Guidelines for implementing process safety management systems

Guidelines for Implementing Process Safety Management Systems

CENTER FOR CHEMICAL PROCESS SAFETY of the AMERICAN INSTITUTE OF CHEMICALENGINEERS 345 East 47th Street, New York, New York 10017

Copyright © 1994 American Institute of Chemical Engineers 345 East 47th Street New York, New York 10017 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise without the prior permission of the copyright owner. Library of Congress Cataloging-in Publication Data Guidelines for implementing process safety management systems. p. cm. Includes bibliographical references and index. ISBN 0-8169-0590-8 : $120.00 1. Chemical processes—Safety measures. I. American Institute of Chemical Engineers. Center for Chemical Process Safety, TP149.G838 1993 66Qf .2804—dc20 93-23165 CIP

This book is available at a special discount when ordered in bulk quantities. For information, contact the Center for Chemical Process Safety at the address shown above. It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry; however, the American Institute of Chemical Engineers, its consultants, CCPS subcommittee members, their employers, their employers'officers and directors, and Arthur D. Little, Inc. disclaim making or giving any warranties or representations, express or implied, including with respect to fitness, intended purpose, use or merchantability and/or correctness or accuracy of the content of the information presented in this document. As between (1) the American Institute of Chemical Engineers, its consultants, CCPS subcommittee members, their employers, their employers' officers and directors, and Arthur D. Little, Inc. and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequence of its use or misuse.

PREFACE The Center for Chemical Process Safety (CCPS) has recognized since its inception that enhancements in chemical process technologies, taken alone, are not sufficient to prevent catastrophic events such as the Bhopal disaster. It is obvious that successful chemical process management technologies need the commitment and participation of top management. Therefore, with support from its advisory and managing boards, CCPS established a multifaceted program to address the need for technical management commitment and technical management systems to reduce the potential for exposures to the public and to the environment. The first document produced under the CCPS program was a brochure entitled "A Challenge to Commitment," which was mailed to the CEOs of more than 1500 companies. It provides an overview and an outline of a comprehensive model for the technical management of chemical process safety, characterized by twelve distinct and essential elements. The second publication was a book entitled Guidelines for Technical Management of Chemical Process Safety. It expands on the twelve elements of the CCPS model and provides both the framework and detailed components for a chemical process safety management system, and offers various alternatives for implementation of each of the elements and components of the model. To further supplement and "customize" the model, American Institute of Chemical Engineers (AIChE) conducts training programs based on the book, to teach the use of the CCPS process safety management program. A third publication, Plant Guidelines for Technical Management of Chemical Process Safety, contains highly detailed instructions and example materials suitable for direct implementation at plants. Most of the example materials are taken from written procedures currently in place at some of the most prestigious U.S. plants. The guidelines are directed toward all those individuals with responsibility for initiating and/or maintaining any of the elements detailed in Guidelines for Technical Management of Chemical Process Safety. Video training programs based on these two books have also been produced to help companies present the principles of process safety management to employees. Other CCPS guidelines address individual elements—such as Auditing, Incident Investigation, and Documentation—in greater detail. This book complements previous work by CCPS in describing how to undertake the design, development, and installation of process safety management systems.

ACKNOWLEDGMENTS The Center for Chemical Process Safety (CCPS) wishes to thank all the members of the Technical Management Subcommittee who provided guidance in the preparation of these materials. CCPS also wishes to express its appreciation to members of the Technical Steering Committee for their advice and support. The Technical Management Subcommittee included the following individuals: Alfred Bickum (Goodyear Tire & Rubber Company); John Dowbekin (Exxon Chemical Company); WJ. Fraser (Merck & Company, Inc.); John Gallamore (Dow Chemical); Jeff Gunderson (Chevron Research & Technology Company); William Helmer (Hoechst Celanese Corporation); Gregory Keeports (Rohm and Haas Company); Anne McGuinness (Chevron Corporation); John Murphy (Dow Chemical Company); Jim Parnell (E.I. Dupont De Nemours & Company); Frank Ragonese (Mobil Oil Corporation); E. J. Ryczek (Merck & Company, Inc.); Stanley Schechter (Rohm & Haas Company); Wayne Scheimann (Nalco Chemical Company); Leslie Scher (Grace Specialty Chemicals Company); Thomas Selders (ARCO); Joseph Sweeney (ARCO Chemical); C. R. West (PPG Industries, Inc.); and Sanford Schreiber (CCPS/AIChE). Arthur D. Little, Inc., Cambridge, Massachusetts, was the contractor who prepared these Guidelines. R. Scott Stricoff was Arthur D. Little's Project Director. The principal author was Mary I. Woodell. Key contributors included Henry Ozog and David Webb. Tracey Martensen's contribution to manuscript preparation was invaluable. We gratefully acknowledge the comments and suggestions submitted by the following companies and peer reviewers: Henry Blunt (Shell Oil); Arthur F. Burk (DuPont); Charles Dancer (Allied Signal); J. A. Hoffmeister (Martin Marietta Energy Systems); Robert Ormsby (Air Products and Chemicals); Duane Sanderson (3M); Anthony A. Thompson (Monsanto); and Guy Van Cleve (Petrocon).

LIST OF TABLES, FIGURES, AND APPENDICES

Table 1-1

AIChE/CCPS Process Safety Management Elements

Figure 2-1 Figure 2-2 Figure 2-3 Figure 2-4 Figure 2-5 Figure 2-6 Figure 2-7 Figure 2-8 Figure 2-9 Figure 3-1

PSM Sponsorship Roles PSM Presentation Worksheet and Sample Outline Sample Executive Summary Sample Vision Statement Sample Group Charter or Mission Statement Example of Preliminary Company Plan Summary Example of a Preliminary Divisional Plan Summary Sample Skills Matrix Sample Level of Effort Allocation Matrix Chemical Manufacturers Association (CMA) Process Safety Management Elements American Petroleum Institute (API) Process Safety Management Elements Environmental Protection Agency (EPA) Risk Management Prt>gram Components Occupational Safety and Health Administration (OSHA) Process Safety Management Elements Sample PSM Skills/Impact Matrix Sample PSM Team Mission Statement: Outline and Final Version Sample Matrix: Skills Applied to Tasks Sample Matrix: Staff Allocation by Project Phase Sample Agenda for First PSM Team Meeting Process Safety Management Assessment Framework Condensed Listing of Management System Characteristics Example Page from an Audit Protocol Format

Figure 3-2 Figure 3-3 Figure 3-4 Figure 3-5 Figure 3-6 Figure 3-7 Figure 3-8 Figure 3-9 Figure 4-1 Figure 4-2 Figure 4-3

2 9 16 20 26 27 32 34 36 38 47 48 48 49 52 54 57 58 60 76 78 80

Figure 4-4 Figure 4-5 Figure 4-6 Figure 4-7 Figure 4-8 Figure 4-9 Figure 4-10 Figure 4-11 Figure 5-1 Figure 5-2 Figure 5-3 Figure 5-4 Figure 5-5 Figure 5-6 Figure 5-7 Figure 5-8 Figure 5-9 Figure 5-10 Figure 5-11 Figure 5-12 Figure 5-13 Figure 5-14 Figure 6-1 Figure 6-2 Figure 6-3 Figure 6-4 Figure 6-5

Example Page from a PSM Topical Outline Baseline Audit Report for Management of Change Yes/No Questionnaire for PSM Program Evaluation Open-Ended Questionnaire for Evaluating Operating Procedures Program Sample Management Grid: PSM Elements/Primary Responsibility and Location Maturity of PSM Systems and Programs Example of PSM Status Summary Example of an Interim Report from a PSM Task Team Example of Responsibility Matrix for Hybrid Approach Sample Analysis of Selected PSM Gaps and Priorities Sample Work Breakdown Structure: Priority Elements and Tasks Example of Interrelated PSM Elements and Priorities Example Matrix : Skills/Tasks Required for Developing PH A Program Example Task Leadership Assignments for PHA Program Development PSM Staffing Needs by Element and Function Final Plan Schedule—Linear Timeline Final Plan Schedule for Overall Program Staff Resources Plan for "Develop PHA Process" Example of Ideal Staff Needs vs. Actual Availability Analysis Sample Project Plan Table of Contents Example of Project Plan Sections on "Installation and Verification" and "Financial Controls" Sample Report: Resources Used vs. Plan Simplified Example of TQM Team Results: Customer/ Supplier Needs Simplified Example of TQM Team Results: Current Process Flow Simplified Example of TQM Team Results: Identification of Breakdown Points Simplified Example of Adaptation of a Model Program Simplified Example of Stakeholder Needs

81 82 84 85 90 91 92 93 99 103 108 109 110 110 111 113 114 117 118 120 121 122 131 132 133 135 138

Figure 6-6 Figure 6-7 Figure 6-8 Figure 6-9 Figure 7-1 Figure 7-2 Figure 7-3 Figure 7-4 Figure 7-5 Figure 7-6 Figure 7-7 Figure 8-1 Figure 8-2 Figure 8-3 Figure 8-4 Figure 8-5 Figure 8-6 Figure 9-1 Figure 9-2 Figure E-I

Simplified Example of Identifying Barriers 139 Simplified Example of Roles Definition 140 Simplified Example of Redesigned Process Flow 141 Sample Outline for Management System SOP 145 Summary of PSM Pilot Test Goals and Parameters 151 Pilot Test Roles and Responsibilities 152 Sample Pilot Test Feedback Questionnaire 153 Sample PSM Pilot Test Interim Report to Management 156 Sample PSM Pilot Test Interim Report to Facility Managers 157 Example of Job Description for Managing PSM Pilot Test 162 Example of PSM Customer Benefits Grid 164 Example of a Monthly Status Report Used within a Facility 177 Example of Quarterly Status Report 179 Sample On-Site Review Interview Format 180 Example of an Exception Report to Management 181 Example of an Overview Report to Management 182 Example of a PSM System User Feedback Survey 183 Application of PSM Elements to Chemical Distribution Activities 189 Comparison of PSM Elements with Industrial Hygiene Management Needs 191 Stages of Process Safety Management Systems 195

Appendix 2-1 Sample Document Presenting PSM to Senior Management 39 Appendix 5-1 Example Facility Ranking Process 124 Appendix 5-2 Example Management Presentation on PSM Plan 126

Contents

Preface ................................................................................

ix

Acknowledgments ...............................................................

xi

List of Tables, Figures, and Appendices ..............................

xiii

1. Introduction ...................................................................

1

1.1 Overview and Objective of This Book ...............................

1

1.2 Scope ...............................................................................

1

1.2.1 What Kinds of Companies and Operations Are Covered? .....................................................

1

1.2.2 What Information Is in This Book? What Is Not? ...................................................................

4

1.3 How to Use This Book ......................................................

4

2. Get Management Commitment .....................................

7

2.1 Why Get Management Commitment? ..............................

7

2.2 Getting Top-Level Commitment ........................................

8

2.2.1 Selecting the Right Sponsor(s) ...........................

8

2.2.2 Selling the Need for PSM ...................................

10

2.2.3 Selling the Need for Top-Level Commitment .......

19

2.3 Using Top-Level Commitment ..........................................

23

2.3.1 Setting Goals for PSM ........................................

23

2.3.2 Communicating the Importance of PSM ..............

28

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v

vi

Contents 2.3.3 Providing Resources ..........................................

33

Appendix 2-1 Sample Document Presenting PSM to Senior Management .........................................................

39

3. Define Goals ..................................................................

45

3.1 Introduction .......................................................................

45

3.2 Select PSM Framework ....................................................

45

3.2.1 CCPS Model ......................................................

47

3.2.2 Other Models ......................................................

47

3.3 Establish a PSM Team .....................................................

50

3.3.1 Who Should Be on the Team? ............................

51

3.3.2 How Should This Team Work? ...........................

51

3.3.3 Soliciting Team Members' Participation ...............

56

3.3.4 Scheduling and Organizing the First Meeting ..............................................................

59

3.3.5 Conducting Team Meetings ................................

61

3.4 Define Company-Specific Attributes .................................

62

3.4.1 Characterize Company Management System Approach ............................................................

63

3.4.2 Define Supervision/Delegation Approach ............

67

3.4.3 Define Documentation Approach ........................

69

3.4.4 Define Communication Approach ........................

70

4. Evaluate the Present Status .........................................

73

4.1 Recognize the Objective ...................................................

73

4.2 Select an Evaluation Tool .................................................

75

4.2.1 Audits .................................................................

79

4.2.2 Surveys ..............................................................

83

4.3 Perform the Evaluation .....................................................

86

4.4 Identify Gaps and Overlaps ..............................................

89

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Contents

vii

5. Develop a Plan ...............................................................

95

5.1 Review the Preliminary Plan .............................................

95

5.2 Select an Implementation Strategy ...................................

95

5.2.1 Companywide Approach .....................................

96

5.2.2 Facility-Specific Approach ..................................

97

5.2.3 "Hybrid" Approach ..............................................

99

5.3 Define Priorities ................................................................ 100 5.3.1 Priority Facilities ................................................. 101 5.3.2 Priority Elements ................................................ 104 5.3.3 Limitations on the Scope of the Plan ................... 105 5.4 Estimate Resource Needs and Schedule ......................... 106 5.4.1 Develop a Program Plan ..................................... 107 5.4.2 Develop a Schedule ........................................... 112 5.4.3 Develop a Resource Plan ................................... 112 5.5 Communicate and Get Approval of the Plan .................... 121 Appendix 5-1: Example Facility Ranking Process ................... 124 Appendix 5-2: Example of Management Presentation on PSM Plan .......................................................................... 126

6. Develop Specific Process Safety Management Systems ......................................................................... 129 6.1 Select an Approach .......................................................... 129 6.1.1 Total Quality Management (TQM) Techniques ........................................................ 130 6.1.2 Using Model Programs ....................................... 134 6.1.3 Business Process Redesign ............................... 137 6.2 Select a Team .................................................................. 142 6.3 Develop the System ......................................................... 145 6.4 Recheck against Criteria .................................................. 146

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viii

Contents

7. Put the System into Practice ........................................ 147 7.1 Pilot Testing ...................................................................... 147 7.1.1 Factors to Consider in Pilot-Site Selection .......... 148 7.1.2 Gaining Local Support for the Pilot Test .............. 149 7.1.3 Implementing a Successful PSM Pilot ................. 150 7.1.4 Assessing Pilot Test Results ............................... 158 7.2 Plan and Manage Installation ........................................... 159 7.2.1 Where to Begin Installation ................................. 159 7.2.2 Who Should Manage Installation ......................... 161 7.3 Sell the System ................................................................. 161 7.3.1 Describe System Benefits ................................... 162 7.3.2 Reinforce Buy-In from Management .................... 163 7.3.3 Reinforce Buy-In from Participants ...................... 165 7.4 Design and Provide Training ............................................ 168 7.4.1 Training Managers ............................................. 169 7.4.2 Training Trainers ................................................ 169 7.4.3 Training Users .................................................... 170 7.4.4 Training others (e.g., Contractors) ...................... 171 7.4.5 Training Methods and Tools ............................... 172 Conclusion ............................................................................... 173

8. Measure and Monitor Installation ................................ 175 8.1 Introduction ....................................................................... 175 8.2 Monitor Installation ............................................................ 175 8.2.1 Plant-Level Monitoring ........................................ 176 8.2.2 Companywide Monitoring ................................... 177 8.3 "Customer Feedback" and Follow-Up .............................. 182 Conclusion ............................................................................... 185

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Contents

ix

9. Expanding Beyond Initial Scope .................................. 187 9.1 Introduction ....................................................................... 187 9.2 Expanding Beyond Minimum Requirements .................... 187 9.3 Involve Other Activities ..................................................... 188 9.4 Involve Other Functions .................................................... 188 9.5 Expand to Other Processes .............................................. 190 9.6 Expand Internationally ...................................................... 190 9.6.1 Evaluate Local Needs ......................................... 192 9.6.2 Establish Priorities .............................................. 193 9.6.3 Match Systems to Local Needs ........................... 193 Conclusion ............................................................................... 194

Epilogue ............................................................................. 195 Case Study in Implementing Process Safety Management .................................................................. 197 Background .............................................................................. 197 Introduction .............................................................................. 199 Getting Management Commitment .......................................... 200 Defining Goals ......................................................................... 201 Evaluating the Present Status ................................................. 203 Developing a Plan .................................................................... 204 Developing Specific PSM Systems .......................................... 206 Putting the System into Practice .............................................. 207 Measuring and Monitoring ....................................................... 209 Expanding Beyond Initial Scope .............................................. 210

Bibliography ....................................................................... 213 Index ................................................................................... 215

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1 INTRODUCTION

1.1 OVERVIEW AND OBJECTIVE OF THIS BOOK Since its founding in 1985, the American Institute of Chemical Engineers7 Center for Chemical Process Safety (CCPS) has promoted enhanced management of chemical process safety. Leading the way in recognizing that process safety involves both technology and management, the CCPS program has included a series of initiatives designed to address the concerns and interests of senior management (A Challenge to Commitment), middle management (Guidelines for the Technical Management of Chemical Process Safety), and plantlevel staff (Plant Guidelines for Technical Management of Chemical Process Safety). These materials derive from CCPS' model for the technical management of chemical process safety, which is presented here as Table 1-1. Guidelines for Implementation of Process Safety Management is designed to assist those who are called upon to design, develop, and install process safety management systems within their plants or companies: the people who must "make it happen." Therefore, this book includes examples and references to assist in the design of a management system for implementation of process safety throughout a plant or company. The task of process safety management implementation is complex because it crosses over several functional areas of a company's organization. For example, comprehensive process safety management systems influence research, development, and engineering; facility and process construction, operation, and maintenance; training throughout the organization; procurement; and information management. This book provides practical assistance in how to implement the ideas and concepts found in earlier CCPS publications.

1.2 SCOPE 1.2.1 What Kinds of Companies and Operations Are Covered? These Guidelines are designed to be adaptable to the needs of most operations involved in the storage, transfer, use, and processing of hazardous materials, and the information is intended to be adapted by the reader.

TABLE 1-1 AlChE/GCPS Process Safety Management Elements Accountability: Objectives and Goals Continuity of operations Continuity of systems (resources and funding) Continuity of organizations Company expectations (vision or master plan) Quality process Control of exceptions Alternative methods (performance vs. specification) Management accessibility Communications ! 'rocess Knowledge and Documentation Process definition and design criteria Process and equipment design Company memory (management information) Documentation of risk management decisions Protective systems Normal and upset conditions Chemical and occupational health hazards Capital Project Review and Design Procedures (for new or existing plants, expansions, and acquisitions) • Appropriation request procedures • Risk assessment for investment purposes • Hazards review (including worst credible cases) • Siting (relative to risk management) • Plot plan • Process design and review procedures • Project management procedures Process Risk Management • Hazard identification • Risk assessment of existing operations • Reduction of risk • Residual risk management (in-plant emergency response and mitigation) • Process management during emergencies • Encouraging client and supplier companies to adopt similar risk management practices • Selection of businesses with acceptable risks Management of Change • Change of technology • Change of facility • Organizational changes that may have an impact on process safety • Variance procedures • Temporary changes • Permanent changes

TABLE 1-1 AlChE/CCPS Process Safety Management Elements (continued) Process and Equipment Integrity • Reliability engineering • Materials of construction • Fabrication and inspection procedures • Installation procedures • Preventive maintenance • Process, hardware, and systems inspections and testing (pre-startup safety review) • Maintenance procedures • Alarm and instrument management • Demolition procedures Human Factors • Human error assessment • Operator/process and equipment interfaces • Administrative controls versus hardware Training and Performance • Definition of skills and knowledge • Training programs (e.g., new employees, contractors, technical employees) • Design of operating and maintenance procedures • Initial qualification assessment • Ongoing performance and refresher training • Instructor program • Records management Incident Investigation • Major incidents • Near-miss reporting • Follow-up and resolution • Communication • Incident recording • Third-party participation as needed Standards, Codes, and Laws • Internal standards, guidelines, and practices (past history, flexible performance standards, amendments, and upgrades) • External standards, guidelines, and practices Audits and Corrective Actions • Process safety audits and compliance reviews • Resolutions and close-out procedures Enhancement of Process Safety Knowledge • Internal and external research • Improved predictive systems • Process safety reference library

This book primarily addresses process safety management for facilities handling hazardous materials, and describes activities and approaches within medium- to large-size U. S. companies. However, readers will find that many of the principles outlined here are equally applicable and readily adaptable to smaller operations and single-plant operations. Similarly, although the case study provided at the end of this volume focuses on the chemical industry, the principles it illustrates apply to the full range of allied industries such as pulp and paper, electronics, oil and gas, etc. The Guidelines can be seen as a template that can be refined and applied to a wide range of processes, industries, and organizational structures. To assist you in looking beyond this book, Chapter 9 addresses the expansion of process safety management programs and techniques to cover transportation and other business activities requiring environmental, health, and safety control. Chapter 9 also raises some of the issues that readers should consider in implementing process safety management internationally. 1.2.2 What Information Is in This Book? What Is Not? This book addresses the design, development, and installation of process safety management systems, but does not address subsequent operation and maintenance of those systems. The book's goal is to help you put together a workable, effective program and put it in place within your company or plant. There is no single "right" way to implement process safety management. Effective programs and systems are fully integrated into an individual company's operations, and reflect its business priorities, culture, and organization. For this reason, as you will see, this book does not present formulae or dictate instructions for implementation. Instead, it provides information and "how to" examples to help people who have responsibility for developing process safety management programs determine the approach that best fulfills their companies' specific needs. Some of this information is presented in the form of very specific examples, used to illustrate a range of approaches and methods. This range is not intended to be all-inclusive; your company's precise organization may not be represented here. However, every effort has been made to address several common structures, including centralized and decentralized operations and " top-down" and "bottom-up" management structures.

1.3 HOWTOUSETHISBOOK Implementing process safety management (PSM) is a process, each of whose phases builds on previous steps. This book's organization reflects this process chronologically. Chapters 2 through 8 of this book present a step-by-step

discussion of the process of designing a management system for implementing process safety. Each chapter includes other common elements, including: • "Hint" boxes, highlighting specific implementation pointers for consideration. • "Troubleshooter" boxes, which help identify potential bottlenecks and suggest ways to overcome them. Because of its chronological presentation, you will probably find it most productive to read this book in chapter order. As you undertake the process it describes, you may find that some sections are particularly relevant to your company and elect to share them with teammates or other colleagues. Similarly, you may find it useful to consolidate hints for discussion inside your company. At the end of this book you will find a case study describing PSM implementation at "Midwest Chemicals and Plastics." Midwest Chemicals and Plastics (MCP) is an imaginary company, but as described it reflects many characteristics commonly seen in both large and small companies interested in PSM. MCP begins exploring PSM without a real understanding of what PSM involves or how to use the concepts. A "champion" is appointed, and under the guidance of the champion and a team of others, MCP proceeds through a series of steps including defining the goals, assessing their current status, establishing priorities, preparing a plan for PSM implementation, and designing, testing and installing specific PSM systems. The experience of MCP shows how both centralized and decentralized management approaches can be consistent with implementation of PSM. There is more than one way to successfully design, develop, and install PSM systems, and in some cases more than one approach will be needed within the same company. As MCP proceeds with PSM implementation, the company emphasizes sharing and making effective use of programs that already exist, recognizing that PSM implementation is a big job, and no one can afford to "re-invent the wheel." Even when different divisions of MCP proceed with different approaches to PSM implementation, ongoing communication facilitates sharing of information. As MCP assesses its PSM status and designs PSM systems, the team pays careful attention to identifying and using systems already in place. MCP's success relies on the continuing support and commitment of the company's senior management. It is vital that such support be enlisted at the earliest stages of PSM design. The PSM implementation effort requires resources; given the inevitable competition for limited resources within any organization, senior management support is a key success factor. The MCP example, though fictional, helps to demonstrate how the approaches described in this book can come together to achieve PSM implementation.

