over to operations, risk assessment practices change fundamentally in nature. It is during this phase in the plant lifecycle that all the engineered systems are in place, and people take over. Behavioural aspects are now significant. Hence the focus during this phase is on safety culture and behaviour. Safety management systems are now implemented. These systems are, however, generally based on exception or deviation processes (incident management) to direct corrective and preventative actions.
During a plant lifecycle, both the techniques of risk assessment and management of safety undergo a fundamental change. HAZOP and SIL assessments are rigorously enforced during the design of a new plant, but to what extent are these practices enforced during routine operations?
New thinking
A balanced and holistic vision is called for if companies are to get out of the philosophy of management of safety by incident. Best practice is to implement several formal systems once the plant reaches routine operations. These systems include: change control (eg, modification proposals); versioned documentation systems (for engineering documentation); operational systems (eg, plant maintenance and safety permits); safety management systems (eg, incident management, tasks and reporting). These systems need to support the underlying risk assessment methodologies such as HAZOP and SIL design techniques and operational risk assessments during permit issue. The same systems also need to be designed around the people who operate the plants, and behavioural aspects must be fully considered.
Accidents can be avoided and companies can remain profitable through a comprehensive and holistic approach to safety that incorporates the design and operation of plants throughout their lifecycle. Senior managers who manage safety by exception can avoid surprises by recognising that this philosophy is not adequate when managing safety in complex environments. Business leaders must recognise the changes in the human element through the complex stages of the operational life-cycle, and lead the culture and approach towards safety. This is not just about providing rubber gloves and respirators. It is a philosophy of safety integrity with the sustained profitability of our mining operations and the safety of personnel as the core values.
For more information contact Gavin Halse, ApplyIT, +27 (0)31 275 8080, halseg@applyit.com, www.applyit.com
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