2 GET MANAGEMENT COMMITMENT

2.1 WHY GET MANAGEMENT COMMITMENT? The simple answer to this question is that you will not succeed without management commitment. Time invested in gaining management's commitment pays off in tangible support, which not only facilitates but also expedites a long-term process such as PSM implementation. Commitment, as the term is used here, refers to explicit, concrete actions, not merely to rhetoric. "We are committed to the principles of process safety management" is only the first step. The goal for gaining management commitment is to complete the thought: "We are committed to the principles of process safety management and we will devote the necessary staff and financial resources to implementing these principles throughout our operations." Without such a commitment from management, process safety management will be far more difficult and time-consuming to implement. An initiative that lacks a collective sense of urgency and priority is likely to be carried out piecemeal, despite the best efforts and intentions of its champion. Over time, piecemeal implementation is a false economy, since it is likely to take longer and cost more; most important, it is very likely to be less effective. PSM is a continuous process, not an event, or a series of discrete activities. Without continuity, the process can easily break down. Tangible support means not only resources but also standing relative to other company priorities. PSM needs legitimacy as a business objective to hold its own in situations requiring a trade-off between long-term process improvement and short-term commercial considerations. No matter how deeply committed safety professionals may be, this legitimacy can only be conferred by top management, who ultimately must make those trade-off decisions. As a practical matter, support from top management also creates strong incentives at the implementation level. If PSM is known to be a priority for the boss, it is much more likely to attract active participation within the company. By contrast, initiatives that employees see as "flavor of the month" win (and usually deserve) little continuing employee support. In addition, commitment from the top sets standards—and deadlines—for performance. While no one wants to constantly invoke the boss (and it can certainly be counterproductive to do so), specific, articulated expectations from the top greatly improve the chances that individual commitments will be met.

Hint: Informally review and consider major initiatives or campaigns (for example, facility safety, employee wellnesst community service, etc.) that have succeeded in your company —along with those that have failed. What made them work? Incentives to participation? Relevance to job or quality of life? Other? And what about the failures? Lack offollowthrough? Weak endorsement? Bad idea in the first place?

2.2 GETTING TOP-LEVEL COMMITMENT

Having established the value of management commitment, the challenge is to win it. While there is no single, fail-safe formula, there are some identifiable steps to consider in the context of your own company. The ideal champion for PSM knows how the company works and what broad strategic priorities drive its business. In addition, the successful champion is skilled at gaining the support of colleagues and building consensus. 2.2.1 Selecting the Right Sponsor(s) Each company has its own culture and management style, and in many cases the functional organization differs from the one illustrated in a formal organization chart. Selecting the right sponsor can depend on how well these organizations are understood. Also, expectations for the sponsor may vary depending on the organization; in some cases, the sponsor will take a very active, hands-on role, while in others endorsement and oversight will be the sponsor's primary contributions. In addition, the source of sponsorship may differ, reflecting centralized vs. decentralized corporate structures. In either case, effective sponsorship requires two tiers: prime mover and key advocate, as shown in Figure 2-1. The prime mover, or primary sponsor, is the one who authorizes the initiative, while the key advocate is the individual without whose explicit support the initiative cannot go forward. To select the right sponsor for your company's PSM initiative, start by identifying the appropriate prime mover and key advocate. In a centralized organization, the most effective primary sponsor is likely to be the CEO or Chief Operating Officer. In organizations like these, a mandate from this level theoretically assures the cooperation and endorsement of facility-based management. (In no way should this suggest that facility managers' support can or should be taken for granted; rather, this approach highlights their key advocacy role.) Decentralized operations, in which divisional managers have considerable independence, require commitment from "top" management at a more local-

In Centralized Companies, May Be:

In Decentralized Companies, May Be:

Key advocate:

Endorses initiative and supports goals, provides resources

CEO COO SVP Operations Other

Division President Product VP Other

Prime mover:

Oversees initiatives, sets goals, supervises resources

Facility Manager GM-EHS Product Manager Other

Facility Manager Facility Technical Staff

Champion:

Drives the initiative, makes it happen

Corporate Staff

Local Staff

Source: Arthur D. Little, Inc. FIGURE 2-1. PSM Sponsorship Roles

ized level. In such companies, the primary sponsor may be a division president, a product-line vice president, or a facility manager. However, regardless of operations managers' levels of autonomy, executive management must also be on board as key advocates to assure long-term continuity, consistency across the company, and conformance to corporate policy. In either case, if s important to keep in mind that localized support is needed for initial implementation, while corporate support sustains the activity over time. HintIn deciding where your primary sponsorship for PSM lies, keep in mind that the terms "centralized" and decentralized" can be misleading because they are relative, not absolute. A company can be seen as decentralized because most operating decisions are made at the divisional level, working with broad corporate guidelines. A division that is part of the decentralized company may, itself, be a highly centralized entity, with key decisions coming from the top of the division and most staff resources based at division headquarters, not in the field.

2.2.2 Selling the Need for PSM Understand Your Sponsor Having selected the right sponsor and identified key advocates, the next task is to sell them on the concept of PSM—and the need for an effective system within your company. The first step in any selling situation is to know your audience. It is up to you to do some informal research on the person or people you want to endorse PSM; look for insights into their business priorities, their track records with comparable initiatives, and their professional backgrounds. This will help you: • Understand their business priorities These might include: —increasing market share —expanding of product lines —expanding into new markets —improving short-term financial performance —achieving other strategic objectives for the company as a whole • The key point to remember is that your company's top management's day-to-day priorities are almost certainly different from yours. Their job is to guide the company as a whole, ever the long term. In determining how best to do this, they must consider business operations in the context of a range of factors (economic, social, political) that influence corporate strategy.

A good place to gain insight into your company's business priorities is your annual report, which, along with other shareholder communications (quarterly reports, proxy statements), probably contains some discussion of overall corporate goals. • Determine how much detail on PSM principles to provide. This may depend on the career paths and professional backgrounds of your company's senior managers. Those who came up through the operations side, or who have facility-based experience and/or technical training, will probably be more immediately knowledgeable about process safety and its management than others whose backgrounds may be in finance, sales, law, or marketing. (Note that there are always exceptions! Be sure to consider this question on an individual basis, rather than making broad generalizations.) • Keep your arguments focused. Everyone has had the frustrating experience of listening to someone who takes forever to get to the point, and gets tangled up in irrelevant side discussions. A focused argument targets the listener's interests and agenda, and keeps background and side issues to a minimum. Examples and anecdotes are often useful; an overreliance on personal experience or "war stories" loses attention. Similarly, an argument that tries to address every conceivable contingency, quirk, and variation will almost certainly fail to convince, because of simple overkill. • Frame PSM in terms of their interests. People pay more attention to information that is relevant to them, than to items of general or academic interest. For example, "PSM provides a cost-effective means of improving our company's safety performance" addresses two senior executive concerns: corporate earnings and exposure to liability. The discussion is framed in terms of the listener's interest; it also focuses on results. This creates a far more compelling argument than a detailed process description or a theoretical discourse on why accidents happen—both of which may be interesting in themselves, but neither of which appeals directly to the listener's concerns. In companies in which senior management has strong operating experience, the concepts behind PSM are more likely to be self-evident. Similarly, some senior managers may have an ongoing interest in process safety and be knowledgeable about CCPS' initiative. In these cases you can limit your preliminary discussion of PSM principles to a brief summary. In other companies, senior management7s knowledge of operations and process safety may be limited, meaning that your first task is to provide basic information. In either case, if s obviously important to assess—in advance— the information needs of the people whose endorsement you seek. Otherwise,

you can risk boring (or, worse, insulting) those who are knowledgeable, or confusing (or, worse, intimidating) those who are less so. Hint: Assessing your target audience's knowledge base and information needs is not always an exact science, nor does it need to be an exhaustive process. Rely on your own judgment and experience and seek out the opinions of others whose insights you trust The key question you need to answer at this point is, "How much information does this person need from me to make an intelligent decision?"

Hint: As a very general rule, it's better to presume less knowledge rather than more because it helps assure that you cover all the bases. It is also easier to shorten a presentation (even while it's in progress) to skip the details than to add whole sections to fill in gaps.

Identify PSM Benefits Once you have a basic idea of who your audience is and what their priorities are, the second step in a selling situation is to match the benefits of your "product"—in this case, PSM—to their needs. New regulatory initiatives (e.g., from OSHA and EPA) and industry programs (e.g., the Chemical Manufacturers Association's Responsible Care® effort) have stimulated increased attention to PSM. While compliance is certainly a requirement in deciding to implement PSM, it is by no means the only benefit. Rather, compliance is the baseline from which other benefits evolve. The quality and effectiveness of the system your company ultimately adopts could well depend on how persuasively those benefits are conveyed. Remember, at this point in your initiative, the goal is to win endorsement of a concept, not approval of a full-fledged plan. The core of that concept is the idea that PSM offers benefits over and above compliance with new regulations, or conformance with an industry initiative. One simple way to start this task is first to identify those benefits as they relate to your company's operations. You might systematically review CCPS' twelve elements of PSM, asking yourself at each stage, "Why is this a good idea?" "What's the benefit of doing this?" Then put yourself in the position of your selected sponsor and consider each element from that person's perspective. Ask yourself, "How can this activity or approach make my sponsor's job easier?" "How would this activity improve my company?" To broaden your input, you might ask others in your company (forexample, divisional or facility-based safety professionals) to conduct the same review—

both from their individual perspectives and from the position of the chosen sponsor. Then compare the responses. This exercise can yield the core of your selling message, framed in terms of multiple benefits both for specific operations and for the company overall. Taking the time to do this up front helps to focus the initiative, and will help frame the rationale required for senior management buy-in. In addition, if you bring others into the exercise, you can lay some groundwork for future cooperation. Taking a disciplined approach to identifying benefits also helps anticipate questions and concerns from senior management and others. Hint: Be creative and make sure your omnibus list includes all kinds of benefits. While your selling effort should emphasize positives, keep in mind that some legitimate benefits may be avoided negatives. For example, a given PSM activity may not yield actual profits but will help the company avoid a financial loss. Similarly, your best focus is probably on very tangible benefits, butdon't ignore those that are less concrete. These might include improving employee morale through teamwork or enhancing your company's image through favorable publicity about PSM.

Some potential PSM benefits to consider include: • improved efficiency arising from consolidating a range of discrete safety-related activities. For example: In reviewing your company's safety efforts against PSM guidelines, a facility safety specialist sees the opportunity to tighten up the procedure he follows for reporting near misses, ensuring a better mechanism for follow-up. A maintenance engineer recognizes that periodic corrosion testing can be incorporated into the preventive maintenance program, and a plant manager remarks that some HAZMAT training courses could be offered to larger classes by sharing instruction with his counterpart at a neighboring company facility. • cost savings from systematic review of new projects and identifying safety enhancements early in the design process. For example: Your company is expanding a facility's capacity. On reviewing the process design against PSM guidelines your safety engineers discover that by adding a redundant cooling system, you can reduce risk. Retrofitting to achieve the same reduction would require a major disassembly and reconstruction. • reduced downtime. For example: Improved maintenance at your facility reduces the frequency of equipment failure. Managing process changes avoids changes that result in process upsets and downtime.

• reduced maintenance costs. For example: Planned preventive maintenance allows more efficient deployment of your local maintenance staff. Fewer equipment failures result in less equipment replacement. • improved operations information. For example: Improved monitoring and data logging allow you to track variances in process operating conditions. Greater reliability means fewer rejects and less rework or waste. • improved customer satisfaction resulting from enhanced quality. For example: Reduced downtime means you are able to deliver product ahead of schedule. Another division, meanwhile, may be able to forestall an anticipated price increase, reflecting a reduction in maintenance costs. • increased prestige within industry, among shareholders. For example: A major institutional investor scrutinizes your company's environmental, health, and safety track record and decides you have less exposure to liability than your competitors, and thus present a better investment opportunity. • improved employee recruitment and retention. For example: Workforce turnover at your company has dropped from an all-time high of 40 percent down to 5 percent. An employee survey reveals that your company's employees consistently cite your company's commitment to safety as an important factor in their level of job satisfaction. • improved labor relations, through involving union leadership in PSM. For example: Your company took the step of inviting the union shop steward to become a member of a PSM task team. In addition, your management agreed to circulate internal safety update memos and other information to union leaders throughout your company. These actions have helped improve ongoing communications between labor and management, and resulting improvements in safety performance have reduced the number of safety-related grievances.

Hint: Most senior managers make decisions at a macro level. For example, a company's senior corporate management considers a $50 million acquisition to expand into a new product line, hoping to capture 15% of a $5 billion market over five years. Decisions such as this require assessment of cost/benefit to the corporation as a whole rather than in terms of impact on a specific process, facility, or activity (e.g., when a product or brand manager decides to redirect the marketing budget.) It is up to you to demonstrate your understanding of senior management's priorities and to frame your arguments in the context of the company and its industry standing. Present your rationale for PSM in terms top management can appreciate, using language they can immediately grasp.

Make Your Case and Support It Once you have identified and prioritized PSMbenefits for your company, they must be organized into an effective presentation. Presentation formats vary by company, so there is not a single "right" way to do this. Some companies are very formal, requiring written agendas and leave-behind documents (for example, Appendix 2.1), and expecting a very structured, scripted presentation with questions and answers at the end. Others are more free-wheeling and presentations take the form of group discussions structured loosely around a topic outline. It is up to you to determine your company's style and your management's preferences, and to develop your presentation in the way that best meets their needs and expectations. However, there are some fundamental techniques to presentation development and delivery that may be useful as you consider this task. These ideas are equally applicable regardless of what form of sponsorship you seek or what organization structure applies to your company. 2. Start with an outline. Everyone learned this in school, but many people overlook its value in real life. A solid outline helps keep proposals focused and can also be used as a checklist to assure that all key points are covered. In addition, a detailed outline can be useful as a tool for midpoint review with colleagues or superiors whose input would improve the finished product. A sample outline and a presentation worksheet appear as Figure 2-2. 2. Prepare your proposal for the benefit of key people who mm/ not be present. Even in the least formal of organizations, effective proposals contain enough detail and information to stand alone, independent of an in-person presentation. The opportunity to sell PSM should not stand or fall with a single meeting. As a practical matter, scheduling time with a company's CEO can sometimes take weeks or even months, and it may ultimately be more efficient to provide a document that can be reviewed at leisure and then discussed. A useful way to approach this is to develop your proposal (1) as if key managers are unable to participate in a meeting, but request a full briefing, or (2) as though you have a sudden emergency and a colleague must stand in for you. This means you cannot rely on brief, cryptic bullet points on an overhead slide, or fall back on "I'll cover that in the Q and A." This approach means more work on the front end, but the discipline it requires is likely to pay off in terms of results since it helps assure comprehensive treatment of the subject and a more thorough appreciation from your audience. 3. Use examples. Selling a concept is in some ways more difficult than selling a specific product or activity because it is less easily quantified or described. For this reason, PSM

WORKSHEET When is the meeting? How much time is allotted? What kind of meeting space? What kind of audio-visual support is available? Who is attending? What is the format? • Forma! presentation • Structured presentation with Q & A • Informal group discussion Other Who is presenting? If more than one person, what is each one's role?

What is the stated purpose of the meeting? What do I want to achieve?

What are the three most important thoughts I want the group to come away with?

FIGURE 2-2. PSM Presentation Worksheet and Sample Outline

This example presumes a 90-minute meeting with senior managers, some of whom have relatively little exposure to process safety management. The PSM champion has decided to devote the first hour to a structured presentation, using the balance of available time for questions and answers. 1. Introduction (5 minutes) Present agenda: what we will be covering, in what order Specify goal for the meeting Acknowledge contributions of others 2. Fundamentals of process safety management (15 minutes) What is PSM? Why is it important? What is required by regulation? Briefly describe CCPS' 12 elements Summarize PSM goal and intent 3. How is this different from what's in place now? (10 minutes) Systematic vs. fragmented approach Emphasis on management systems Integrates PSM into business operations (Use examples from inside the company) 4. What are the benefits of a systematic approach? (IO minutes) Make the case that compliance can be achieved piecemeal, but continuous performance improvement requires an overall strategy. Compare with TQM, other companywide initiatives Emphasize that PSM draws on existing capabilities and structure Demonstrate that performance improvements can yield: • cost savings (how) • reduced downtime (how) • competitive advantages (what are they) (Use results of benefits identification exercise, section 2.2) 5. Industry comparisons (5 minutes) Present comparative intelligence: • What are other companies doing about PSM? • How do we stack up? • What can we learn from others' experience? (Use formal and/or anecdotal examples from conferences, industry associations, CCPS, etc.)

FIGURE 2-2. PSM Presentation Worksheet and Sample Outline

6. Next steps (10 minutes) Outline work to date (meetings with colleagues, fact-finding, etc.) Recommend establishment of task team (membership, responsibilities) Present process overview: • Define goals • Evaluate present status • Develop detailed plan • Develop specific PSM systems • Put the system into practice • Measure and monitor Provide broad schedule parameters Suggest categories of resource requirements Commit to delivering a detailed action plan within a specified time-frame 7. What is needed from senior management today? (5 minutes) Stress the need for senior level commitment Identify categories of necessary support: • setting goals • communications • resource allocation Reinforce personal commitment as PSM champion • Ask for the order FIGURE 2-2. PSM Presentation Worksheet and Sample Outline (continued)

particularly lends itself to illustration. Moreover, examples from your industry help shed light on what the competition is doing, which puts PSM in a context that senior management will readily grasp. Published articles and industry studies lend third-party support to your rationale for PSM; so does anecdotal information gleaned from your counterparts at other companies. Examples can be effectively woven into the proposal text, with documents included as appendices. Another approach is to incorporate all supporting examples in a single section devoted to "Industry Perspective/' 4. Prepare an executive summary. This section, usually only a page or two long, summarizes the subject, the proposed course of action and its rationale, and the next steps. Its organization tracks the proposal outline. Executive summaries can be very useful because they help your audience remember the highlights of a lengthier presentation, and provide them with a "script" on the subject. For example, a CEO or division president may decide

to brief your company's board of directors on the company's PSM initiative; a manager may want to provide an overview to facility staff. A concise executive summary provides PSM sponsors with ready access to key information. Figure 2-3 shows an example of an executive summary. Depending on your company's style, the executive summary may be the primary selling document, with the full proposal acting as backup or provided as an appendix. 5. Rehearse. If your selling opportunity includes an in-person presentation, rehearsal can be a wise use of time, especially if your company tends toward more formal meetings. If possible, ask a group of colleagues to spend an hour or so listening to the presentation and providing a critique. Your boss7 participation in rehearsal can also be very helpful in reinforcing his or her support and addressing concerns prior to meeting with senior management. Hint: In conducting a dry run, pay particular attention to the question and answer session: ask your colleagues to play devil's advocate and challenge your proposal. If you are preparing by yourself, review your proposal critically and try to anticipate the toughest possible questions. Hint: As you prepare your PSM proposal, ask yourself at each stage if it answers two questions: "Why should we do this?" and "Why should we do it this way?" Keep your audience and their agenda in mind at all times.

2.2.3 Selling the Need for Top-level Commitment All right, says senior management, you've convinced us that PSM is a good idea, and we like your ideas. Now, what do you want from us? Alternatively: All right, says senior management, we're sold; go do it. What do you need us for? Define the Need Answering these questions requires having a clear idea of what role you want senior management to play and being able to articulate very specific recommendations for their participation. As discussed in previous sections, the role of senior management in implementing PSM may vary company to company, reflecting differences in style and structure. However, there are three broad areas in which top management can be valuably deployed, regardless of individual structure or style. These are

Following is an example of an executive summary developed to accompany the presentation shown as Figure 2.2. Executive summaries highlight the key points of a detailed presentation for easy access. The longer and more complex your presentation, the greater the value of an executive summary, which should be organized to parallel the structure of the longer document. Executive summaries generally appear at the beginning of a document, just after a table of contents. PROCESS SAFETY MANAGEMENT: CHALLENGES AND OPPORTUNITIES /. Introduction and Background Prompted by new regulation, industry standards, and good business practice, our corporate safety staff has prepared recommendations for the Core Management Group concerning Process Safety Management (PSM). PSM, which applies a management systems approach to process safety, is required by OSHA 1910.119, The Center for Chemical Process Safety (CCPS) has issued guidelines for recommended PSM practices. //. Applying PSM Principles to Our Business Operations PSM improves overall safety performance by organizing safety-related activities in a consistent manner that promotes continuous improvement. While most of the components of a PSM system are already in place, there is no unifying management system that knits them together and maximizes their value. PSM builds on what is in place, and seeks to integrate safety issues into ongoing business operations"as opposed to imposing an elaborate external structure. The goals of PSM are process-oriented, not proceduredriven, and reflect the Total Quality Management principle of continuous improvement. ///. PSM Benefits at Our Company The ultimate goal of PSM is improved safety performance. In addition, over and above the mandatory compliance with OSHA standards, there are potentially significant business benefits to implementing PSM, including improved efficiency, cost savings, and competitive advantages. These can be achieved through reduced downtime, consolidating safetyrelated activities, improving operations information, facilitating process design improvements, minimizing exposure to liability, and improving customer satisfaction. FIGURE 2-3. Sample Executive Summary

IV. PSM Industry Perspective PSM commands a high priority in our industry and our counterparts and competitors are actively pursuing PSM initiatives. The primary competitor of one of our divisions has become highly visible in promoting its PSM system, and several others are active on the topic at conferences and in professional journals. Our safety staff is continuously monitoring new developments and seeking opportunities for information exchange. V. PSM Action Plan. Our corporate safety staff proposes a team approach to implementing PSM1 drawing on expertise throughout the company to: 1. Define company goals for PSM 2. Evaluate our current PSM status 3. Develop a detailed plan for management review and approval 4. Develop specific PSM systems 5. Test the system at a selected pilot site 6. Measure and monitor progress By this means the team can: Establish benchmarks for performance Capitalize on existing structures and activities Organize the process against a schedule and budget Ensure sufficient management input Test the system prior to large-scale implementation VI. PSM Resource Requirements The team will develop a detailed plan, including timetable and cost estimates. In the meantime, it is estimated that the process, from start through pilot testing, will require about 120 staff-months over a period of approximately 18 months, including time from corporate division and facility personnel. A more rigorous estimate will be made before we move into PSM system development. VIL Conclusion PSM is a cost-effective means of improving safety performance while: —improving efficiency; —realizing cost savings; and —achieving competitive advantages. The Core Management Group's continuing endorsement and support of PSM will be critical to success. Our corporate safety staff stands ready to lead the PSM initiative, and seeks the Core Management Group's approval to proceed.

FIGURE 2-3. Sample Executive Summary (continued)

discussed in further detail in Section 2.3, but are presented here to help clarify your thinking about defining the need for management support. • Setting corporate goals for PSM. These may be tangible (e.g., dollar savings, percent reduction in accidental releases, etc.) and /or philosophical (e.g., "Our company will be an industry leader in process safety"). • Communicating the importance of PSM. This includes internal as well as external communications and may be part of broader corporate communications strategy or a freestanding effort. • Providing resources for PSM. This means recognizing that PSM will require some level of investment and authorizing appropriate allocations of staff and other resources to achieve PSM goals. In addition, some common denominators probably apply across the board: 1. Senior management's role supports but does not duplicate the efforts of the PSM champion. The boss should understand that you do not expect anyone to do your job for you. At the same time, senior management should recognize that there are some activities—such as allocating resources, or representing the company in a high-level business forum—that you cannot appropriately undertake. 2. Senior managers generally respond better to specific requests than to broad expressions of need. "First we need a mission statement" is likely to draw a quizzical expression and limited assistance. "The task group has developed this mission statement for your review and signature; we plan to distribute it to all plant locations to kick off the effort" tells the boss exactly what you need and why you need it, and establishes that you expect to carry the ball. 3. Top-level support is often most valuable when it is highly visible. Perhaps the most useful role senior management can take on behalf of PSM is to endorse it explicitly—both inside the company and externally. Senior managers' active participation in communications about PSM lends cred ibility and generates awareness of PSM as a company priority in ways that not even the most dedicated staff team can achieve. 4. Senior management may appear to have a short attention span. It is important to stress that PSM implementation is a long-term process, and therefore the commitment requested involves long-term participation. In other words, a simple "yes, go do it" is unlikely to be sufficient; it is up to you to clarify your expectations for senior executives' involvement over time. The following section provides some suggested ways to use management commitment and may help you further define the role you propose for your company's senior PSM sponsor.

Hint: Try framing your expectations of senior management in terms of a job description. This may help you focus your own thinking and provide the basis for this section of your proposal. Hint: Make sure your expectations for senior management and others are consistent with your company's operating style. For example, a CEO who is accustomed to delegating most decisions is unlikely to accept a role that seems to take away divisional authority, while a facility manager with little functional autonomy will probably be leery of taking a highly visible role without approval from a superior.

Ask for the Order

One of the most common mistakes in closing a sale is forgetting to ask for the business. Even sales professionals make this error, sometimes out of a misplaced sense of nicety or a reluctance to appear pushy. In the case of selling PSM, you are asking for senior-level support of an important initiative. You will need this support to be effective and you should not hesitate to request it explicitly.

2.3 USING TOP-LEVEL COMMITMENT Having won commitment from the top, the next challenge is to put it to good use. As summarized in the previous section, the most effective application of management commitment involves three kinds of activities, as detailed here. 2.3.1 Setting Goals for PSM Goals set for PSM at the senior management level will tend to be very broad, as distinct from the far more specific objectives a PSM champion will establish as part of the planning process. These broad goals help define the company's position with regard to a PSM initiative and provide a focus for achieving consensus. Hint: The relationship between broad goals and specific objectives is comparable to the difference between policy and procedures. Goals help establish what your company expects to achieve, while objectives delineate how those goals will be met.

PSM goals will vary from company to company, both in style and in substance. For example, a company with very little currently in place and few resources might decide on the simple goal of achieving full regulatory compliance within a specific timeframe and budget. For companies with more to build upon, more ambitious goals mightbe established; forexample: "Our company will become recognized in its industry for our process safety management initiative/' PSM goals can be qualitative, quantitative, or a combination of both. For example: • By year-end 1993 all process engineers will have completed hazard analysis training. • By year-end 1994 we will reduce releases by 50 percent companywide. • By year-end 1995 we will have implemented a fully integrated process safety management system throughout our worldwide operations. • Over the next 12 months we will reduce downtime by 25 percent companywide. PSM champions can play an important role in helping management set goals. Since they are likely to be knowledgeable about the specifics of PSM as well as about the company's operations, they should be well-equipped to recommend realistic, workable goals. Depending on the company's culture, developing goals for management review and approval may be an appropriate task for the PSM champion; in other organizations, the management group may take this on itself. In either case, the PSM champion should be prepared to stay close to the process, offering the appropriate level of support. Keep in mind that goal-setting is not a finite event, but rather should be seen as an ongoing process in the spirit of continuous improvement. Process safety management is never "over," "finished," or "done;" as objectives are achieved, new and more ambitious goals replace them. Over time, as PSM becomes integrated into your company's business operations, safety management goals should become part of your company's business planning. Troubleshooter: Make sure your company's short-term objectives (e.g., updating all P&IDs) are consistent with broader PSM goals (e.g., accurate process safety information), and communicate them in ways that clearly encourage work habits and procedures that support PSM performance. For example, your employees need to understand that the company will achieve its goal of reducing reportable incidents by changing its PSM procedures, not its reporting processes.

Vision Statements Many companies find it useful to express corporate goals as vision statements, which articulate top management's operating philosophy concerning a given

initiative. Effective vision statements contain enough specifics to be meaningful but are expressed broadly enough to be applicable throughout the company. In addition, vision statements are usually written in a manner appropriate for wide dissemination. A well-written, well-thought-out PSM vision statement can be the centerpiece or launch for internal and external communications. Hint: Once you have agreed on broad goals for PSM, consider enlisting someone from your company's corporate communications or public relations staff to help you draft a formal vision statement. This will help you: (1) assure a well-written document and (2) win communicators'support by involving them.

Hint: Vision statements that lack substance are easily dismissed as windowdressing. Once it's drafted, review your PSM mission statement critically for the "fluff factor."

Hint: If your company is actively involved in industry initiatives such as Responsible Care®, a formal mission statement may have been prepared that could be helpful as a guide.

An example of a PSM vision statement appears as Figure 2-4.

Group Mission Statements and Charters Group mission statements express more specifically the role and function of a given group within the company. In essence, a group's mission statement or charter officially empowers the group to take on a particular job. It confers on the group the approval of top management, and outlines the company's expectations for its performance. These kinds of mission statements, while not confidential, are generally intended for distribution within a company, not outside it. Hint: If your company has established a formal product stewardship or other major intracompany program, a charter designating a work group, committee, or task force may have been developed that you can use as a model

Following is an example of a broad vision statement a company might develop and disseminate once its management has made a commitment to PSM implementation. [What is the commitment] Company X is committed to the continuous improvement of process safety management (PSM)1 the discipline that helps assure that we conduct our business operations in a manner that protects and promotes the health and safety of our employees and our neighbors. [Why is it important] We recognize that the effective management of process safety is critical to our continuing business growth, and that, to be effective, PSM issues must have an integral role in our daily business operations and decisions. [What does it mean] To meet this challenge, we have adopted a comprehensive approach to the management of process safety throughout our operations, which builds on our existing strengths. The goal of this approach is to assure that, in all of our businesses, we maintain PSM standards and practices that: —meet or exceed all applicable regulation; —are continuously reviewed and upgraded; —establish us as an industry leader in safety performance; and —create a competitive advantage through increased efficiencies and enhanced company reputation. [How we will achieve it] Goals such as these can only be achieved through an ongoing, companywide effort. We endorse and promote process safety management as a priority throughout our businesses, and will dedicate the appropriate resources—time, skills, money—to assure continuous improvement. FIGURE 2-4. Sample Vision Statement

Hint: Mission statements and charters are often most useful when expressed in terms of job functions rather than of individuals, especially for long-term initiatives during which there may be turnover in the composition of the designated task team.

An example of a group's PSM mission statement appears as Figure 2-5.

Following is a sample charter or mission statement, establishing a company's PSM champion and task group, endorsing their activities, and broadly defining their responsibilities. Memorandum To: All Company X employees From: Chief Operating Officer As you know from the policy statement distributed last month, we recognize continuous improvement in process safety management (PSM) as a company priority. I am pleased to announce that the Management Committee has designated (corporate safety director) to lead the development of our companywide PSM initiative. In this capacity, (name) will be responsible for recommending a detailed plan of action for review and approval by the Management Committee, Our expectation is that, once approved, the plan will be tested at a selected site to be determined, and ultimately implemented throughout the company. An important part of (name's) mandate from the Committee is to assure that our plan for managing process safety reflects our businesses* diverse needs and takes full advantage of our resident experience and specialized expertise. To do this, (name) needs your help; effective implementation of PSM can only be achieved as a team effort. For this reason, we have encouraged him to identify and call on experts throughout Company X to work with him. I know I can count on your assistance, which will contribute strongly to our efforts by assuring that the right mix of divisional and technical perspectives is represented. In the coming weeks, as the PSM initiative takes shape, you'll be hearing more about our plans and progress. In the meantime, if you have questions, please don't hesitate to call (name) or me. Please join me and the Management Committee in congratulating (name) on his new assignment, and in supporting our commitment to excellence in process safety management. FIGURE 2-5. Sample Group Charter or Mission Statement

2.3.2 Communicating the Importance of PSM With goals established and agreed upon, the next step is to communicate them. The form and content of PSM communications will vary greatly, depending on the individual company, but some general principles apply to virtually any companywide initiative: • Communications support is critical to the success of any major company effort, especially in cases such as PSM that are both relatively complex and inherently long-term. • Communications serves two functions: information and promotion. Both are important to the success of PSM, which requires a significant amount of intracompany information transfer as well as sustained high levels of employee participation. • Communications addresses both internal and external audiences. Both are important and neither should be ignored. However, the extent and the nature of their interest are often very different, and so are their information needs. • Communications, like PSM, is a process, not an event. Whether it's a staff memo or a "publicity blitz/' a one-time effort is generally a waste of time and money. A more effective approach considers communications as a long-term priority, a core component of the overall initiative, rather than as an "add-on" or an option. • Communications can take many forms, both formal and informal, but the content must be essentially consistent to be effective. • Communications should be two-way, incorporating mechanisms (e.g., questionnaires, response cards, callback numbers, etc.) for soliciting feedback from the people receiving information. This is particularly true of communications that support initiatives like PSM that require cooperation and may require changes in working habits. Hint: If your company has people responsible for internal and external communications, seek them out Consider inviting a member of your company's corporate communications or public relations staff to join a PSM discussion group.

Work with What's in Place In considering how to communicate the importance of PSM, a useful place to start is by reviewing the ways in which your company ordinarily communicates. Make a list of every company communication you receive. Then consider how you get the information you need to do your job and how you communicate with your colleagues and subordinates. Make a list of the information sources you rely on professionally. Finally, make a list of all the

materials you can think of that your company routinely distributes to a wide external audience. The combined lists should yield a preliminary inventory of the communications vehicles available to you within your company, for example: • Formed internal communications: newsletters, chairman's letters, bulletin boards, video conferences, staff meetings, etc. • Informal internal communications: memos, hallway meetings, drop-in visits, conference calls, training sessions, electronic mail, etc. • External information sources: industry groups, professional associations, technical journals, print and broadcast media, professional development coursework, etc. • External communications: quarterly and annual reports, press releases, new product announcements, existing product information and updates, customer newsletters, community newsletters, etc. Keep in mind that there may well be other communications vehicles in active use within your company. For example, employees at operating facilities may rely on pre-shift meetings to get information summaries; some divisions and facilities may have their own newsletters in addition to a companywide publication.

Hint: Find out where your company's formal communications originate. Who is in charge of putting out press releases, newsletters, product information? Arrange to meet with those responsible, to see how you might incorporate PSM information into these publications and offer to provide sample texts.

Any or all of these communications vehicles can offer an opportunity for conveying information about PSM. Using existing vehicles is usually more effective than creating altogether new ones. In addition to the obvious benefits in terms of time and money, using familiar communications media reinforces the idea that PSM is part of your company's ongoing business, not a newfangled notion that is being imposed.

Identify Priority Audiences As indicated previously, PSM information and messages have different values for different audiences. Your company's workforce has a more immediate and specific interest in the initiative than people who are less directly affected, such as plant neighbors, shareholders, or the general public. This doesn't mean confining communications efforts solely to company employees; it simply suggests that you organize communications priorities to reflect levels of interest and information needs.

Listing all the people you want to reach and then ranking them helps to focus your communications efforts. For a company that is undertaking PSM at the facility level, such a list might look like this: • Internal —Facility management group —Facility safety professionals —Shift supervisors —Shop stewards —Employees • Intracompany —Division president —Other facility managers —Facility safety professionals • Intermediaries —Union leaders —Regulatory authorities • External Constituents —Key customers —Local officials —Community activists —Neighbors As this list suggests, the first priority for this facility is its own people, who will require the most comprehensive information and who should receive priority attention. Others on the list have widely varying information needs and levels of interest, all of which the facility manager must take into account in developing a communications plan. Introduce PSM A company's PSM initiative deserves some special treatment to attract the initial attention that will help give it momentum. Depending on what is already in place, a special edition of the company newsletter could be produced, including a letter from the CEO and a copy of the PSM vision statement. Other information might include identification of the proposed PSM champion and a summary of the company's preliminary plans. (Two examples of such summaries appear as Figures 2-6 and 2-7.) The same information could be provided in a letter to all employees, posted on local bulletin boards or mailed to employees' homes. On a grander scale, senior management may address employees through a specially produced videotape, distributed to all locations.

Hint: A questions-and-answer format, or an "Interview with the Chairman (or other senior sponsor)" can help present PSM information and messages in a conversational manner that many readers find more interesting than a more static narrative. External communications about PSM can parallel internal efforts. For example, the CEO or other senior sponsor might take advantage of a public speaking opportunity or a media interview to discuss the company's commitment to PSM and the ways it has devised to implement it. Similarly colleagues who participate in professional conferences may wish to incorporate PSM information in papers or speeches, to highlight the company's approach and accomplishments. HintPrepare a briefing document, drawn from the PSM proposal and executive summary, that executives, colleagues, and staff can use in responding to media queries or in crafting speeches and other presentations. Regardless of the form of initial PSM communications, it is important to promise future information and regular updates—and to deliver. Hint: If you have established a schedule for PSM meetings, this can provide a tickler for updating internal communications. Otherwise, establish a timetable (e.g., monthly) for providing your internal "sources" with current information about progress. Troubleshooter: Beware the "big splash;" it's a hard act to follow. Large-scale publicity—whether inside or outside a company—raises expectations of immediate, radical benefit or change that are often unrealistic, and puts your credibility on the line. Make sure PSM communications are consistent, timely, accurate, and persuasive to build and maintain credibility over time. Troubleshooter: Be sure to get appropriate approvals for any information you disseminate, especially outside the company. The news media can be very valuable conduits for conveying information so long as you work within your company's guidelines.

Following is a plan summary that a decentralized company might use in introducing its corporate PSM initiative, either as a stand-alone document or as part of a larger communications package. What are our process safety management plans? First, we have identified (name) as our PSM "champion" to lead the initiative. His first task will be to assemble a task group representing our best thinking in a range of key disciplines, such as safety engineering, design engineering, occupational health and safety, facility management, and process safety. In addition, the task group may call on other specialists from throughout Company X, to lend special expertise as needed. The team's composition will be announced as soon as it is finalized. (Name's) task group has responsibility for developing detailed recommendations for implementing PSM throughout Company X, and overseeing its installation at a pilot site to be determined. We expect the process to take approximately 18 months, during which the group will submit regular progress reports to the General Manager of Environmental, Health, and Safety, and provide the Management Committee with periodic updates. These progress reports will be circulated to facility managers for review, comment, and input at each stage, to assure that the end result fully reflects local concerns and capabilities. At Division A, the Facility Managers' Council has accepted similar responsibilities, under the direction of the division's Vice President of Environmental, Health, and Safety. We expect ongoing interchange between the two task teams, which will facilitate the process throughout Company X and help us take advantage of the full range of our process safety experience. The overall process is expected to include the following steps: 1. Define goals. The task groups will define the company's goals for process safety management. These may be qualitative or quantitative; they will take into account the varying needs of the company's different operations. Estimated time required: one month 2. Evaluate current status. Because PSM builds on what is already in place, the teams will research and assess our current status, to identify strengths and opportunities for improvement. Estimated time required: three months 3. Develop a plan. Based on established goals and current status, the teams will develop detailed plans for implementing a process safety management system, including projections of time and staffpower requirements and other resource needs. When completed, these plans will be our blueprint for PSM implementation, subject to refinement based on experience. Estimated time required: two months FIGURE 2-6. Example of Preliminary Company Plan Summary

4. Develop specific process safety management systems. Working within the plan, the task groups will develop specific systems and procedures for implementing PSM. The Division A team will focus on its own operations, while (name's) group will direct its efforts toward the other divisions. Estimated time required: eight months 5. Put the system into practice. Pilot sites will be selected in collaboration with facility management, to test the new PSM system. By this means, we can assure that the system works and identify any areas needing refinement, in a cost-effective manner. Estimated time required: as systems are developed In step 4 6. Measure and monitor. Installation at the test sites will be closely monitored against an established timetable, as well as in terms of our established PSM criteria and goals. Throughout this process, we will solicit feedback and other commentary from the pilot sites for incorporation into ongoing process improvement. Estimated time required: as step 5 is performed These timeframes are "guesstimates" at this point, and are subject to change. Similarly, at each stage of the process there will be a number of activities that may affect overall scheduling. On completion of this process, we are confident that Company X will be well on its way toward achieving its goal of industry leadership in process safety management. FIGURE 2-6. Example of Preliminary Company Plan Summary (continued)

2.3.3 Providing Resources The third area in which top-level support is needed is assuring that the PSM initiative receives the resources required for success. It is only realistic to expect that PSM implementation will require a significant level of funding— either direct or indirect. Senior management will probably expect the PSM champion to develop a detailed budget estimate as part of the implementation plan. Well in advance of that, however, management needs to know orders of magnitude, types of resources, and approximate levels of effort to make the commitment required. No executive is likely to offer a blank check without at least a rough idea of what is needed. Resource estimates both for the short-term planning task and for the longer-term implementation should be developed; your estimate of short-term needs can be relatively detailed, while your long-term estimate will simply communicate the expected range of resources needed. There is no single formula for estimating resource requirements, which are a function of two variables: what's planned (PSM goals) and whaf s already

This sample is designed to summarize the key steps in the process a centralized company or division plans to follow in developing PSM. Note that the primary differences indicated relate to reporting requirements and timeframe; the process components remain the same regardless of organizational structure or management style. How does the division plan to develop a PSM system? The Facility Managers' Council has responsibility for developing a recommended PSM system for facilities, under the direction of the division Vice President for Environmental, Health, and Safety. The four-member Council expects to draw on others within the division for their special expertise; for example, professionals with experience in process safety, safety engineering, and occupational health and safety, along with others, may be called on to advise the Council. The overall process the Council will follow includes these components. Primary responsibility for each one will be assigned to an individual Council member. 1. Define process safety management goals: What do we want to achieve? 2. Evaluate current status and activities: What are we doing now? 3. Develop a detailed plan, including resource requirements and timetable: How can we meet our goals? 4. Develop specific PSM systems and procedures for installation: What do we need to do differently to achieve our goals? 5. Put the system into practice at a selected facility: How can we translate our recommendations translate into practice? 6. Measure and monitor progress against PSM goals and planning timetable: What can we learn that can be applied throughout the division? The entire process is expected to take six to eight months. FIGURE 2-7. Example of a Preliminary Divisional Plan Summary

in place (PSM status). A company that sets very modest goals when it already has many PSM components already fully operational, obviously can achieve them with relatively few resources. (In such a case, the PSM champion might consider urging more ambitious goals for the initiative.) In other companies the decision may be made to use PSM as an opportunity to upgrade a whole range of safety- and process-related activities well beyond compliance levels, requiring significant resource allocation.

The process outlined here is intended to help "structure the ballpark/' As you read through it, keep in mind that the goal at this stage is to provide management with a general sense of the nature and scale of PSM's resource requirements. In addition, applying this kind of discipline early in the game helps lay the groundwork for more detailed planning. Identifying Resources One way to approach this task is to identify categories of resources and define broad parameters for their deployment for managements review. This will provide executives with a general sense of what the PSM initiative will require, without committing themselves—or the company—prematurely. The kinds of resources needed are fairly straightforward. The primary resource requirement for most PSM implementation efforts will be staff-time, both professional and clerical/secretarial. It is also reasonable to expect to incur travel expenses at intervals throughout the process, especially for companies with multiple facilities. Support resources, such as telephone, computer time, facsimile, photocopying, and document production, will almost certainly be required in any initiative. As your planning evolves, you will probably identify other resource needs unique to your company, in addition to these three areas. However, taken together, these three core resource categories provide a good starting point for developing a rough projection of PSM resource needs. Allocating Resources Human resources, whether in-house or retained by contract, cost money, and represent either a direct or an indirect investment. In lobbying for PSM resources, be realistic about the time you think the effort will require: underestimating the level of effort can raise management's expectations beyond your ability to meet them. At the same time, estimates of staff required can't ignore prevailing company priorities; for example, a request for five new staffers during a hiring freeze is unlikely to be favorably received. One way to approach the human resources question is to consider not the people but the tasks to be performed, and the skills you think you will need. Especially in large companies, where bodies of expertise may be isolated from each other, this technique helps broaden the resource base. It also makes it easier for managers to assist you: defining your needs in terms of skills sets, rather than of specific individuals, gives them greater flexibility. The skills matrices shown as Figures 2-8 and 2-9 are provided as an example of one way to approach this task. The skills indicated are examples only; there maybe others your company's initiative might need. The first matrix, Figure 2-8, helps to locate skills within your company. Note that as a practical matter, one person may have multiple skills, just as several people may share one key skill. Note also that this matrix can help identify "pockets" or concentrations

Process safety Risk assessment Design engineering Maintenance engineering Operations Operations management Communications Budgeting Project planning Other FIGURE 2-8. Sample Skills Matrix

Other

Facilities

Manufacturing

Division C

EHS

Division C

Administration

Division B

Manufacturing

Division B

R&D

Division B

EHS

Division A

What Skills Do We Need?

Company HQ

Where Can We Find Them?

of desirable skills within your company that in turn can help you decide where to locate the primary effort. For example, if you determine that most of the skills you need reside in a single part of your company, a mote localized approach may be suggested. On the other hand, if necessary skills are dispersed throughout the organization, this may create the opportunity for intracompany collaboration. This exercise also helps you identify gaps in your company's skill and staff base. Where gaps exist—either because the skills are not represented, or the people who have them are not available because of other commitments—you may wish to consider drawing on outside consultants. For the purposes of resource allocation, consultants or contractors are best considered in terms of the value they add in either of two categories (or both): supplementary skills and supplementary time. The second matrix, Figure 2-9, helps you begin to estimate levels of effort and associated costs for your initial planning. Keep in mind that these can only be very preliminary estimates at this point. However, it's useful to start the process with this kind of discipline, recognizing that the results will be subject to continuous refinement.

Hint: Who should lead the PSM system implementation effort? It is best to consider skills and experience, not job title. You want someone with good "people" skills, a solid understanding of process safety, a track record of earning respect within the organization, and good project management skills. You need someone who can be both advocate and manager.

Hint: In considering human resource needs, don't forget to include your own role. If you believe your commitment to PSM may temporarily displace other priorities, make sure to include provisions for them.

Travel is relatively simple to forecast, once you have a broad idea of who within your company will participate. Keep in mind that in-person meetings provide a means not only for information exchange but also for teambuilding; while much of any team effort can be accomplished by phone or in writing, it is generally a good idea to bring people together at key points in the process. Support resources more often than not directly reflect level of effort. Sometimes these can be expressed as a percentage (15 to 20 percent) of the cost of staff.

Process Safety Management Initial Planning Effort

Percentage of Total Effort

Number of Staff Days*

How Much of Each?

35

1 0O days

Risk assessment

9

1 5 days

Design engineering

2

5 days

Maintenance engineering

2

5 days

35

1 0O days

Operations management

9

10 days

Communications

4

1 0 days

Budgeting

4

5 days

Project planning

2

5 days

What Skills Do We Need? Process safety

Operations

Associated expense costs

Associated Costs ($) (Travel, Reports, Etc.)

$25,000 (total)

FIGURE 2-9. Sample Level of Effort Allocation Matrix * Estimated level of effort for initial planning phase only.

Hint: In weighing the pros and cons of inside staff versus outside contractors, the most useful determinant is long-range cost-effectiveness. It's easy to underestimate the true cost of using employee resources, since these expenses are "buried" within ongoing business.

Hint: Regardless of whether most of the groundwork is developed by employees or contractors, effective PSM initiatives are company-driven, not imposed from outside the company. Effective implementation relies on a sense of investment among the people who ultimately will put theory into practice.

APPENDIX 2-1 SAMPLE DOCUMENT PRESENTING PSM TO SENIOR MANAGEMENT Following is a sample "leave-behind" document developed for use in PSM presentation to company management. Documents such as these are commonly developed to capture presentation content for future review and/or for the benefit of key people who could not attend. Note that this document closely reflects the presentation sample shown as Figure 2-2 on pages 16-18. As an alternative to preparing a separate document, you might consider distributing copies of your overheads or slides, if they are comprehensive enough to be meaningful without narration. Introduction This document presents an approach for implementing Process Safety Management (PSM) within our company, prepared for the Core Management Group's review. It is organized to include the following sections: • Background: Fundamentals of Process Safety Management —What is PSM and why is it important? —Regulatory requirements and industry standards • Applying PSM to Our Needs and Business Operations —How is PSM different from what is already is place? —Why change now? • PSM Benefits —Improved efficiency —Cost savings —Competitive advantages • PSM Industry Comparison • PSM Action Plan —Task team formation -^Process overview —Benefits • PSM Resource Requirements —Preliminary estimates • Summary and Conclusion

/. Background: Fundamentals of Process Safety Management What Is Process Safety Management (PSM) ? The Center for Chemical Process Safety (CCPS) defines PSM as "The application of management systems to the identification, understanding, and control of process hazards to prevent process-related injuries and incidents/' Why Is PSM Important? • Regulation requires PSM • Industry endorses PSM • PSM supports good business practice What's Required by Regulation? • OSHA 1910.119 [Summarize regulation.] What's Endorsed by Industry? • CCPS has identified 12 elements that together make up process safety management. [List 12 elements.] What Good Practice Does PSM Support? PSM improves overall safety performance by organizing safety-related activities in a consistent manner that assures and promotes continuous improvement. PSM improves efficiency and reliability, reducing downtime, rework, and waste. IL Applying PSM to Our Needs and Business Operations How Is PSM Different from What We're Already Doing? • Safety standards and practices tend to evolve opportunistically rather than systematically. • Like most companies, we tend to make improvements incrementally, based on specific experience. • This is a sound approach that has yielded many improvements. For example: —Division A revised its near-miss investigation procedure after last January's incident. —Division B expanded its emergency response training when a neighboring facility had a spill. —Division C added safety professionals when we reorganized into business units.

—Division D added process safety to the Facility Managers Council's standing agenda at the suggestion of their in-house auditors. • We have high safety standards and committed people—thanks to whose efforts our track record in process safety is a good one.

Why Change Now? We have all the components for continuous improvement. What we don't have is a comprehensive management system that incorporates all of these components and maximizes their value to the company as a whole. PSM offers a systematic approach to safety issues that builds on these kinds of improvements; knits incremental changes into an overall strategy; integrates safety issues into business operations; recognizes critical differences among businesses; and promotes employee participation in a flexible management system. Ill PSM Benefits This kind of approach can have many benefits to our company. By organizing and systematizing our safety activities, we can improve our overall safety performance, and, in the process: • Identify areas where we can improve efficiency, • Identify areas where we can save money, and • Identify areas where we can gain a competitive advantage. PSM benefits can take many forms, including examples such as:

Improved Efficiencies and Operations Information • We could gain efficiencies by consolidating a range of safety-related activities. For example, if several of our facilities offer similar HAZMAT training, plant managers might be able to share instructors—either within a single division, or across divisional boundaries. • If we improve process monitoring and data logging, we'll be better equipped to track and predict variances in process operating conditions.

Cost Savings • We could save money by identifying safety enhancements early in the design process. —For example, Division A is expanding its Akron plant. PSM guidelines for process design review might turn up risk reduction methods that can be incorporated into the design phase, instead of more expensive retrofitting. • We could save money by reducing downtime.

—Improving maintenance helps reduce equipment failure. In addition, managing process changes can help avoid process upsets and thus reduce downtime. • Or by reducing maintenance costs. —If we are able to plan ahead for preventive maintenance, we deploy maintenance staff far more efficiently. Competitive Advantages

• We could gain a competitive advantage by reducing downtime. —If we reduce downtime, we can deliver product faster and keep our prices lower. • We could gain a competitive edge by enhancing our value to the investment community. —Reduced waste and increased efficiency reduces manufacturing costs and increases profitability. Reduced environmental, health, and safety liabilities make us a more attractive investment. • Or by improving employee recruitment and retention. —Our commitment to worker safety can help us attract good people and reduce turnover. These examples are provided to demonstrate that PSM offers our company a range of benefits over and above the minimum threshold of regulatory compliance. IV. Industry Comparison Our competitors are moving quickly to develop and implement these kinds of PSM systems. While we haven't done an exhaustive study, we do know that: • CMA reports that a majority of its members are starting up PSM activities, or reviewing existing programs. • CCPS sponsors frequent conferences and workshops on the topic. • Division A's primary competitor presented a paper on PSM at the Spring AIChE technical conference. • Division B's competition has established an in-house consul ting group to provide PSM training seminars. V. PSM Action Plan PSM is required by OSHA, and we must comply. Our work to date strongly indicates that, for us, the most efficient and effective approach is one that

reaches beyond compliance to achieve the goal of continuous improvement in: —safety performance; —efficiency; —cost savings; and —customer satisfaction. To achieve these goals, we propose the following preliminary action plan. Establish a PSM Task Team. A sound PSM system needs the input, expertise, and support of a wide range of our people. A multidisciplinary, interdivisional team would provide the insight and the skills this initiative requires. Such a team should include experts from all four divisions, as well as representatives from corporate staff. Key disciplines include: —process safety —design engineering —facility management —risk assessment —operations Process Overview. Once formed, the team would quickly establish specific responsibilities for each member, and would work against the following process: 1. 2. 3. 4. 5. 6.

Define company goals for PSM Evaluate our current PSM status Develop a detailed plan for management approval Develop specific PSM systems Put the system into practice at a selected pilot site Measure and monitor progress

Process Benefits This process enables us to: • • • • •

Establish viable benchmarks for PSM performance Capitalize on existing structures and activities Organize the process against a schedule and budget Ensure sufficient management input Test the system prior to large-scale implementation

VI. PSM Resource Requirements Undertaking a PSM initiative will require time, staffpower, and funding— direct and/or indirect. The task team's first priority will be to develop a detailed plan for the Core Management Group's review and approval, including specific schedules and cost estimates. This level of detail requires understanding and agreement as to where we are and where we want to be. At this point, it would be reasonable to consider—f or planning purposes— the following broad parameters: 120 staff-months, spread among a team including corporate, division, and facility personnel over an 18-month period, at the end of which we can expect to have a PSM system that has been carefully thought out and fully tested, ready for implementation throughout the company. VII. Summary and Conclusion PSM is a cost-effective means of improving safety performance that also offers us the opportunity to: —improve efficiency; —realize cost savings; and —achieve competitive advantages. We can achieve these goals with: —multidisciplinary teamwork; —intracompany cooperation; and —top management's endorsement and support. We are ready to start work today, and prepared to stay with the initiative through its completion. To do this, we need this group's help to: —Guide the process of setting PSM goals that support our business objectives; —Communicate the importance of PSM throughout the company and to the outside world; and —Provide the resources needed to do the job right. Most important, our process safety management initiative needs management's commitment to proceed.

3

DEFINE GOALS 3.1 INTRODUCTION Once your company's senior management is on board, your next priority is to define specific goals for the PSM initiative. This helps you determine what your finished product (i.e., the new PSM system) will look like and how it will work within your company. This chapter focuses on gaining an understanding of some of your company's key attributes as they relate to effective implementation of PSM. This will help you adapt the PSM framework you select to your company's individual needs, and help assure that the PSM systems you devise properly reflect "the way we do things here." As you will see, a team approach is probably the most effective way to do this; teamwork provides both a reasonable division of labor and the opportunity to draw on a range of the disciplines that contribute to PSM. Whether or not a team effort is feasible, defining goals for your efforts helps you stay on track, anticipate bottlenecks and obstacles, and assure that the end results reflect the real world of your particular company.

3.2 SELECTPSMFRAMEWORK As a first step, you must decide which framework for a PSM system to use. A framework defines the elements and components of your program, and must be established before you can take stock of what is already in place, and before you can plan for filling the gaps. During the past few years, several descriptions have emerged for what constitutes a PSM system. You should consider these and select one (or define your own based on these). In selecting among the available alternatives, there are several factors to consider, including: • Preexisting company frameworks: If you already have your own framework for PSM, it is advantageous to retain it if it has proven effective. The existing system will be readily understood and accepted within the organization. Before choosing a new framework, you should compare the contents of your PSM framework against the alternative models, ensuring that your system is complete. Where necessary, you can modify your existing PSM framework to include additional elements.

Hint: An easy way to make this comparison is to begin with a listing of the components of (for example) the CCPS PSM framework, and next to each CCPS component list the corresponding component of your framework.

• Commitments to industry programs: If your company is committed to an industry initiative, such as the American Petroleum Institute's RP750 or the Chemical Manufacturers Association's Responsible Care<S> program, you will want to ensure that you are consistent with the framework used by that program. • Flexibility among divisions/operations: If your company has divisions or operations involved in different types of products, you will want to use a framework that is broadly adaptable among these different operations. • Management system design: You should use a framework that helps define what a management system is, so that you will be better able to ensure that the systems you design are comprehensive. In other words, you should be looking for more than a listing of the areas of concern (e.g., Project Safety Review). You should seek guidance on what a management system for an area will address. • Peer company programs: You may wish to consider what peers and/or industry leaders are doing. Benchmarking is an approach to examining the ways in which particular business processes are performed by other companies. At this stage of your PSM implementation effort, you may wish to gather some information from other companies. This will help you gain perspective on what others have done, and will also provide ''ammunition" for responding to any skeptics within your company who may believe that PSM efforts are consuming too much effort. • Compliance: Some aspects of PSM are required by regulations. If you are not already in compliance, this will probably influence your priorities. Hint: Many companies are quite willing to share information on their PSM programs with other firms. CCPS and industry associations provide good places for networking to make the initial contacts that begin this. Attending process safety conferences is a good way to meet people who share your interest in PSM.

With these criteria in mind, you should evaluate the alternative PSM models. A brief review of some of the major alternatives follows:

3.2.1 CCPS Model The CCPS model for PSM was first provided in A Challenge to Commitment and later explained in Guidelines for Technical Management of Chemical Process Safety. The CCPS model describes process safety management systems in terms of 12 elements and 68 components. The elements and components appear as Table 1.1 on pages 2 and 3 of this book. The CCPS model was designed for applicability throughout the process industries, and is also applicable beyond process safety to other areas of safety, health, and environmental protection. This model is unique in its description of what constitutes a management system, and its effort to address the planning, organizing, implementing, and control aspects of process safety management systems. 3.2.2

OtherModels

A variety of other descriptions for process safety management systems have been published since 1988. Among these are frameworks published by the Management Leadership in Process Safety Commitment Accountability Performance measurement Incident investigation Information sharing CAER integration Process Safety Management of Technology Design documentation Process hazards information Process hazards analysis Management of change Process Safety Management of Facilities Siting Codes and standards Safety reviews Maintenance and inspection Multiple safeguards Emergency management Managing Personnel for Process Safety Job skills Safe work practices Initial training Employee proficiency Fitness for duty Contractors FIGURE 3-1. Chemical Manufacturers Association Process Safety Management Elements

Chemical Manufacturers Association (CMA), the American Petroleum Institute (API), the Environmental Protection Agency (EPA), and the Occupational Safety and Health Administration (OSHA). The components of these systems are listed in Figures 3-1 through 3-4.

• Process Safety Information • Process Hazard Analysis • Management of Change • Operating Procedures • Safe Work Practices • Training • Assurance of the Quality and Integrity of Critical Equipment • Pre-Startup Safety Review • Emergency Response and Control • Investigation of Process-Related Incidents • Audit of Process Hazards Management Systems FIGURE 3-2. American Petroleum Institute Process Safety Management Elements

• Hazard Assessment • Prevention Program —Management System —Process Hazards Analysis —Process Safety Information —Standard Operating Procedures —Training —Maintenance (Mechanical Integrity) —Pre-Startup Review —Management of Change —Safety Audits —Accident Investigation • Emergency Response Program • Risk Management Plan FIGURE 3-3. Environmental Protection Agency (EPA) Risk Management Program Components

• Employee Participation • Process Safety Information • Process Hazard Analysis • Operating Procedures • Training • Contractors • Pre-Startup Safety Review • Mechanical Integrity • Hot Work Permit • Management of Change • Incident Investigation • Emergency Planning and Response • Compliance Audits • Trade Secrets FIGURE 3-4. Occupational Safety and Health Administration (OSHA) Process Safety Management Elements

Comparison of these models quickly shows that they are all very similar. There are differences in terminology and emphasis, but the fundamental concepts of process safety management are consistent. For example: • The Chemical Manufacturers Association's Code of Management Practice for Process Safety is oriented toward the chemical industry, and describes the elements of a process safety management program as part of CMA's Responsible Care® program. • The American Petroleum Institute's Recommended Practice 750 describes process safety management elements recommended for operations in the oil and gas industry. • The Occupational Safety and Health Administration's regulation 29CFR1910.119 provides a regulatory framework for process safety management. This regulation applies to facilities handling a specified list of chemicals above indicated threshold quantities.

3.3 ESTABLISH A PSM TEAM Every company is unique, and the success of an initiative such as PSM often depends on the mesh between theory and practice: the objectives you have established and the context in which you plan to meet them. The framework defined (as in the previous section), while specific, is essentially theoretical; different companies might identify the same basic PSM elements, but apply them very differently in their own organizations. Thus the next step, once a PSM framework is established, is to gain a practical understanding of your company's culture and management style, and in general "how we do things here/' This will define the company-specific context in which you can plan for practical application. Note: Much of the following section discusses the basics of establishing and working with intracompany, multidisciplinary teams. If you are familiar and experienced with this approach to problem-solving, you may wish to skip to Section 3.4, "Define Company-Specific Attributes." A listing of useful reference materials concerning teamwork and organization appears in the Bibliography.

You should not feel that you must tackle this activity alone. In fact, most people would agree that teamwork is essential, by the very nature of the task. Your views and understanding of your company represent a single perspective, one of many. Keep in mind that your experience is unique, and that, for example, a facility manager's view of the world is very different from that of a divisional safety engineer. Getting a true picture of the way your company does things should involve multiple perspectives and you should try as much as possible to take advantage of the experiences of others. Hint: Note that the term "team" can be used very loosely. In smaller companies, or those where key individuals cannot participate consistently, your "team" may comprise individuals whom you can consult informally at key stages in the process.

Hint: If your company has a TOM or other group-oriented program, consider consulting the person in charge of it to get some pointers on team leadership and process.

Hint: While a multidisciplinary team approach is ideally suited to PSM design and installation, it is not the only way. PSM goals can be achieved through the efforts of a single professional, or a small homogeneous task group (for example, facility managers or safety specialists); the process is essentially the same as described here, but on a smaller, more limited scale.

3.3.1 Who Should Be on the Team? Your challenge in assembling a team is to include as many relevant perspectives as possible while at the same time keeping the group to a reasonable, practical size. The skills identification matrix in the previous chapter provides a useful starting point in identifying potential teammates. In addition, you may find it useful to base selection in part on the degree to which PSM affects an individual's job: as a general rule, people who are most directly affected have the greatest investment in participating. Other considerations include location, available time, and broad representation from different parts of the organization. A sample matrix shown as Figure 3-5 may help to organize your thinking. Hint: Keep in mind the temperaments and personalities of the people you want on the team, but don't make this a primary criterion for selection. For example, lone wolves can sometimes be prickly, but they may offer unique insights. And don't rule out known adversaries just because they don't like each other; despite their differences they may well offer individual contributions. Hint: Remember also that an effective team needs both ideas and action, and often it's different people who supply them. Try for a balance between creative "idea people" and steady, committed workers. Troubleshooter: Traits to avoid include cynicism, laziness, and "nay-saying," any of which can undermine a group's esprit de corps and impair its momentum.

3.3.2 How Should This Team Work? Once you have identified the skills and viewpoints you need, your next step is to consider how this group—which may be very disparate—can work best together. As the person convening the team you are effectively its leader, and

Other (i.e., Special)

Low

Medium

What Skills Do We Need?

High

Level of Impact PSM Will Have

Process safety Risk assessment Design engineering Maintenance engineering Operations Operations management Communications Budgeting Project planning Other

FIGURE 3-5. Sample PSM Skills/Impact Matrix

people will look to you for direction and definition. Organize your own thinking before getting others actively involved. Everyone who has ever accepted a team or committee assignment knows the frustration of fuzzy definitions: of responsibilities, of individual roles, of leadership, or of the team's overall mandate. Teams lacking clarity in these critical areas tend to fall apart quickly.

Hint: Consider your own experience with task teams, both within your company and in other contexts such as industry associations, professional committees, or even non-professional groups such as volunteer or community organizations. Review what worked and didn't work, what you liked and didn't like, and what you found rewarding or frustrating about each experience. This simple exercise helps identify potential pitfalls as well as successful techniques for managing a task team.

The following checklist maybe useful in organizing your thinking. You can complete it formally, in writing, or simply conceptually or mentally; whaf s important is to thinik these kinds of questions through in advance of starting up a team effort. Q What is this team's mission? A team's mission, or mandate, or charter, provides a capsule summary of its reason for being: why it has been created, how it will operate, and what is its goal. While a formal team mission statement should be refined and adopted by the group itself (to assure members' understanding and endorsement), you should have clear ideas in outline form to share and discuss with teammates. A sample of such an outline, and a more formal mission statement deriving from it, appears as Figure 3-6. Q What are this team's responsibilities? Team responsibilities help define how it plans to achieve its stated mission by providing more detail regarding work process and end product. By clearly stating team responsibilities, you define expectations both within the group and for the benefit of the PSM sponsor. If s important to establish limits; teams with open-ended responsibilities tend to become diffused. For example, a task team may define its responsibilities for PSM as beginning with establishing PSM criteria and ending with installing a pilot system at a single facility. Along the way, the team takes responsibility for following certain procedures, such as regular reporting to specific people, and periodic formal progress reviews. By setting these kinds of boundaries from the beginning, the team can avoid misunderstandings (e.g., "weren't you going to oversee implementation throughout all of our operations?") and maintain focus. Q What is this team's structure? Task teams are miniature organizations, and take many forms, from "flat," peer-oriented groups to more structured, hierarchical forms. There is no single "right" way to structure a task team, because it must reflect your company's needs and style. Whaf s important is that an appropriate structure be established and understood. However, keep in mind that a flexible team structure encourages the involvement of advisors or specialists who may not have an ongoing role, but who lend specific expertise to a given topic.

Following are two versions of a PSM team's mission statement. The first is a draft prepared in advance of such a team's first meeting; the second reflects group consensus and is designed for dissemination to company employees. Outline Team mission: To design and install a PSM system that will be practically applicable throughout the company. [What] Team priorities: Initial team effort focuses on Divisions A and B; Division C to develop parallel effort; Division D to come onstream as second stage. [Limits] Team composition: Multidisciplinary, including full range of PSM "customers," i.e., facility management, process safety, engineering, research and development, occupational health and safety, others to be determined. [Who] Team responsibilities: Define PSM criteria and goals for Company X; evaluate current PSM status; develop a plan to build on what's in place and address gaps; develop specific PSM systems; select a test site and install a pilot system; measure and monitor its progress; refine systems as needed. [Limits] Team practices: Combine meetings, informal communication, individual assignments based on expertise, free flow of information. [How] Team reporting: Report to General Manager-Environmental, Health, and Safety; keep others informed as needed via formal and informal reports. [Accountability] FIGURE 3-6. Sample PSM Team Mission Statement: Outline and Final Version

Hint: Try to strike a balance that provides enough structure to be meaningful, but not so much that it restricts the team's creativity or discourages the contributions of "outsiders."

Hint: Some effective team structures distinguish between a core group and a standing advisory group. This can be helpful in assuring consistent feedback from key people (such as facility-based safety experts) who may be unable to participate in regular working sessions but whose input and endorsement will be critical to success.

Final Version Company X has established a Process Safety Management (PSM) Task Force to guide the company's PSM initiative. Reporting to the General Manager, Environmental, Health, and Safety, this team comprises a broad range of talent, and brings together individuals representing a full spectrum of backgrounds and expertise. The Task Force's mission is to design a state-of-the-art process safety management system that will support all of Company X's varied business operations, and to install it at a pilot site to be determined. The team will maintain ongoing communication with Division C's Facility Managers' Council, which has accepted responsibility for focusing on the division's process safety management systems. Company X's PSM champion, (name), will lead the Task Force, whose initial emphasis will be on Divisions A and B. Task Force members are: (name) (name) (name) (name) (name) (name) (name)

Division A facility management Division B safety engineering Corporate process safety specialist Division B risk assessment Division A research and development Corporate EHS auditing Corporate process design

This core group will be regularly supplemented by other specialists, tapped as needed for their particular expertise. The Task Force will accomplish its mission through the following activities: Defining PSM criteria and goals for the company; evaluating current PSM status; developing a detailed plan that builds on our strengths and addresses gaps; developing specific PSM systems; selecting a pilot site and fielding a test of these systems; measuring and monitoring effectiveness and progress; and refining the systems as needed. On completion of this process, Company X expects to be well on its way toward achieving its goal of industry leadership in process safety management. FIGURE 3-6. Sample PSM Team Mission Statement: Outline and Final Version (continued)

Q What are team members' roles? When you approach colleagues to participate in a task group, the first question you'll hear is, "what do you need me to do?" People understandably want to know what they're getting into, and what is expected of them, before making a commit-

ment. While it's probably premature to provide a precise job description, you should be prepared to offer a realistic sense of how you see each team member's role. The matrix displayed as Figure 3-7 offers a framework for matching skills with some sample tasks, which helps to define how you may productively utilize team members' expertise. This in turn helps to project in general terms individuals' roles within the team. Figure 3-8 applies the same technique to allocating skills to project phases. Q What is this team's work product? Task team work products vary widely and reflect the team's mission and composition as well as a company's needs. You probably can't predict in great detail what the actual work product will look like at this point, but you should be considering in a broad sense what your team will be producing. Examples of a PSM team's work product might include: —written reports on current status —analysis of industry trends —detailed recommendations for management approval —policy statements —procedures manuals —flow charts —oral reports and recommendations The form these end products take should be consistent with your company's style; for example, if you have specific protocols for project planning or developing Standard Operating Procedures, these will probably apply to comparable tasks within the PSM initiative.

3.3.3 Soliciting Team Members'Participation Having set some preliminary groundrules for your PSM team, you are ready to start soliciting members. Ideally, your involvement with the initiative will have been announced ("Communicating the Importance of PSM," Section 2.3.2), so you won't be going in cold; people inside your company will know something about what you are doing and know that you have management's support. Whether you ask for participation formally (e.g., in memo form with copies to your sponsor and/or the recipient's boss) or informally, for example by phone or in the hallway, you should be prepared to explain concisely: • What the team is and what its responsibilities are (e.g., "I've been asked to put together a team to design and install our PSM system; we'll be reporting to the GM-EHS");

Process safety Risk assessment Design engineering Maintenance engineering Operations Operations management Communications Budgeting Project planning Other FIGURE 3-7. Sample Matrix: Skills Applied to Tasks

Other

Evaluation

Project Monitoring

Systems Design

Benchmarking

PSM Communications

Research

What Skills Do We Need?

Team Management

How Will We Apply Them? What Kinds of Tasks Are Required?

Process safety Risk assessment Design engineering Maintenance engineering Operations Operations management Communications Budgeting Project planning Other FIGURE 3-8. Sample Matrix: Staff Allocation by Project Phase

Measure/ Monitor

Install Systems

Develop Systems

Develop Plan

Evaluate Status

What Skills Do We Need?

Define Goals

When Will We Need Them?

• What the team's proposed composition is (e.g., "It'll be a group of us from Safety, along with some people from Engineering, and the manager of our ammonia plant"); • What you expect from the individual (e.g., "I need your help because of your background in process safety, and Td like you to work with us on assessing our current status"); • What kind of time commitment is involved (e.g., "We expect the whole thing will take about 18 months, and Tm hoping to meet once a month for a day. Your overall involvement will probably require 25% of your time. In addition, I'll be asking you specifically for extra help on the front end to help define our overall PSM goals"); • When and where the first meeting will take place. Hint: Even in cases where frequent in-person meetings won't be feasible (due to cost and/or multiple locations) a kickoff meeting at the outset is a good opportunity to bring the full team together and generate enthusiasm for the assignment. This is especially true for teams whose members are scattered throughout the company and have limited opportunity for regular interaction. Hint: Remember that enthusiasm is contagious. In soliciting membership for your team you are "selling" people on the PSM initiative as a professional opportunity. You're much more likely to get cooperation if people see it this way than if they view your efforts as "just another committee."

3.3.4 Scheduling and Organizing the First Meeting No one likes meetings that lack substance, that run too long, that seem disorganized. You and your colleagues have certainly experienced these kinds of sessions, and it's useful to remember the worst of them in planning for your initial meeting. Some points to consider in scheduling and organizing your first PSM team meeting (and subsequent ones) include: • Make sure to poll the team for its preferences as to frequency and location of group meetings. • Be sensitive to other people's schedules, especially those who will be traveling. • Try for reasonably congenial meeting conditions. • Consider rotating in-person meetings among locations. • Develop an agenda and circulate it in advance. (An example of a PSM team's first meeting agenda is provided as Figure 3-9.)

In advance of a PSM task team's first meeting, an agenda such as this might be prepared and circulated to participants. (See Section 6.4 for further discussion.) This agenda would require a lull-day meeting. Also, it presumes a meeting of teammates from multiple locations who may not be well-acquainted with the team leader or each other. 1. Welcome and introduction. (10 minutes) Self-introduction "Housekeeping" notes: location of telephones, emergency exits, other facilities. Summary of meeting agenda: what we want to accomplish today. 2. Introduction of members. (20 minutes) (ask each to introduce self, briefly describing background and current company responsibilities.) 3. Discussion of team mission. (15 minutes) (use preliminary notes as guide.) 4. Revise, expand as needed. (30 minutes) 5. Discuss recommended PSM criteria. (10 minutes) describe process of arriving at CCPS model discuss advantages of this model vs. others 6. Begin to define goals for the team. (15 minutes) describe process and desired results (break) 7. Discuss approach to management systems (90 minutes) brainstorm representative management systems review against "traits" define priority characteristics 8. Discuss approach to supervision/delegation (45 minutes) review management systems against "traits" 9. Discuss approach to documentation (45 minutes) review management systems against "traits" 10. Discuss approach to communication (45 minutes) review management systems against "traits" (break) 11. Discuss and summarize findings (45 minutes) assign two team members to develop written summary 12. Discuss how to mesh findings with PSM criteria (20 minutes) assign three team members to draft "straw man" recommendations FIGURE 3-9. Sample Agenda for First PSM Team Meeting

13. Discuss team working procedure and preferences (20 minutes) methods of information exchange reporting meeting schedules 14. Summarize next steps (IO minutes) team assignments upcoming meetings other 15. Thanks and conclusion FIGURE 3-9. Sample Agenda for First PSM Team Meeting (continued)

• Circulate relevant materials in advance. • Consider taking minutes. Documentation of team discussions and decisions can be very useful, both in keeping the team up to date and in providing the foundations for periodic progress reports. • Allow enough time. An initial PSM meeting will probably require more time than subsequent meetings, and you should be sure to allow sufficient time for discussion.

3.3.5 Conducting Team Meetings The way you conduct team meetings will naturally reflect both your own style and your company's broader culture. There is no single "right" way to lead a team. However, there are some common principles for effective leadership, including: • Establish clear expectations. Be sure you have a clear idea of what you hope to accomplish at each meeting. For example "next month's meeting will focus on evaluating our current status against CCPS7 Elements 4 and 5, Process Risk Management and Management of Change; in addition, we'll review comments from our facility managers, revise our recommendations for PSM Element 3, and incorporate them into our draft plan." • Establish clear assignments. Make sure to provide team members with enough detail to allow them to successfully complete any assignments you give them. For example, "Find out what the industry is doing about PSM" is subject to many interpretations, most of which will probably not be what you want. A more satisfactory assignment might be: "I'd like to ask you to put together an industry PSM summary for the next meeting. You may want to include information from CMA and CCPS, along with your own ideas."

• Facilitate interchange of ideas. The most effective team leaders are often facilitators, not dictators. An interdisciplinary team's greatest strength lies in its multiple perspectives and fresh ideas. Try to incorporate your own ideas into the group's discussion rather than imposing them. Keep in mind that healthy disagreement can enhance both the process and its end result. • Encourage participation. Some people are more comfortable than others in group settings and it's up to the team leader to bring out everybody's thinking. One way to do this is to structure assignments in such a way as to encourage participation by all members; for example, you might give a more reticent team member an assignment that requires him or her to poll the full team on a particular issue, such as safety training. • Establish and stick to deadlines. This applies equally to your own commitments and those you expect of team members. The team leader must take responsibility for seeing that deadlines are met and commitments honored; team members who don't contribute drain the group's momentum. HintCirculating "reminders" with meeting agendas can help teammates meet their deadlines. In addition, request team members to notify you in advance if it appears that a deadline might slip.

Troubleshooter: Dealing with a poor contributor requires a combination of firmness and tact. If a team member consistently misses deadlines or produces shabby work, talk to him or her privately to try to find out the reason. Ask for suggestions as to how you or others might help. At the same time, make it clear that the team expects a certain level of performance and be prepared to replace a team member who cannot or will not achieve it.

3A DEFINE COMPANY-SPECIFIC ATTRIBUTES The task group's first activity will be to define company-specific attributes that must be taken into account in defining appropriate PSM goals. A good way to begin this is through structured brainstorming and discussion against four key components (which are further detailed in Sections 3.4.1-3.4.4): management systems, supervision/delegation, documentation, and communication.

The goal of these discussions is to focus on "how we do things here;" the next step will be to apply these findings to the PSM framework you have selected. The result will be clearly defined goals for your company's PSM initiative. Brainstorming helps draw out participants7 ideas in raw form. To make the most of this technique, you must set some groundrules, the most important of which is that brainstorming is non-judgmental. Team members must be encouraged to voice ideas without fear of criticism from the leader or their teammates. Questions posed in brainstorming should be open-ended (as opposed to yes-or-no) and relevant to the task at hand. Be sure to record responses accurately, and in enough detail that you can recall their substance for further discussion. Some examples of useful brainstorming questions are: "In what areas of PSM do we excel?" "What areas of PSM need the most improvement at our company?" "What are the barriers to improvement?" "What should our company's goals be?" "How much PSM structure is enough for our company?" "What are some ways to organize a PSM system in our company?" "What makes our company unique in its approach to PSM?"

Hint: Leading a brainstorming session takes practice. Try for a fast pace and be sensitive to participants; move on to another question as soon as you sense that ideas are becoming forced. Hint: Brainstorming often throws off valuable ideas or information that may be off the immediate topic (e.g., Ve really should review and update our MSDSs"). These should be encouraged and recorded for future use. Note: Brainstorming is only one of many useful techniques for generating ideas and productive discussion. Interested readers should consult the reference list in this volume's appendix. 3.4.1 Characterize Company Management System Approach Review CCPS'Management System Characteristics In its 1989 book, Guidelines for Technical Management of Chemical Process Safety, CCPS identifies 22 characteristics of a management system, organized to reflect four key activities: planning, organizing, implementing, and control-

ling. Reviewing these elements will help you establish a framework for understanding and evaluating your own company's way of doing things. Remember that the CCPS definitions may not fit all companies or situations; however, they provide a useful set of guidelines for considering how a management system like PSM can work within your company. Some companies have adopted these guidelines very literally and use a highly documented, checklist approach. Others follow them conceptually, in a less structured manner. For example, CCPS notes "identification of needed tools and training" as a management system component that supports planning. One company might use a very formal approach to this process, with established procedures for each activity; at each stage of defining, recommending, approving, and procuring these resources, a predefined group or individual may have specific duties, with a specific reporting hierarchy. Another company may accomplish the same goal less formally. An ad hoc committee (at the corporate or facility level) might brainstorm on resource needs, discuss priority items with an empowered manager, and gain verbal approval. The difference is one of style, as opposed to substance; in both cases the task of identifying tools and training has been addressed. Similarly, "internal coordination and communication," an organizing component, takes very different forms in different companies. Depending on such factors as location, organizational structure, and individual preference, internal communication may be best accomplished by in-person meetings, committee or task group assignments, conference calls, memoranda, or some combination. Whaf s important is that the company recognizes the importance of this component as part of a management system and incorporates it in the way thaf s most effective. Identify Some Existing Management Systems within Your Company Having reviewed the components of a management system, if s useful to identify some existing systems as a means of isolating key company attributes. The goal here is not to try to itemize each and every management system currently in place within your company, but rather to identify some representative systems to provide tangible focus. Examples may include: • A facility's system for investigating near-misses • A division's system for compliance with ISO 9000 and /or Good Manufacturing Practice requirements • A division's system for managing customer relations • A product line's system for maintaining current MSDSs • A corporate EHS department's system for assuring regulatory compliance • A company's system for internal communications • A business unit's system for establishing a product stewardship program

• • • • • • • • • •

A treasurer's office's system for monitoring shareholder composition A division's system for hiring and assimilating new employees A facility's system for providing safety training A product line's system for marketing to new customers A research and development group's system for designing a new product or process A finance department's system for managing cash flow A central engineering department's system for evaluating a facility expansion A government relations office's system for identifying emerging regulatory or legislative trends An industrial hygiene department's system for assuring timely compliance with new regulatory requirements A facility's system for managing traffic and distribution

These examples are intentionally very broad-based to help expand your thinking about your company's management systems. While they address some very different issues, they all share the 22 characteristics of a management system as defined by CCPS, whether implicitly or explicitly.

Hint: Try using brainstorming techniques to identify representative management systems currently in place within your company.

Identify some common traits Given the breadth of activities that management systems address, there will almost certainly be variations in how they are applied. For example, the system your company's human resources department uses to recruit and hire new employees will probably differ in form and structure from Central Engineering's system for safety design. However, by analyzing some representative management systems you can arrive at some broad common traits. If you have used brainstorming to identify some existing management systems, the resulting list may be lengthy. One way to consider these systems is to subject them to further definition, drawing distinctions such as the following: Implicit versus explicit. A useful way to begin your analysis is to break the list into "implicit"—those systems that are informal or undocumented—and "explicit"—those that are documented in detail, as policies and /or procedures. Mandatory versus discretionary. Second, identify those management systems that support mandatory processes or activities (e.g., safety training, MSDS

maintenance), versus those that govern discretionary company actions (for example, hiring, customer relations, R&D). Self-contained versus companywide. Third, pick out those management systems that are self-contained within a given business unit or department, versus those that apply throughout the company. For example, does each facility have its own system for safety training, or do all operations follow a corporate system? Results versus procedural orientation. Last, consider each system in terms of its content: is its thrust instructional or is it couched in terms of desired results, leaving specific procedures to the discretion of the end user? The results of this exercise yield useful information about your company's approach to management systems, that you will need to keep in mind as you define PSM goals. For example: • Systems governing legally required processes are, of course, more likely to be formal and documented. If you find a one-to-one correspondence, this may suggest that your company tends toward an informal approach to management systems, documenting them only as they apply to mandatory processes. If you find formal documentation of a number of systems that support discretionary activities, this may indicate that your company's style requires more structure. • If you find numerous self-contained systems, this may imply (a) that your company's methods are more likely to be driven from the bottom up than from the top down, and (b) that there maybe some redundancy, overlap, or conflict among multiple systems devoted to the same issue. • A highly procedural orientation in a company's management systems indicates a preference for a "cookbook" approach that emphasizes "how to." Results-oriented systems generally focus on meeting a specified set of goals (usually within a specified set of parameters), with greater emphasis on "what must be achieved." This approach may suggest a company style that encourages more individual latitude in managing a given process. Hint: Rendering these broad distinctions among your company's management systems can be accomplished efficiently in a group setting by working quickly against the list the team has brainstormed, asking each person's opinion about whether each item is "implicit or explicit," "mandatory or discretionary, * etc. Note that opinions may vary depending on viewpoint and level of exposure to a given system.

Troubleshooter: Remember that the point of this exercise is to identify broad characteristics of representative systems. Avoid getting bogged down in detailed discussions or analyses of specific management systems, since the relevant systems identified will be considered in detail as part of evaluating your company's current PSM status. Hint: Remember also to take advantage of the team's individual, anecdotal experience with your company's management systems. Defining your company's management systems approach will be greatly enhanced by drawing on expert judgment as well as quantitative methods.

Having identified some broad characteristics of your company's approach to management systems will enable you to apply this discipline to some specific activities that are vital to a successful PSM effort: —Supervision / delegation; —Documentation; and —Communications. 3.4.2 Define Supervision/Delegation Approach A review of representative management systems helps to shed light on your company's approach to supervision and delegation, which must be taken into account in defining PSM goals. For example, some companies establish broad corporate guidelines and then routinely delegate significant day-to-day responsibility for operations to facility managers. In others, corporate management maintains operating responsibility, and facility managers focus on implementing company directives. On a smaller scale, a facility manager may rely on participatory management techniques, such as quality circles or task teams, or may pursue a more traditionally hierarchical approach. Similarly, a division may display entirely different management styles in several different functional areas; the sales organization may be highly structured, while research and development is more collegial and informal. In all of these cases, the extent and nature of supervision can vary greatly. Like management systems themselves, supervision can be results-oriented or procedurally focused, depending on the preferences of the company and the individual. One boss may tell her staff, "Fix that problem we're having with the product specs in the ag-chem division," and expect to hear no more about it until the problem is resolved. Another supervisor with the same problem may expect a detailed situation analysis, formal recommendations, and con-

stant progress reports, so that he is fully involved and making decisions at every step of the way. Neither approach (nor any of the many gradations in between these two extremes) is right or wrong; both can work and both can fail. More important than the specific supervision level or style is its adequacy for the task at hand. As a group, consider each of the management systems you have identified in terms of what it suggests about your company's approach to supervision and delegation. You will almost certainly discover variations, but some common findings will emerge. One way to organize this assessment is to run through the list, asking: • How many formal checkpoints does this system require? For example, a system for maintaining MSDSs may require multiple reviews of each new entry, or be consolidated as a single person's responsibility. Results may be forwarded to a centralized checkpoint, or may remain at the facility or division level. • How many layers of our organization are involved in this system? The final authority of a given management system maybe a facility manager, a division president, a corporate safety expert, the chief executive, or a plant superintendent. All of them maybe involved at some stage of the process. • What kind of reporting does this system require? Some management systems call for multiple reporting (direct and dotted line); some require interim reporting at predetermined intervals; some incorporate very little formal reporting. Others leave the question of reporting nebulous, relying on individual preference. By answering these questions about existing representative management systems, you can derive a reasonable sense of the level and type of supervision that will be workable for your company's PSM system. Hint: In determining the right supervision/delegation approach for your company, remember a key trade-off between investment and control. As a general rule delegation improves employees'sense of empowerment and thus their level of investment in a given initiative, which can greatly enhance the effectiveness of a PSM system. At the same timef delegation almost always means less control, and the system must compensate for shortfalls. Hint: As a very general rule, try for the least amount of supervision that will do the job, i.e., provide adequate control of the PSM system and sufficient assurance that it is achieving its goals.

3.4.3 Define Documentation Approach Similarly, the way your company documents representative systems can help guide your efforts on behalf of the PSM initiative. "Documentation" in this usage refers both to the documentation of an individual's or a team's work process and to the ways in which the process' results will be documented for dissemination within the company. Documentation of Group Process The way in which a PSM team documents its activities is best determined in collaboration between the PSM champion and his/her sponsors, as part of establishing groundrules for the effort. In making this decision, keep in mind the kinds of documentation that will prove useful over time, remembering that the PSM initiative will involve a number of different people and tasks over a period of months, not days. Because of this, if s sensible to consider regular documentation as opposed to relying solely on oral reports or informal hallway updates. Even if your sponsors don't require much formal reporting, internal documentation of the group process can help keep the process itself on track and can also provide the foundation for documentation of the end results. Some useful forms of documentation to consider include: For each meeting: • agendas (circulated in advance) • minutes (circulated promptly after each meeting) • summary of next steps (assignments to be completed) For each stage of the process: • Summaries of results, for example, -PSM criteria identified -JPSM goals defined —Assessment of current PSM status —Implementation strategy selected —Resource needs identified —Design approach selected In addition, the PSM team can expect to develop some specific documents as "deliverables," including: • Written plan (see Chapter 5) • Written PSM systems (see Chapter 6) • Plan for pilot installation (see Chapter 7) • Assessment of pilot test effectiveness (see Chapter 7) These documents should provide the basis for materials that will be more broadly disseminated within the company once its PSM system is in final form, as discussed below.

Process Results Documentation The specific PSM systems that are finalized for installation will act as the core of your company's overall system for process safety management. For this reason, it's wise to approach their development in a manner that's consistent with your company's practices, to minimize the need for reconstructing detailed text to conform to company standards. In reviewing the representative management systems you have identified, consider the ones that most closely approximate, in complexity and/or in scope, your vision of PSM. This may give you and your team a good start in terms of how PSM systems might best be documented within your company. Many companies have specific protocols for the development and description of standard operating procedures. Like the management systems they detail, these SOPs vary considerably in terms of their organization and level of detail. While it's clearly premature to develop a specific format within which PSM systems will be described, you can get useful ideas in advance by reviewing written protocols and existing SOPs. 3.4.4 Define Communication Approach Communication is a critical component of any major company initiative, especially one as complex and far-reaching as process safety management. As used here, "communication" applies to both internal information transfer (within a team and between the team and its sponsors) and companywide dissemination of information (outside the team to the broader employee base).

Internal Information Transfer A PSM team needs to exchange two kinds of information: specific information about task group assignments and group progress, and more general information about PSM and related topics. General information may come from many sources (conferences, sales calls, industry briefings, media reports, etc.) and helps to enhance the group's overall knowledge base. As PSM champion you have considerable influence in determining how the PSM team can most effectively exchange information. At the same time, it's almost always true that people function best with familiar methods and techniques. For example, people who are unaccustomed to electronic mail or teleconferencing are unlikely (at least in the short term) to use these vehicles effectively. Similarly, colleagues who ordinarily exchange information informally may bridle at written call reports or daily memos. For this reason, it's important to understand how your company approaches information transfer, recognizing that, as in other areas, variations are to be expected. In addition, in working with your team, if s a good idea to be sensitive to individual preferences— while you may never fully satisfy everyone, it's helpful to make the effort.

Hint: Generally speaking, the more information the better, especially when dealing with an interdisciplinary team whose members bring different levels and aspects of knowledge to the process.

For teams that are highly centralized (i.e., a majority of members in a single location), information transfer is a relatively simple matter. Some common means of transferring information among a centralized group include: • informal, "drop-in" meetings between two or more team members. • frequent, brief meetings held several times a week, solely to exchange information, in addition to regularly scheduled working sessions. Meetings like this can be effective even if they are very informal; some company teams or committees have standing meetings at a regularly scheduled time, attended by whichever members (or interested staffers) are available that day. • routine circulation of articles, conference reports, news reports, and other relevant topical information. Some teams have a standard procedure whereby everyone receiving such information routes it to the full membership; this sometimes creates some redundancy, but helps assure blanket coverage. For a more widely dispersed team, whose members may work in remote locations, information transfer may require more effort; however, most of the same techniques apply. For example: • Circulation of periodicals and other information can be centralized, with a single team member acting as the "mail drop," taking responsibility for copying and distributing PSM information of interest to the team. • A regularly scheduled conference call can substitute for an in-person "drop-in" meeting. • "Offline" discussions between members, by phone or in person, can be encouraged. Hint: Voice mail can be extremely helpful in facilitating information transfer, especially for informal exchanges among dispersed teams. On a larger scale, interactive computer programs such as Lotus' Notes enable teammates in multiple locations to work simultaneously on a single assignment.

Companywide Dissemination of Information In reviewing the representative management systems, pay attention to the way in which documented systems have been communicated to employees. You will probably find variations that reflect the topic and the specific

audience addressed; a companywide initiative in, for example, Responsible Care® probably includes a number of different communications, ranging from very broad, all-employee bulletins to specific procedures for implementation of new practices. Similarly, some divisions may routinely circulate details of their management systems to their counterparts simply for informational purposes, while others confine such information to those who are directly affected. Another variation you may encounter is one of style; some companies circulate management systems information in a very terse, concise manner, keeping strictly to the procedures required. Others present this information in a broader context, providing employees with an understanding of the " why" as well as the "what." Thus a useful way to understand your company's approach to communication is to review the identified management systems against these kinds of questions: • How many versions or variations of this information were developed and circulated? • How many different audiences were addressed? • Was the information provided to all hands, or to a single individual responsible for distributing and interpreting it to his or her staff? • How broadly circulated was this information? Need-to-know or F.Y.I.? • How much "positioning" was provided to put this information in context? Taken together, this review should provide you with useful insights into the way your company ordinarily approaches communication of information, which you should take into account in defining the company's PSM goals.

Conclusion At the conclusion of this set of tasks, the task group should review the PSM framework against its findings and adapt it accordingly to reflect the company's individual approach to management systems. The result should be a clear expression of your goals for the company's PSM initiative.

4

EVALUATE THE PRESENT STATUS

4.1 RECOGNIZETHEOBJECTIVE Having agreed on PSM goals and objectives, your next step is to conduct a more detailed assessment of the present status of PSM activities within your company, to form the basis for your implementation plan. This baseline assessment works against both the model you have selected for PSM and the characteristics that describe a sound management system, such as those described by CCPS. By conducting the assessment against these two sets of criteria you can accomplish two objectives: identifying the existence and current status of your company's PSM management systems, and evaluating them against good practice. Thus the baseline assessment has two goals: establishing the existence of PSM systems ("do we have these systems in place?") and judging the completeness of their design ("how sound are these systems in practice?"). Properly conducted, this assessment should yield valuable information about your company's strengths and weaknesses with regard to PSM, as well as a clear identification of the gaps you and your team should address in developing an implementation plan. Hint: Do it once = do it right The process outlined here requires a front-loaded level of effort to ensure that the solutions you determine will hold up over time. In many companies this deliberate approach to problem-solving runs counter to a more "action-oriented" culture, and there is a strong temptation to fix the problem and get on with it Keep in mind that the goal here is to develop a process, not to undertake multiple tasks, and consider the time spent in gathering this information as an investment in the longer term value of the resulting PSM system.

Given this objective, it's useful to keep several factors in mind as you consider the baseline PSM assessment: • You are not starting from a zero base. Virtually every company has at least some portions of a PSM system already in place, even though they may

not be recognized as such. Part of the assessment process is to identify these activities or programs and establish them as part of a broader PSM system. • Look for transfer ability. In establishing a PSM system for your company, you have the opportunity to build on what is already in place and to learn from the successes of others. These may range from specific procedures that make sense for governing other activities to entire management systems that can be effectively applied throughout the company. Hint: Remember that "homegrown" solutions are frequently better received (and thus more effectively applied) than totally new approaches that seem to be artificially created and imposed. The more transferable ideas you are able to identify and incorporate into your implementation plan, the greater the likelihood of its success.

• Brood variations in substance and quality are not uncommon. Within yourown company, some businesses, because of their individual needs, may have addressed a number of PSM issues ahead of other parts of the company. In the course of the baseline assessment, you may well identify programs that exceed the minimum requirements of your PSM goals and objectives, as well as those that fall short. In the course of identifying gaps, don't forget to highlight "pacesetters" as well. • Expect broad variations in style. Many companies (and individual facilities) have both formal and informal management systems. The degree of formality (e.g., documentation, authorization, follow-up) is often a function of the degree of risk associated with the activity the management system is designed to control, as well as of the structure or culture of the organization itself. Hint: Higher risk activities will require more formal management systems. For example, a process that uses a highly toxic raw material may require an extensive pre-startup leak check of the process as part of standard operating procedures.

Hint: A small organization where people have worked together for many years may require less documentation to achieve the same degree of control.

• Assessment results reflect the method selected. Any assessment you conduct will involve sampling of documentation and interviews with the people involved in program development and implementation. The scope and depth of your fact-finding and verification efforts will determine how detailed an implementation plan can be developed. • The assessor's skills and outlook affect results. Personnel conducting baseline PSM assessments should have the skills and experience that promote a balance between objectivity and familiarity with the programs and processes under scrutiny. Hint: An assessment that lacks objectivity may yield questionable results, e.g., a higher (or lower) level of compliance with PSM program goals and objectives than is actually in place. An independent perspective helps eliminate potential biases that could interfere with an objective assessment. "Independence" refers to the perspective of individuals who have not been involved in the design of ongoing operation of these management systems. You should use people who will not take things for granted and who will take a fresh view of how things really are managed.

4.2 SELECT AN EVALUATION TOOL Using a single evaluation tool or methodology throughout the baseline assessment helps ensure consistency among evaluations conducted at different facilities and by different individuals. In addition, remember that you will need to consolidate all the information you gather during the assessment phase, and it's far easier to do so if you have used a common method. Figure 4-1 displays the components for a generic assessment framework. Within this framework, there arc several tools and methods that can be applied to baseline PSM assessments, which are discussed in this chapter. Regardless of the assessment method selected, it's useful to keep in mind the following general principles: • Clearly defined assessment criteria. Clearly defining the criteria against which existing PSM programs will be evaluated helps to minimize the margin for error and maximize objectivity. Ill-defined evaluation criteria require the person conducting the assessment to rely solely on individual skill and experience, which may or may not yield objective results. • Applicability to organizational structure. In choosing your assessment method you may want to revisit the PSM implementation approach selected, as discussed in Chapter 3. For example, in centralized organizations baseline assessment programs should consider corporate and

Laws, regulations, and industry guidelines

Corporate policies, guidelines, and standards

Characteristics of good management systems*

Guides** - protocol - topic outline - questionnaire

Understanding and assessment - management interviews - program review

Verification - interviews with supervision and wage roll - records review - observations/inspections

Evaluating findings and reporting - current status - exceptions - "pacesetters"

See Figure 4.2. See Figures 4.3, 4.4, 4.5, and 4.6.

FIGURE 4-1. Process Safety Management Assessment Framework Source: Arthur D. Little, Inc.

division policies and procedures applying to PSM. These policies and procedures may need to be assessed at the appropriate corporate organizational level and then verified at the facility or unit level. In decentralized companies, where corporate or divisional PSM roles may be very limited, greater emphasis would be placed on assessing the individual effectiveness of facility-level systems. • Maximum usefulness and focus on end use. Remember that the PSM assessment phase is a means to an end: the design and installation of a workable PSM system within your company. This means you may want to gather information that might otherwise not be included in comparable studies, audits, or reviews, e.g., data concerning resource allocations and requirements. If so, these considerations should be factored into both selection of your assessment method and the specific design of the tools you select. • "Buy-in" of facility management. Cooperation of facility-based staff and managers strongly influences the effectiveness of baseline PSM assessments. The assessment phase may be the first visible manifestation of your company's PSM initiative at the local level, and should be properly understood by those participating—especially those whose PSM activities and programs are under review. An assessment method with which local personnel are at least somewhat familiar, conducted by professionals whose skills they respect, will more likely gain buy-in and cooperation. • Relevance to the PSM model selected. Whichever assessment tool or method you decide to use, it should reflect the PSM model you have selected for your company's PSM program framework. This model of PSM program elements establishes characteristics for the goals you have selected for your PSM system, and provides a structure for the baseline assessment. For example, the CCPS PSM model comprises 12 elements, each of which should be assessed if you have selected this model. • Consideration of minimum management system characteristics. Where significant gaps in PSM programs are known to exist, your assessment may be heavily weighted toward evaluating compliance against the PSM model, simply because if programs do not exist, you cannot evaluate their management systems. However, where programs do exist, assessments should evaluate programs against both the PSM model and a definition of the necessary or minimum characteristics for each management system. The 22 CCPS characteristics of good management systems can be usefully condensed into seven basic characteristics as shown in Figure 4-2. This condensed version can then be applied as a benchmark for each PSM management system. Keep these general principles in mind as you consider the following discussion of PSM assessment tools; they can help you determine the best approach for your company.

In the absence of explicit criteria, the seven characteristics listed below may be useful in evaluating management systems. Keep in mind that these characteristics are not absolute requirements; facility management systems may vary significantly and still be capable of achieving the desired results. 1. Policies, Programs, and Procedures: Goals and objectives have been set. Formal corporate and facility work plans, policies, guidelines, standards, and procedures are available to clearly define PSM program scope, outputs, milestones, initiating mechanisms, and alternatives. Management demonstrates commitment and sponsorship for these programs. Policies, programs, and procedures are periodically reviewed and revised. 2. Definition of Responsibilities: Facility personnel understand their roles and responsibilities in achieving the desired level of PSM performance. Appropriate checks and balances have been established to minimize conflicts of interest. Internal coordination and communication mechanisms exist. 3. Approvals and Authorizations: Appropriate delegations have been established, and authorities are clearly established for approval of specific routine operations and non-routine or out-of-specificalion operations. Variance procedures are defined. Approval levels are commensurate with the importance of the task. Appropriate resources are authorized. 4. Personnel Training and Experience: Facility personnel have sufficient experience, training, and awareness to accomplish the PSM program or activity. Personnel are familiar with applicable regulatory requirements, internal standards and guidelines. Employees at all levels in the organization are involved in program development. 5. Protective Measures: Safeguards have been established to prevent or control major problems; administrative controls are in place to cross-check completion of critical operations. 6. Documentation: Results of PSM activities are documented as are compliance/performance results. 7. Internal Verification: Systems or procedures are in place for reviewing performance against standards and milestones and reporting departures from established (external or internal) standards. Exceptions and deficiencies are corrected in a timely manner. FIGURE 4-2. Condensed Listing of Management System Characteristics. Source: Arthur D. Little, Inc.

4.2.1 Audits Audits are primarily designed to verify that required PSM programs are in place and functioning; however, they can also serve to evaluate the present status of these programs. The primary difference is one of emphasis: compliance audits confirm the implementation of management systems ("are the systems working as they should?"), while baseline PSM program assessments focus on assessing their presence and design ("are the right systems in place?"). Hint: The CCPS book Guidelines for Auditing Process Safety Management Systems provides guidance on developing PSM audit programs and conducting PSM audits.

A program of baseline PSM audits to evaluate the current status of PSM programs at each facility is the best way of assessing where improvements are needed. Audits by definition are conducted on-site. An audit may be conducted using a variety of approaches and guides, but in general involves a team that gathers data through interviews, observation, and review of documentation. The team usually includes at least two people; depending on the complexity of the facility or processes under review, this may expand to as many as five or more. The level of team members' effectiveness depends on skills, experience, and the guidance they follow. A formal audit protocol provides the user with step-by-step instructions on how to conduct the audit, and thus can be used by less experienced auditors. Use of less formal assessment guides such as topical outlines requires more experienced auditors. Either way, the skill level of an audit team must be sufficient to enable members to: • understand the processes and procedures under study, and • command the respect of local management. Examples of an audit protocol and a topical outline are provided in Figures 4-3 and 4-4. Whichever audit tool is chosen, it should be used consistently for all audits. Hint: To improve objectivity, choose auditors with appropriate functional experience but who work at different locations within the corporation.

A. Introduction Background Information 1. Review background information obtained from the facility to develop a general understanding of process safety hazards, areas of process safety concern, chemicals and processes used, etc. Typical background information includes: a. List of major hazardous chemicals used at the facility and applicable MSDS sheets for those chemicals; b. Description of the facility including site plan, flow diagrams, and general arrangement diagrams; c. Types of operations conducted; d. Organizational charts; e. Environmental, Health, and Safety Policy and any other applicable corporate policies; f. Selected facility reports (i.e., insurance carrier reports, incident reports, etc.); g. Copies of prior PSM audits or any other safety audits conducted at the facility; h. List of process hazards analysis conducted, and i. Number of contractors typically on-site.

Auditor(s) Comments

Working Paper Reference

2. Obtain and review applicable company and facility plans, policies, procedures, and standards. 3. Obtain and review Pre-Audit Questionnaire completed by facility. Source: Arthur D. Little, Inc. FIGURE 4-3. Example Page from an Audit Protocol Format (page 1 of 17)

1. Process Safety Information 1.1 Written process safety information 1.1.1 Chemical hazard information 1.1.1.1 Toxicity information 1.1.1.2 Permissible exposure limits 1.1.1.3 Physical, reactivity, and corrosivity data 1.1.1.4 Thermal and chemical stability data 1.1.1.5 Hazardous effects of inadvertent mixing 1.1.2 Technology of the process 1.1.2.1 Block flow diagram or simplified process flow diagram 1.1.2.2 Process chemistry 1.1.2.3 Maximum intended inventory 1.1.2.4 Safe upper and lower limits for temperatures, pressures, flows, and/or compositions 1.1.2.5 Evaluation of the consequences of deviations, including those affecting safety and health 1.1.3 Equipment in the process 1.1.3.1 Materials of construction 1.1.3.2 Piping and instrument diagrams (P&IDs) 1.1.3.3 Electrical classification 1.1.3.4 Relief system design and design basis 1.1.3.5 Ventilation system design 1.1.3.6 Design codes and standards employed 1.1.3.7 Material and energy balances 1.1.3.8 Safety systems (e.g., interlocks, detection, and suppression systems) 1.1.4 Documentation that equipment complies with recognized and generally accepted good engineering practices 1.1.5 Determination and documentation that equipment is designed, maintained, inspected, tested and operating in a safe manner and that existing equipment was designed and constructed in accordance with codes or standards that were applicable at the time FIGURE 4-4. Example Page from a Process Safety Management Topical Outline (page 1 of 12). Source: Arthur D. Little, Inc.

Hint: If your company has an in-house audit function or standing team, try to enlist their support, either on a consulting basis or to conduct the PSM assessment under your team's direction. At the very least, make sure they know about the PSM assessment, to avoid potential misunderstandings.

Regardless of who conducts the audit, the team should gather data from all levels in the facility or organization, which suggests interviews with selected: • line management, to determine how PSM policies and procedures are developed • supervisors, to determine how PSM procedures are written and implemented • wage roll personnel, to determine how well PSM programs actually work Based on the audit findings, the team typically issues a report that summarizes the status of current management systems and identifies pacesetter programs and areas of non-compliance or exceptions. These findings should be provided both to the facility manager and to the PSM team, for consolidation into overall recommendations. A sample audit report is shown in Figure 4-5. 777/s sample uses CCPS PSM Element 5, Management of Change, to illustrate a useful audit report format. The full report would include similar treatment of the other 11 PSM Elements. Summary of Current Status A number of procedures are currently used to address changes in technology and facilities. The Research Department uses a Trial Request Procedure to manage experimental changes. Small maintenance modifications and capital improvements must go through a Facilities Change Procedure. New chemicals must be approved by a Chemical Safety Committee. Each procedure has been reviewed and updated as necessary during the last year. Personnel responsible for initiating change requests and implementing changes are aware of their responsibilities. All procedures require documentation of changes, the technical basis for the change, safety review requirements, updating of process safety information and operating procedures and required training. Findings Pacesetter programs: The Facilities Change Procedure (FCP) is an excellent program that requires cross-checking of all work orders by the maintenance planner to ensure any changes go through the FCP. This program should be distributed to other company locations for use as a model for their programs. Exceptions: • There is no procedure to address organizational changes. • The Chemical Safety Committee does not review chemicals used by contractors. • The Trial Request Procedure does not require that a duration for the effective time of the trial be specified (i.e., all trials are temporary changes). FIGURE 4-5. Baseline Audit Report for Management of Change

Start to finish, a baseline PSM audit of a typical chemical plant can be conducted in a matter of one to two weeks using a team of about four auditors. Hint: You may be able to achieve some economies by linking the PSM baseline assessment with other, scheduled review programs in your company, e.g., annual safety reviews, compliance audits, etc.

4.2.2 Surveys Surveys often involve questionnaires that are completed by facility staff. Surveys can be used in place of any on-site audits; however, this precludes your gaining first-hand knowledge of the PSM systems and leaves you unable to vouch for the accuracy of the information gathered. Despite their limitations, surveys can play a role in assessing PSM program status. Surveys can be used in advance of each site visit to gather information that you subsequently review with facility staff and verify during a visit. This may reduce the time needed on-site. Alternatively, a survey can be used as the principal method of information gathering, with a limited amount of "spot-checking" at selected facilities to give you confidence that the survey was understood by recipients and accurately completed. This method may be most useful in situations in which: • the number of affected company facilities makes individual site visits impracticable; and/or • major gaps in PSM programs are known to exist; and/or • resources are severely limited; and/or • comprehensive audit information is current and readily available, indicating that a PSM audit may be to some degree redundant. In considering whether or not this method is right for your company, keep in mind that the effectiveness of surveys depends on: • • • •

the quality and depth of the questionnaire; appropriate distribution of the questionnaire; the skills and insights of the interviewer^ the candor of respondents.

Questionnaires can be used by a facility to conduct a self-assessment or can be administered by an outside evaluator, by phone or in person. In any case the questionnaire typically focuses on identifying PSM activities and program content based on the requirements of the PSM model selected, and assessing condensed criteria for the effectiveness of management systems (as shown in Figure 4-2, page 78).

Policies, Programs and Procedures D Do corporate/division safety policies or guidelines apply? D Do facility standards or policies apply? D Do specific facility procedures apply? D Do any areas or functional procedures apply? D Does this element overlap with other PSM elements? Definition of Responsibilities D Are responsibilities and accountabilities defined, established, and communicated? D Are personnel who need to know or understand responsibility assignments made aware of them? D Are assignments of responsibilities reinforced? D Are any key responsibilities overlapping, shared, or conflicting? D Is there potential for conflict of interest in accomplishing key process safety management tasks and functions? Approvals and Authorization U Does someone have the authority to waive adherence to, or conformance with, an established standard or requirement? D Are authorizations to depart from internal procedures made and recorded? D Are there perfunctory approvals - authorizations without understanding what is involved? Personnel Training and Experience D Have key personnel had formal training to assist them in performing key process safety management functions? D Are there training and awareness activities to provide an understanding of process safety management obligations and responsibilities? Protective Measures D Are administrative controls in place to help achieve desired results? D Have measures been taken to reduce the likelihood of non-conformance with established criteria? Documentation D Are records routinely developed and retained in carrying out various tasks and functions? D Are exception reports developed? D Does the relative importance of a task correspond with the type and amount of documentation that is developed? D Are records kept centrally? For at least 5 years? Internal Verification D Does facility management or supervision review, measure, and evaluate results achieved against established criteria? FIGURE 4-6. Yes/No Questionnaire for PSM Program Evaluation

Two basic types of questionnaires can be used: yes/no or open-ended. A sample yes/no questionnaire is provided in Figure 4-6; Figure 4-7 displays an open-ended version. The yes/no questionnaire confirms the existence of specific PSM program components or management system characteristics, while an open-ended questionnaire requires an explanation of the response and can be used to invite discussion. Yes/no questionnaires can be filled out by the facility or can be administered by less experienced assessors. Openended questionnaires require more experienced assessors, who are equipped to guide discussion and probe for further information.

Hint: Another advantage of open-ended questionnaires is that they can be used to elicit opinions and anecdotal information that, in addition to strictly quantitative data, can be very useful in developing the PSM implementation plan.

1. What written operating procedures exist for each covered process? 2. How do the operating procedures provide clear instruction for safety conducting activities in each process? How are they kept up-to-date and accurate? What operating phases do they address? 3. How are safe operating limits addressed? What is included about corrective actions? 4. What safety and health considerations have been addressed and documented? 5. What is included regarding safety systems and their functions? 6. Where are operating procedures available? 7. When are operating procedures reviewed? 8. What safe work practices been developed and implemented for employees and contractors to control hazards during operations? 9. How are the quality of raw materials and the hazardous chemical inventory levels in vessels controlled? FIGURE 4-7. Open-Ended Questionnaire for Evaluating Operating Procedures Program

The survey method relies heavily on interviews to gather data and typically involves little or no on-site verification or observation. Results can be obtained in a timely and cost-effective manner; however, they may reflect the bias of the individual filling out a self-administered questionnaire. One way you can help minimize such bias is to involve more facility personnel in a PSM survey than would likely participate in a PSM audit. Broad distribution of a questionnaire among facility staff does not appreciably add to the level of effort required of the PSM team, and may help provide a more balanced perspective. For example, a facility manager may be confident that PSM policies and procedures arc in place, but line personnel may indicate in the same survey that they are unaware of them—suggesting a gap that your implementation plan should address. Hint: If a survey is administered throughout a facility, it is critical that it be understood and believed to be confidential; staff should be encouraged to forward their responses directly to the PSM team and signatures should be optional.

As with audits, survey results form the basis of a facility-specific report for circulation to facility management and the PSM team. This report may follow the questionnaire format, with responses tabulated and analysis and commentary provided at the end. If necessary, baseline PSM assessments can be performed by a single individual using a survey method. Hint: In designing a survey form, consult with people in your company's data processing department, who can help build in tabulation requirements on the front end. Make sure they understand that responses may be qualitative as well as quantitative and ask for advice on structuring the questionnaire to facilitate consolidating results.

4.3 PERFORMTHEEVALUATION Once you have selected the right assessment method for your company, you must now consider: • • • •

Who will conduct the assessment? What skills are needed? How will information be reported? How should information be consolidated?

Staffing As suggested in previous sections of this chapter, the individuals charged with actually performing the assessment need a range of skills that you will need to take into account in organizing this task. In addition to having relevant operating, technical, or managerial experience (which helps assure judgment and promotes local buy-in), staff conducting audits or surveys may require special training in audit skills and techniques. The most fundamental skill required is interviewing, an area in which many technically proficient managers may lack experience. Other important skills and techniques include: writing findings, sampling, and taking notes during the audit. Hint: If you do not have an in-house audit function, it may be wise to consider investing in a professional EHS auditing course for one or more staff members who can then share their knowledge with others.

Hint: The key to effective interviewing is to spend more time listening than talking. Approach each interview with an open mind, with as few preconceived ideas as possible about the facility, process, or individual you're reviewing. Remember that your goal in interviewing is not to fill out a form but to elicit essential information that will help guide your PSM system development.

Ideally, the staffers you recruit to conduct a PSM assessment should be a dedicated team; that is, the same team assesses each facility or organization, using the same method and format. This may not be practical in many companies, in which qualified staff are often overcommitted; a workable alternative is a " revolving door" approach, under which assessment team composition varies according to designated individuals' availability. This suggests that in organizing the assessment task, you may want to identify as broad a group of qualified individuals as possible, and be prepared to provide them with detailed guidance. This may help you accommodate last-minute scheduling problems while assuring consistent quality.

Reporting and Consolidating Information Regardless of which assessment method you choose, assessors and auditors should take detailed notes using a common format to help capture maximum information in a consistent manner. Forms for questionnaires, topical outlines, and audit protocols (as shown in the exhibits) can perform double duty by providing interviewers with a format for notes as well as reporting.

Hint: In addition to recording quantitative information, assessors can use these forms to record observations and opinions for future use. It's important, however, to make sure that the interviewer's opinion can be clearly distinguished from an interviewee's response; use brackets, asterisks, or other symbols to set opinions apart.

Hint: Encourage auditors and assessors to review and organize their notes as soon as possible after completing an interview or site visit It's easy to lose track of insights and observations if too much time elapses, particularly when an assessment involves multiple sites.

Reporting Results Audits and surveys yield two reports: one to the facility reviewed and one to the PSM team. While this dual reporting maybe more time-consuming than simply collating information for future reference, it is likely to be time well spent. Providing audit or survey results (appropriately condensed to protect confidentiality) to facility managers not only provides valuable feedback, but also helps to underscore their involvement in the PSM initiative. The two reports may be very similar; it may be wise to confine reports to facilities to strictly factual findings, leaving interviewers' opinions and ideas for review by the PSM team to determine their value and potential application to the implementation plan. To consolidate multiple reports efficiently, you may want to develop an enlarged chart based on the assessment report form (questionnaire, protocol, other), which can be filled in as assessments are completed. This may help to illustrate common strengths and weaknesses, as well as highlighting pacesetter programs and gaps. Where particularly effective PSM programs are found at individual facilities or units within facilities, these should be flagged for possible use as a model for other facilities to develop or improve their existing programs. It is important to keep in mind that any evaluation will reflect a snapshot in time, showing whether systems are in place and have been or are functioning. It is only by including appropriate characteristics of good management systems in the assessment that there can be assurance that these programs will continue to function effectively in the future.

4.4 IDENTIFY GAPS AND OVERLAPS Once you have gathered the information you need, your next challenge is to organize it so that you and the team can readily identify gaps and overlaps. Several tools can help you. Management grids, also known as roles and responsibilities charting, provide a useful structure for organizing diverse material against fixed coordinates, and providing literally an "at-a-glance" perspective on PSM gaps. These grids are similar to the skills matrices displayed in Chapter 2 (see Figure 2-4), in that they match up attributes with processes or tasks. Depending on your company s needs, the management grid's axes may reflect any of several components; you may also find it helpful to develop a series of grids, representing increasing levels of detail. For example, the management grid shown as Figure 4-8 matches PSM elements with job titles and identifies the role each performs. A useful way to consider these roles is displayed below: AP

Approver—Allocates resources, signs off, can veto. Delegates responsibilities to:

PM

Prime Mover—Has more responsibility than any other staff function to ensure that an Element is implemented.

CO

Contributor—Significantly contributes to carrying out the Element.

CR

Concurrer—Provides review and concurrence in area of expertise.

EX

Expert—Provides expert information or assistance.

You will note that in this example, more than one job description applies to several of the elements, indicating potential overlap; at the same time, some other elements display no clearly definable responsibility, suggesting a possible gaPAnother useful tool in understanding the overall status of PSM systems is to rate the management system for each element at each facility using a qualitative rating scale. One approach is to rate PSM system maturity, using the definitions found in Figure 4-9. The facility ratings can then be combined (see Figure 4-10) to indicate overall PSM strengths and weaknesses. The Figure 4-8 example suggests some areas where transfer of a management system among plants might be effective (e.g., process knowledge and documentation) and other areas (e.g., training) where no existing systems are strong.

AP/PM

Facility manager

._ . . Engineering

-Local _ HQ

,_, ,~ ,. EHS director

- Local . — urMU -Local — uri MU - Local _ HQ

. , A . ,, . Industrial hygiene R&D

,x Process safety Gaps

Enhancement of PS Knowledge

Audits and Corrective Actions

Standards, Codes and Laws

Incident Investigation

Training and Performance

AP PM

CO

CO

Operators

.. . x Maintenance

|

AP AP

Shift supervisor

Human Factors

AP

Process and Equipment Integrity

AP

Management of Change

Process Risk Management

Job Title

Project Review and Design Procedures

Accountability

Approver Prime mover Contributor Expert

Process Knowledge and Documentation

PSM Elements AP = PM = CO = EX =

-Local — un MU

PM

PM AP "

CO

EX

PM

CO PM CO

CO

CO CO CO

CO

CO

AP

AP

CO PM

EX PM, CO

CO AP, PM, AP, CO CO

FIGURE 4-8. Sample Management Grid: PSM Elements/Primary Responsibility and Location

EX

AP, PM, AP, PM, AP, PM, CO CO CO

In collecting data for assessing the strengths and weaknesses of PSM systems, the auditor can also make an initial judgment about the maturity of the program. The levels of system or program maturity can be broken down into three stages. Stage 1 programs • Staff reacts in a fire-fighting mode to the most immediate and pressing need. • Program effectiveness depends on one or two key people. If the key people leave, a significant part of the program and institutional knowledge goes with them. • The facility is more or less in compliance with those regulations that are known to them, but there is little assurance that all applicable requirements have been identified, let alone addressed. • Documentation of compliance is weak. • Written program documentation is spotty and incomplete, and there is little coordination or correlation between program areas. Stage 2 Programs • The facility has set some PSM goals. • Established programs exist. • The program capabilities are integrated into the organization to a greater degree than in Stage 1. If a key person leaves, the program is likely to recover after a short time. • The facility can demonstrate compliance with most applicable regulatory requirements, and has identified those areas where compliance is not yet achieved. • The facility periodically reviews its compliance status to assure that the programs which have been implemented are operating as designed. Stage 3 Programs • The facility sets formal PSM goals and objectives and tracks their progress. • Staff has moved beyond managing for compliance and is now actively managing risk. • Program capabilities are fully integrated into the organization. If a key person leaves, organizational recovery is a function of being understaffed, not underskilled. • The facility can demonstrate and document compliance with all applicable regulatory requirements. • Written programs are complete and satisfy the regulatory requirements. • The facility has a regular self-inspection program utilizing experts from outside the facility or company, in addition to internal personnel. • New regulatory requirements are anticipated and tracked by the organization, and compliance is achieved according to a regulatory schedule. FIGURE 4-9. Maturity of PSM Systems and Programs. Source: Arthur D. Little, Inc.

PSM Element

Embryonic (Stage 1) Systems

Management of change

Training

E

Process knowledge and documentation Project review

Human factors

Developing (Stage 2) Systems

Mature (Stage 3) Systems

J E

R

J R E R

J

J

E R

E J R

FIGURE 4-10. Example of PSM Status Summary. (Three facilities: E = Effingham, J = Jackson, R = Rextown.) Troubleshooter: Any rating system can be useful in developing priorities and measuring improvement However, keep in mind that despite management's reassurance that "numbers aren't important" facility managers may be tempted to use the rating system to their advantage. One pitfall is that some managers may try to influence the assessment team to give higher ratings than conditions warrant. Other managers (generally those who are new in their positions and therefore do not feel ownership of current conditions) may try to obtain low ratings so they can show considerable improvement with time.

Regardless of the method selected, this exercise should provide you and your team with a clear idea of where your company excels and where it needs work, in terms of current PSM status. These results can be summarized in a concise progress report (see Figure 4-11 for an example). Hint: Informal management systems generally work because someone is the champion behind the program. When this individual leaves there is no assurance that the program will continue. Thus, even in informal organizations documentation may be a necessary characteristic of a good management system.

Progress Report from Process Safety Management Task Force This report summarizes the PSM team's progress in developing Process Safety Management (PSM) systems. Since receiving management approval to proceed, an assessment has been conducted to ascertain the status of PSM in each division. These assessments have found the following: Status by Division PSM Element Process knowledge and documentation Accountability Capital project review Process risk management Management of change Process and equipment integrity Human factors Training and performance Incident investigation Standards, codes, and laws Audits and corrective actions Enhancement of process safety knowledge FIGURE 4-11. Example of an Interim Report from a PSM Task Team

PSM system in place, documented, and fully operational Informal system in place Incomplete system in place; upgrading needed No system in place System exists but is not followed

Whether you use an audit, a survey, or a combination of both, remember that your results provide a picture of your PSM activities as of a fixed point in time. This creates a useful point of departure for detailed planning, pointing the way toward implementation and establishing a benchmark for future measurement.

5

DEVELOP A PLAN 5.1 REVIEW THE PRELIMINARY PLAN The plan you develop for implementing PSM will outline your approach to addressing the needs you have identified within your company. While the appearance of the written plan itself can take any of a number of forms, the content should focus on: • • • • • • • •

Statement of goals What is in place What is needed to address gaps Tasks required Work products or "deliverables" Resources required Time required Expected results

At this point in the process, you may find it useful to review the preliminary plan you presented for initial management approval (see Chapter2). That "first take" necessarily lacked the detail you are now able to provide. For example, your initial estimates of time requirements might have predicted 18 months for system design and installation; now you realize that 24 months will be needed. While the initial plan will require changes, it should have components (organizational, stylistic, narrative) that can be adapted for use in the formal plan. More important, compare the broad themes and projections you presented then with the perspective you have gained. Pay particular attention to major shifts in key areas such as goals and resource requirements. If these have changed dramatically based on your findings, it may be wise to bring them to management's attention sooner rather than later, in case fundamental expectations need revision.

5.2 SELECT AN IMPLEMENTATION STRATEGY There is no single " right" strategy for implementing PSM. Depending on your company's needs and culture (which you have defined through your work to date) you may select a strategy that will implement PSM companywide, one that is facility-specific, or a "hybrid" implementation strategy that combines characteristics of both.

Choosing the best implementation strategy for your company depends on a number of factors, most of which you have already identified. As you consider the benefits of each implementation strategy described in this section, it's useful to keep in mind some specific factors, including: • the present status of PSM may vary dramatically, either within business segments or between individual facilities within the company. • the requirements for PSM may differ in each manufacturing location because of variations in equipment or local regulation. • different manufacturing processes may have different PSM requirements. • company management may be highly centralized or very localized. Regardless of the implementation strategy you select, try to build in at least some degree of local involvement in planning and implementation. Local involvement can give facility personnel "ownership" of the process, meaning that they will be more likely to work to overcome any problems or false starts. In addition, local participation means that you will be able to identify any local barriers to implementation—sooner rather than later. In all cases the preliminary work (obtaining commitment, defining goals, and evaluating the current status) provides most of the information you will need to select and develop an implementation plan. 5.2.1 Company wide Approach In the course of your work to date, you have identified your company's management style in different divisions, regions, and locations. If this style favors centralized management, a companywide PSM implementation strategy may be highly effective. A companywide approach has several key benefits, including: • ensuring consistent application of PSM throughout your company, and • minimizing resource requirements for program development and some activities through economies of scale. In addition, a companywide PSM system is likely to yield ongoing programs that can be supported by a relatively small, centralized group of experts. At the same time, companies whose PSM requirements vary widely among locations may not find a centralized, companywide approach practical, unless PSM status is uniformly poor. In any case, some central coordination will help identify common issues and facilitate the sharing of knowledge and experience among locations. Depending on the findings of your PSM assessment, you may wish to consider a companywide (or centralized) approach if: L the current status of PSM is relatively low. If this is the case, it probably means there is not sufficient knowledge and expertise for local implemen-

tation to be effective. A more practical approach involves a small centralized team and a plan that emphasizes training of local staff to upgrade necessary skills. 2. manufacturing processes are similar in each location. If your company's processes are essentially comparable throughout the organization, you may have a good opportunity to minimize PSM resource requirements. For example, a detailed program at one facility can easily be copied and installed at other facilities without significant modification. If this approach runs counter to corporate culture (e.g., each location is used to developing its own programs with independence), you will need to build in a degree of local implementation to assure local "buy-in." A centralized approach calls for establishing multiple teams under the direction of a single PSM manager or champion to assure coordination. The overall structure of a companywide task force and its organization will depend on your company's management style and the implementation strategy you adopt. Some companies routinely use independent project teams for any significant task while others establish teams within existing departments. The centralized team(s) will approach PSM element by element. The teams develop detailed guidelines, procedures, and standards for each PSM element, which can then be installed by facility management. However, in handling one PSM element at a time, teams must be careful to incorporate a consistent approach to those elements that are interrelated (e.g., training), and to the management system characteristics (e.g., documentation) that apply to the whole PSM system. In considering this method, keep in mind that these teams must include staff familiar with all the operations of the company to assure consistency. In addition, team members as a rule should have experience in operations, design, maintenance, and safety management. Hint: Consider the practicality of assembling and managing people with these kinds of qualifications in your company; this may help you determine whether a companywide approach is feasible. Single divisions may offer stronger possibilities, since they usually have more common manufacturing processes and equipment

5.2.2 Facility-Specific Approach A facility-specific implementation strategy relies on local expertise and calls for a number of local PSM teams to work in parallel. One benefit of this approach is that it can provide for very rapid implementation of PSM. In addition, facility-specific programs can be adapted to local requirements, such

as different management styles, equipment, or local regulation. The downside is that this may result in programs that are very different in each location and the possibilities of learning from one another are less. Facility-specific approaches to implementing PSM make sense if you have determined significant variations among locations in one or more of the following areas: • • • • • •

the current status of PSM; the potential process hazards; local regulatory requirements; manufacturing processes; process technology and equipment; or local management styles.

Hint: As previously noted, facility-specific approaches tend not to succeed where the overall current status of PSM is poor. Local staff will not have the necessary knowledge or experience of safety management to develop and implement a program without considerable outside assistance. Even if you have identified significant variations, if your team decides that overall PSM performance is low you should consider a companywide strategy rather than a facility-specific approach.

Facility-specific implementation requires formation of a local team at each of your company's facilities. As a general rule, these teams comprise resident staff and report to the facility manager. A typical local team would include the facility safety manager and representatives from operations and engineering. More often than not, teams such as these benefit from outside assistance, either from other company experts or from consultants or engineers who can supplement their expertise. In any case, these teams, either directly or through facility managers, should report to a company PSM manager or champion to monitor progress, assure consistency, and facilitate cross-fertilization of efforts through exchange of experience. Hint: Where individual facilities have strong programs in specific aspects of PSM, a facility-specific approach may involve identifying "best practice" programs and facilitating cross-communication among locations.

5.2.3 "Hybrid" Approach Neither the companywide nor the facility-specific implementation model offers a magic solution. In fact, many companies incorporate elements of both strategies into a "hybrid" approach that better meets their individual needs. A hybrid approach addresses some PSM elements centrally and others locally, reflecting current PSM status. In many real situations, this offers the best way to take advantage of what already exists. Where the status of different elements varies (e.g., some may be poor throughout the company, while others are either strong throughout the company or at particular locations), a hybrid may be the only effective means of addressing gaps systematically. Hybrid approaches are generally more difficult to manage as the relationships and division of responsibilities between the PSM project teams and other management varies from element to element. This can lead to confusion within both the PSM teams and among other managers, which can result in misunderstandings and wasted work. For a hybrid program to succeed the management of the teams must be thoroughly planned in advance. The result should be a network of corporate and local teams that work with well-defined responsibilities. Overall coordination generally lies with the corporate PSM manager, who will manage a combination of staff working on specific elements and staff working on particular facilities (see Figure 5-1). Local facility management represents a third dimension, and responsibility for coordination at the local level will generally be with a local PSM manager. Hybrid programs require carefully designed communication programs specifically designed to keep all the interested parties up-to-date on all activities. Team

Responsibility

Leader

Corporate "MOC" team

Develop management of change system for all sites

W. Miller, Plant Maintenance Supervisor

Corporate "Training" team

Develop training system for use at all sites

F. Williams, Corporate Human Resources Manager

Rocky Butte plant PSM team

Adapt Rocky Butte process hazard analysis system for use at all sites

F. Kirby, Plant Safety Manager

Plant team at each plant

Adapt own preventive maintenance system to meet PSM needs

Site PSM Coordinator

FIGURE 5-1. Example of Responsibility Matrix for Hybrid Approach

5.3 DEFINEPRIORITIES No company today has the luxury of unlimited resources to implement PSM programs and few have the capacity to tackle everything at once. Clearly, you will need to set priorities for each of the actions required by the system you design to ensure orderly and rational implementation. Having defined your company's PSM goals (Chapter 3) and assessed your current status (Chapter 4), you should be well equipped to establish workable criteria for setting priorities. Some possible criteria might include: • • • •

Compliance with regulations Extent of potential hazards Relevance to plant conditions Compliance with corporate policies

Before selecting which of these (or other) criteria make sense for your company's situation, it's useful to consider some of the reasons why each may be important. Noncompliance with regulations exposes your company to the risk of financial penalties, arising from fines or from restrictions or closure of operations. In addition, the company can suffer serious adverse publicity as a result of regulatory violations, which in turn can affect customer, shareholder, and employee goodwill. For example, you may have a management of change program that is lacking an aspect required by OSHA, such as the time period of the change. Resolving a noncompliance situation may determine the importance of implementing a particular element at a specific facility. The extent of potential hazards varies among facilities, and among units within a facility. If two facilities have similar inadequacies in their PSM program, but one has a greater hazard potential, the benefit of improvement will be greater at the high hazard facility. For example, a strong management of change procedure will be more important in the processing of reactive monomers than in the processing of aqueous latex products. In the absence of other considerations, PSM priorities can be set to reflect the level of hazard at each unit. Relevance of each element to plant conditions will vary. Some actions will produce a greater improvement in the level of process safety than others. Priorities for action items could be set according to the improvement in safety achieved. For example, addressing management of change will have greater impact than addressing facility siting at an existing facility.

Corporate policies governing safety management must be reflected in a company's PSM program. Hint: In setting priorities for action, you must also consider available resources. You may identify an action step that produces the single largest improvement in process safety, and discover that it requires all of your available resources. Alternatively, you may be able to spread your efforts among a number of lower priority actions that together have a greater impact on overall safety performance. Hint: Remember as you set priorities that you and your team must consider the expected benefit to the company, division, or unit as a whole, rather than simply addressing a single gap. Obviously, any specific immediate risk you identify in the course of your assessment must be dealt with quickly and responsibly; however, be careful not to let anomalous findings skew your perspective on broader priorities. For example, the absence of a capital project review process is a significant gap. However, if there is only one project per year this gap may have lower priority than an existing but seriously deficient operator training program.

Criteria such as those suggested above can be usefully applied to the implementation strategy you have selected. In assessing your current PSM status, you will have gained considerable insight into which facilities warrant priority attention; similarly, the assessment process sheds light on those PSM elements whose improvement will yield the most productive results. Whether you have chosen a facility-specific, a companywide, or a hybrid approach, it may be helpful to consider your priorities in terms of both facilities and PSM elements. The goal here is to help determine what needs doing, in what order, and with what level of effort. 5.3.1 Priority Facilities In the course of assessing your company's current PSM status, you and your team have almost certainly gained a clear sense of which facilities pose the greatest risk, whether by virtue of inherent process hazards, human factors, management systems, or a combination. As you set priorities for implementation you should closely review information gleaned from the assessment tasks. In addition, you should try to validate or flesh out your impressions through some more quantitative analysis that can help to identify priority facilities.

Stated simply, the extent of potential hazard depends on how much hazardous material a facility uses and the conditions under which it is contained. The quantity of material stored provides a measure of the size of any release that could result from a loss of plant integrity. The conditions under which it is contained can influence the extent of any damage that might result from the release. However, total quantities of hazardous materials do not, on their own, provide an entirely reliable measure of potential hazard. It is more useful to consider quantities of material within sections of the plant that can be isolated. The amount of material within these individual plant sections usually represents the largest credible release that could occur. Some examples of plant sections that may be isolated include: tank farms, unloading racks, and separate process buildings. You can quickly identify these plant sections by reviewing process flow diagrams and valving arrangements. Isolation points are defined by control valves or powered block valves that can be remotely activated. Process hazard analysis techniques help you identify the maximum credible accident scenarios. (Note that manual valves should not be considered reliable isolation points unless they are located to be accessible following a major accident. However, remotely-activated valves can only be considered reliable isolation points if there are adequate reliability engineering and maintenance programs in place.) You should be able to estimate the quantities of material contained within a section from mechanical and operating data. You should also consider operating conditions, which should be available from the plant mass balance or from actual operating data. Simple hazard models can predict the size of vapor clouds, radiation hazards from fires, and explosion over-pressures. Such models are available from a number of sources. A possible facility ranking exercise is described in Appendix 5-1. Hint: This ranking exercise can be assigned to one or two team members as a subtask. Consider selecting a teammate with experience in facility operations to compile the necessary data and one with process safety and computer experience to run the models. The resulting report can then be shared with the full team and included in the plan you submit to your management.

Once you have ranked your company's facilities in terms of inherent hazards, compare these results against the gaps you have identified in the PSM assessment tasks. In Figure 4-10, PSM systems were rated relative to their maturity alone. By adding information on facility hazards, you gain a more complete picture (see Figure 5-2). For example, a high-hazard facility that has

PSM Element Maturity PSM Element Management of change

Training

Developing

R

j E

E

R

J

E R

j

j

E R

Process knowledge and documentation Project review

Human factors

Mature

Embryonic

J R E

FIGURE 5-2. Sample Analysis of Selected PSM Gaps and Priorities E = Effingham J = Jackson R = Rextown Hazard code: Larger letter size indicates greater hazard. For example, high hazard materials (R) include phosgene, carbon disulfide, ethylene oxide, etc. Moderate hazard materials (E) include toluene, sulfuric acid, etc. Low hazard materials (J) include soda ash, alum, etc.

a relatively poor overall PSM status (e.g., the Rextown plant in Figure 5-2) should command top priority; low-hazard facilities with relatively sound PSM programs (e.g., Jackson) fall at the other end of the spectrum. In between, there will almost certainly be a number of cases that are far less clearcut. For example, you may find situations in which PSM programs are well developed but fail to fully address a high-hazard process or a worst-case scenario; in others, a facility engaged in relatively low-hazard operations may have a proportionately low level of PSM systems.

Hint: Remember, there is no substitute for judgment and experience. Consider these quantitative exercises as tools or methods to guide your team's determination of the right priorities, not as absolute formulas. In addition, keep in mind that your goal is to improve the overall status of process safety as part of a continuing effort—not as a single action, event, or "silver bullet. *

5.3.2 Priority Elements To establish priorities among the elements of the PSM program, you will need to consider two factors: the level of noncompliance and interrelationships with other elements. Levels of Noncompliance Consider your company and the findings of your PSM assessment of each of CCPS' 12 elements in terms of these levels of compliance: 1. 2. 3. 4. 5.

a formal system exists and is operational; an informal system is in place; a system exists but is not followed; an incomplete system is in place but needs upgrading; no system exists.

Each of these noncompliance situations is fundamentally different, and bringing each of them into compliance will require a different approach and series of actions. Where an effective informal system exists and is followed, the issue is one of style, not substance. A facility or unit may have a strong safety culture and sound safety practices, but its managers lack the habit of formal documentation, or simply don't think it is important. Assuming that safety performance meets applicable standards, you will probably assign cases like these a relatively low priority, compared with other noncompliance situations. Cases like these are also often the easiest to fix; since the fundamentals are already in place, whaf s required is simply to formalize the informal system by preparing and implementing documentation procedures. Where a system is not followed, or does not exist, the effect on safety is the same, and should command the same priority for attention. Keep in mind, however, that the underlying causes for these situations may be very different. In any case, when you identify these noncompliance situations you should carefully consider why they exist; this can yield valuable qualitative information about potential obstacles to effective implementation.

• If an element has a formal system that isn't followed, this suggests either a problem with the system itself (e.g., flawed design, impractical, insufficient detail or explanation) or a failure of management (e.g., inadequate supervision, lack of training, no followthrough or enforcement, or inadequate resources). Whatever the cause, you will want to make note of it and try to address it in your implementation plan. • If an element has no system at all, it may indicate that the facility manager does not fully understand what the element requires, or is for some reason unable to carry his/her responsibilities. In addition, a weakness in corporate oversight, direction, or resource allocation may contribute to the problem. Either way, the plan you develop must take these gaps into account.

Interrelated PSM Elements Some PSM elements are relatively easy to isolate, while others are integrally related, touching virtually every aspect of the program as a whole. In any program you should devote the highest priority to those elements with impacts across other parts of the program. This will yield greater efficiency for your PSM effort as well as improved consistency for the resulting system. Two elements with particularly widespread impact are process knowledge and documentation and process risk management. Other elements with significant cross-element impact include: training, management of change, and human factors. In addition to considering those elements that interrelate, you should pay particular attention to those that affect your operations most directly. For example, if your company has a major expansion program underway, you would assign the capital project review and design procedures element a higher priority than if your company has deferred all major capital projects. 5.3.3 Limitations on the Scope of the Plan Defining priorities helps determine the limitations of your company's plan— which in turn makes it more manageable. Remember that your goal at this stage is to develop a workable prototype, not an all-inclusive, perfect blueprint. If your plan is properly thought out and soundly put together, it should be adaptable to a wide range of contingencies—not all of which need to be explicitly addressed. At a minimum, your plan should address those activities that are covered by the OSHA regulations, or by equivalent local regulations and corporate standards. This means that all manufacturing or storage operations handling specified materials in excess of threshold quantities must be included in the program. Once your plan has been developed, tested, and refined, you may wish to consider expanding it to include activities that may not be governed

by regulation but that would benefit from PSM principles and practices. For example, the current OSHA regulation covers only certain operations that involve one or more materials listed by OSHA. However, a comparable operation handling an unlisted material might be considered for comparable treatment. In the immediate term, however, your plan may be most effective if you focus on the specific needs and priorities you have identified in the course of your work so far. If you clearly define the scope of your plan, and it directly addresses specific needs, your efforts will be far more successful than if you try to do all things for all people. Moreover, focusing on priority needs will almost certainly provide a sound basis for expansion or adaptation; for example, procedures developed to address training for operators using highhazani materials at one facility (see Rextown vs. Effingham in Figure 5-2) should be readily adaptable to lower-hazard substances at another facility— far more so than the other way around.

5.4 ESTIMATE RESOURCE NEEDS AND SCHEDULE The best approach is to begin by developing a plan for each PSM element. The summary of those plans represents an overall plan for the PSM program. The steps required to prepare a plan are the same whether your approach is centralized or decentralized. Your work up to this point has created the framework for a detailed plan. By following the process outlined in previous sections, you should have gained a clear understanding of: • What PSM goals make sense for your company, • Where your company currently stands in terms of PSM, and • The major gaps between goals and current status. This has enabled you to determine: • An appropriate implementation strategy, • Priorities for action, and • Realistic limitations. The next task you and your team must tackle is to fill in the blanks: what gets done, when, by whom, and at what cost. To do this, you will need to: • • • •

Identify all the steps required, Determine what resources will be needed to accomplish them, Decide on a timetable for completion, and Identify the ongoing resources that will be required after installation is complete.

Hint: At this stage of your efforts, you may wish to consider keeping senior management apprised of progress and involving facility managers more actively in the planning process. Because of their interest in the outcome, facility managers' input should be particularly valuable; in addition, keeping them close to the process will help you get the buy-in you will need for plan approval and implementation. Hint: A simple project management software package can be an invaluable aid to developing a good plan. These programs greatly reduce the effort required to modify plans and automatically make adjustments when variables change. Many good programs exist for both Macintosh and IBM PC compatible computers; ask someone in your company's planning or finance department for a recommendation. 5.4.1 Develop a Program Plan The basis for your program plan should be your team's assessment of the current PSM status (Figure 4-11), which will have yielded a list of deficiencies compared with the required PSM elements. These gaps must now be translated into statements of required tasks, which in turn suggest work products for inclusion in your implementation plan. For example, your assessment shows that the process knowledge and documentation management system needs improvement. To address this gap you need to plan a series of tasks. A simple way to define these is to select one of the priority elements you have identified and brainstorm all of the tasks required to address it, as shown in Figure 5-3. Hint: If you have chosen a facility-specific implementation strategy, it's wise to involve facility managers in planning at this point. Depending on your company's customs and individual preferences you might ask for specific input in defining the required tasks for addressing gaps. For example, some managers may prefer using brainstorming approaches involving all levels of staff, while others may not do this. Seeking input during task definition helps achieve buy-in. Networks of Tasks and Work Breakdown Structures You will notice as you complete this exercise that in many cases tasks will be interconnected, so that the product of one task provides the starting point for another task. For example, defining PHA-related training needs depends on

Priority Elements

Tasks

Process risk management

Define process information needs Develop PHA procedure flow Document PHA procedures Define staff training needs Develop follow-up tracking process

Process knowledge and documentation

Define P&IDs needed Establish management system for future updates

Training

Define training requirements Define training management system Develop training program Pilot test training Implement ongoing program

FIGURE 5-3. Sample Work Breakdown Structure: Priority Elements and Tasks

defining PHA procedures. These interrelationships, along with the priority elements and facilities you have defined, should help determine the order in which you plan to undertake the tasks. At another level PSM element interrelationships must be considered. For example, it will not be possible to install a PHA program until process knowledge and information are up to date. Figure 5-4 displays the interrelationship among several PSM elements, suggesting the order in which related tasks might be undertaken. This example reflects the finding that management of change, process integrity, and incident investigation procedures already exist. Once this "network" of tasks has been established, your next step will be to define a work breakdown structure for each task. A work breakdown structure shows the individual steps or elements required to complete each task. Each of these work elements can then be assigned to individuals or groups for action. Staffing Once you have identified and ranked necessary tasks and work products, you need to consider the skills required to accomplish them—and where you might be able to find them. To do this, you may want to revisit the skills matrices you developed in Chapter 2, which helped you select the PSM team. This same technique can be effectively applied to the tasks you have identified, as shown in Figure 5-5. Once this is done for each PSM element the overall needs for the complete program can be understood.

Accountability Process knowledge and documentation

Training and performance Process risk management

Capital project review Audits and corrective actions Standards, codes, and laws

Human factors Enhancement of process safety knowledge

Management of change Process and equipment integrity Incident investigation

FIGURE 5-4. Example of Interrelated PSM Elements and Priorities

Hint: Like the hazard ranking exercise, matching skills with tasks can be assigned to one or two PSM team members rather than requiring the full group's attention. In making such an assignment, keep in mind that this subtask creates the foundation for estimating resources (Section 5.4.3).

Training

Computer Systems Analysts

Operations

Process Safety Engineering

Process Engineering Define process information needs Develop PHA procedure Document PHA process Define training requirements Develop follow-up tracking process

FIGURE 5-5. Sample Matrix: Skills/Tasks Required for Developing PHA Program

In the context of staffing questions, you will also want to think in terms of supervision, or assigning responsibility for various tasks and subtasks. Each task you identify must be assigned to an individual who will assume responsibility for carrying it out to assure accountability. (The full team will probably prefer to be involved in these determinations, since all members have a stake in how responsibilities are divided up.) As a practical matter, you will likely find that certain clusters or groups of interrelated tasks fall together logically, suggesting that they arc best supervised by the same individual. (For example, in Figure 5-6, the tasks of developing a PHA procedure and documenting the procedure are closely related, and are assigned to the same task leader.) At the same time, you need to be sensitive to the demands on team members7 time, as well as that of colleagues the team proposes for task leadership roles. Define process information needs

Smith, Program Manager

Develop PHA procedure

Jones, Process Safety Engineer

Document PHA process

Jones, Process Safety Engineer

Define training requirements

Carmody, Training Specialist

Develop follow-up tracking process

Smith, Program Manager

FIGURE 5-6. Example Task Leadership Assignments for PHA Program Development

H/nf: It may be useful to consider the program plan, at this stage of its development, as your company's "ideal," within the limitations you have established for its scope. By first identifying what is needed, independent of the constraints of time or resources, you emphasize the tasks themselves as the substance of the plan—the core that drives decisions about resource allocations, rather than the other way around. (For example, see Figure 5-7) The result may prompt your team to think more creatively about schedule and resource requirements, as discussed in the following sections.

Training Specialists

Computer Systems Analysts

Operations

Process Safety Engineering

Process Engineering

Staff (Weeks)

1

4

4

O

2

24

8

8

20

2

4

4

4

4

30

Process risk management

10

18

4

4

6

Capital project review

12

8

2

2

2

Audits

1

34

4

2

4

Standards, codes, and laws

4

6

2

1

2

Human factors

4

22

16

O

4

Enhancement of knowledge

1

4

2

O

2

Management of change

12

8

26

2

2

Process and equipment integrity

30

12

30

18

2

4

12

6

O

2

107

140

108

53

60

Accountability Process knowledge Training

Incident investigation Total

FIGURE 5-7. PSM Staffing Needs by Element and Function

5.4.2 Develop a Schedule Any schedule you develop should reflect both the tasks you have defined and the resources available for accomplishing them. In addition, the implementation schedule in some cases may depend on a predetermined end date. For this reason, schedule and resource requirement tasks should be seen as interdependent; if s realistic to expect that you may need more than one iteration before both are firmly established. Each of the tasks and subtasks that make up the work breakdown structure should be relatively simple to estimate in terms of time required. If no one on the PSM team has specific experience with a given task, find someone else (for example, a facility manager) who does, and ask for his/her input. Once the time requirements for each task have allowed you to define the overall time required for each element these estimates can be combined to give a total program plan. In addition to specific deadlines for each task and subtask, you should also consider program milestones, key points in the plan at which you will want to review progress to date and make any necessary adjustments. For example, if you have adopted an element-by-element approach, you could consider completion of each PSM element as a milestone; similarly, each facility's program would constitute a milestone, if that is the approach you've chosen. Troubleshooter: In setting schedules and deadlines, try to be realistic while maintaining your sense of urgency. Be sure to build in sufficient time for group meetings to evaluate progress to date. Also, remember to consult those most immediately affected (for example, people whose staff will be called on) by the plan, whose other priorities must be taken into account in scheduling.

The final plan schedule should be presented in whatever form you think is clearest; a linear timeline, shown as Figure 5-8, for a single element and Figure 5-9 for the overall program, is one of the more common formats. Remember that your plan may call for multiple tasks to be undertaken simultaneously, which must be clearly indicated. 5.4.3 Develop a Resource Plan As discussed in Chapter 2, most of the basic resources you will need are fairly self-evident; time of staff will almost certainly be the largest single cost. Support expenses and travel also require funding. In addition, in the course of your work to date you may have identified specific resource requirements, such as computer software for hazard analysis or project management, or consulting services that fill in specific gaps in the knowledge base.

Month 1

Month 2 Week

Develop PHA Process Define process Information Develop PHA procedure Document PHA procedure Progress report Train staff Develop follow-up tracking Circulate for comment Revise and issue for pilot Progress report

FIGURE 5-6: Final Plan Schedule—Linear Timeline

Month 3

Quarter 1

Quarter 2

Quarter 3

Quarter 4

Quarter 5

Quarter 6

Quarter 7

Quarter 8

Feb Mar Apr May! Jun I JuIAug I Sep I OctNov I Dec I JanFeb Mar Apr May Jun JuI Aug Sep Oct Nov I Dec I Jan

Finalize project plan Accountability Design PSM system Pilot test Install Process knowledge & doc. Design PSM system Pilot test Install Training & performance Design PSM system Pilot test Install Process risk management Design PSM system Pilot test Install FIGURE 5-9: Final Plan Schedule for Overall Program

Quarter 1

Quarter 2

Quarter 3

Quarter 4

Quarter 5

Quarter 6

Quarter 7

Quarter 8

Feb Mar Apr May Jun I JuIAug Sep Oct Nov Dec Jan Feb Mar Apr May Jun JuI Aug Sep Oct Nov Dec Jan

Capital project reviews Design PSM system Pilot test Install Audits & corrective actions Design PSM system Pilot test Install Standards, laws, codes Design PSM system Pilot test Install Human factors Design PSM system Pilot test Install

FIGURE 5-9: Final Plan Schedule for Overall Program (continued)

Quarter 1

Quarter 2

Quarters

Quarter 4

Quarters

Quarter 6

Quarter?

Quarter 8

Feb Mar Apr May Jun JuI Aug Sep Oct Nov Dec Jan Feb Mar Apr MaylJun JuI Aug Sep Oct Nov Dec Jan

Enhancement of knowledge Design PSM system Pilot test Install Management of change Review existing PSM system Pilot test improvements Install Process & equipment integrity Review existing PSM system Pilot test improvements Install Incident investigation Review existing PSM system Pilot test improvements Install

FIGURE 5-9: Final Plan Schedule for Overall Program (continued)

Hint: A good place to start this part of your plan is to revisit the preliminary discussion you developed in Chapter 2, which may provide a framework that can simply be filled in with greater detail or more accurate information.

Human Resources The skills matrix you developed as part of the program plan forms the basis of your resource requirements estimate. In addition to the skill sets you have identified for each task, you will need to estimate the level of effort required at each stage of the work breakdown structure (see Figure 5-10). As with the scheduling exercise, team members should actively participate in this discussion, since they reflect varying areas of experience. Consider these requirements in as much detail as possible, for example: the number of staff-days of effort required to redraft process and instrumentation diagrams, or the number of days of operations engineering time needed to prepare operating procedures. The sum of individual task resource requirements provides an estimate of overall project needs. As a next step, identify the specific resources that are currently available to you and try to quantify them in terms of staff-time. Also, make sure to factor in any restrictions that might apply (e.g., a company policy that limits reas-

Srnith Jones Sweeney Carmody Total

Total

Progress Reports

Revise Per Comments

Develop Tracking Process

Define Training Needs

Document PHA Procedure

Develop PHA Procedure

Define Process Information Needs

Staff-Days Required

signment of support staff, or confines travel to a specific staff level). Ask each PSM team member to participate in this exercise, since each may have a different perspective and / or access to different resources within the company. Then compare the resource list with the staff allocation estimate, as shown in Figure 5-11. The gaps that emerge from this comparison represent areas for the team to examine closely and determine how best to address them. Some of the points the team should consider include: • • • •

do alternative resources exist? is there another way to accomplish this task? would a schedule adjustment free up needed resources? should we rethink the priority assigned to this task?

If the answer in each case is "no," the team must next consider other available options and their cost. Some of these might include: • reassigning resources from another, lower priority task • hiring additional project staff • retaining consultants Staff-Weeks

Available

Needed

Available

Needed

Available

Quarter 4

Needed

Quarter 3

Available

Quarter 2

Needed

Quarter 1

Process engineering

24

20

24

26

16

26

15

20

Process safety engineering

16

26

23

26

24

26

24

39

Operations

13

13

21

26

23

13

21

13

Computer analysts

12

9

12

10

7

9

6

9

Training specialists

12

9

20

13

4

13

O

9

FIGURE 5-11. Example of Ideal Staff Needs vs. Actual Availability Analysis

Other Resource Requirements As you review each of the tasks, you should also consider what other resources (other than time of staff) may be needed. For example, improvements to incident/near-miss reporting might require modem communications between facilities and headquarters; or a particular training module could be purchased to address an identified gap. In those areas where you think outside services will be required you should get estimates from qualified consultants. Consultants charge their time by the hour or will bid specific jobs at fixed rates. (If you contact a consulting firm, make it clear that you are looking for general information rather than a detailed proposal at this point; otherwise you will raise expectations, and, more important, it will take far longer to get the information you need.) In addition, working from the schedule you have developed, you will need to estimate travel costs. Key dates to keep in mind include those you have established as milestones, since they may call for group meetings to review progress. Once you have estimated the level of effort required for each task, you can, with some reliability, project support requirements (secretarial, administrative, etc.) at 15 to 20 percent of professional staff time. Identify Variables and Monkey Wrenches Even the best-laid plans are subject to last minute changes and unexpected variables, and there is an element of uncertainty in every estimate. Some of the more common sources of variance include factors beyond your control, such as: • • • • •

unexpected economic setbacks affecting available resources; price increases for major out-of-pocket items; layoffs; shift in business strategy that changes key processes; emergency conditions that command immediate priority.

Other types of variances arise from causes you can more readily predict, such as: a task turns out to be far more (or less) complex than estimated; necessary skill levels are higher (or lower) than estimated; available skill levels are lower (or higher) than estimated; more (or less) travel is needed; reporting is more (or less) time-consuming than expected. While none of these kinds of variances can be precisely estimated you should consider them (and others you identify) in terms of their potential impact, and build an appropriate contingency percentage into estimates of

both time and resources. In addition, where you know estimates to be soft, identify them as such; this is preferable to creating unrealistic expectations. As a final task in estimating resource requirements, ask the team to play devil's advocate. Given the range of experience the team represents, they should be able to poke holes in even the most precise, well-considered estimates. This will help you identify areas in which your numbers maybe soft and flag those in which you may have been overly ambitious in terms of time requirements. Once you have developed the program plan and schedule, and estimated resource requirements, you should organize this information in a manageable form for presentation to your PSM sponsor. If you have kept management informed about your progress you should have a clear idea of what is expected in terms of form, content, and level of detail. A sample table of contents for a project plan appears as Figure 5-12, and Figures 5-13 and 5.14 provide additional detail on selected portions of the plan.

1. Organization and responsibilities 1.1 Project description 1.2 Project organization 1.3 Project responsibilities 2. Administration 2.1 Communications 2.2 Documentation 2.3 Progress reporting 3. Project controls 3.1 Work breakdown structure (See Figure 5-3) 3.2 Schedule (See Figure 5-9) 3.3 Resources needed (See Figure 5-7) 3.4 Resource estimates (See Figure 5-11) 4. Quality plan 4.1 Quality management objectives 4.2 Project quality assurance 5. Installation and verification (See Figure 5-13) 5.1 Pilot testing 5.2 Training 5.3 Implementation 5.4 Verification 6. Financial controls (See Figure 5-14) FIGURE 5-12. Sample Project Plan Table of Contents

Installation and Verification Pilot Testing. Pilot testing of each PSM system will be performed at two locations to be selected by the project team. The test period will be two months. During the test period, the project team will monitor the PSM system to assure that procedures are clear and do not conflict with other procedures. Training. The project team will define the training needed for implementation of each new PSM system. The amount and type of training, and the number of staff requiring training, will be identified in the procedure developed. Installation. Installation of each new PSM system will occur after the pilot test phase. Documentation on the procedure will be circulated, and the procedure will be described at a meeting of the company Engineering Council. Verification. Each PSM system will include a mechanism for verifying installation. This will either be the requirement for copies of documentation being sent to Corporate EHS, or another mechanism defined by the project team. Financial Controls All effort expended in support of this project will be tracked by the Controller's office and reported to the Project Manager. Accumulated costs will be reported in monthly project team progress reports. An example is shown as Figure 5-14.

FIGURE 5-13. Example of Project Plan Sections on "Installation and Verification" and "Financial Controls"

5.5 COMMUNICATE AND GET APPROVAL OF THE PLAN Just as you presented a preliminary plan at the outset of the PSM initiative, you may want to think in terms of a formal presentation to your company's management when the detailed plan is complete. Remember that senior management's buy-in will be essential to successful implementation; so will the endorsement of line managers at the operating level, who will be directly affected by your plan. The way you present the plan depends a great deal on your company's style, your management's preferences, and the expectations you have established early in the process. In a hierarchical organization, senior management

Staff-Weeks Expended vs. Plan

Sep

Aug

JuI

Jun

May

Apr

Mar

Feb

Weeks

Plan Actual

Direct Expenses vs. Plan

FIGURE 5-14. Sample Report: Resources Used vs. Plan

Sep

Aug

JuI

Jun

May

Apr

Mar

Feb

Plan Actual

may expect to see and approve the plan before it is more widely disseminated. Other executives prefer to review materials after line management has seen and commented on them. Either way, both senior management and line personnel should have the opportunity to review the PSM plan and discuss it with the team. As a general rule, the more input and commentary you can incorporate into the finished product, the better its chances of approval—and of successful implementation—since it will reflect the interests of the people affected by it. Hint: If you decide on a formal presentation, consider having the full PSM team participate. Similarly, written communications concerning the plan (if, for example, it is broadly distributed for comment) should originate with the team. This will not only acknowledge their contribution but will also tangibly demonstrate the interdisciplinary nature of the challenge you have undertaken.

A formal presentation of the detailed plan might be organized to include the following topics: 1. 2. 3. 4. 5. 6. 7.

Brief review of preliminary plan, presented previously Discussion of process and tasks to date Overview of PSM assessment findings Major variations from initial proposal Discussion of implementation strategy selected and rationale behind it Discussion of priorities, by PSM element and by facility Summary of the plan —tasks required —schedule —resource requirements —accountability and reporting structure —expected results 8. Summary of plan benefits 9. Summary of support requested 10. Questions and answers A sample of Item 7, Summary of the Plan, is provided as Appendix 5-2. If you have circulated drafts of the plan, or portions of it, to your company's decision-makers, a full-blown presentation may not be necessary. However, you may find the discipline of following an outline such as the one provided above useful in organizing less formal discussions, either individually or with groups.

As with your earlier presentation, it's important to remember to "close the sale." Your goal for this discussion is not just to win approval but to gain a commitment for the resources you will need to move the initiative forward. To achieve this goal, you should devote particular attention to summarizing the benefits of the plan and the kinds of support you are requesting; these two points, taken together, create the essence of your sales proposition: What you will get and what it will cost you. To help define these benefits as crisply as possible, ask each team member to answer the question, "Why is this plan the best possible way for our company to implement PSM?" Then ask each one to list every positive characteristic the plan offers and every positive effect the company can expect from it. You will almost certainly find that the results of this brief exercise can be easily grouped into categories, each of which probably represents a selling benefit. Then consider these selling benefits in the context of your company's business priorities, match them against the goals management has established for PSM, and then try to distill the comments into a few key points that summarize the long-term value of your plan to the company as a whole.

APPENDIX 5-1: EXAMPLE FACILITY RANKING PROCESS* 1. Collect Data on Quantities and Condition of Hazardous Material Use the list of hazardous materials contained in OSHA CFR 1910.119, or other similar lists published by industry associations and regulators worldwide. Data on plant sections, quantities of hazardous material, and their storage conditions can be gathered in a number of different ways, depending on what information is available. • If good process flow diagrams or process and instrumentation diagrams exist they will identify the plant sections. • If no satisfactory process drawings exist you can identify major sections of the process (e.g., heat exchanger trains, refrigeration circuits, distillation equipment, reactor systems) that probably represent equipment that can be isolated from the rest of the process. • Data on the quantity and storage conditions of material within the plant sections may be available from a plant material balance. • The mechanical design drawings for equipment can be used to calculate quantities of material contained in major equipment items. Also include quantities in hold-up within the process area. *Source: Arthur D. Little, Inc.

• In addition to the quantities in the major equipment items there will be material in the associated pipework and other ancillary equipment. In the absence of better data, add 20 percent to allow for this. • Estimates of flow rates, residence times, and time required to shut off flows can be used to calculate estimates of potential release quantities. Such information can often be obtained from operating instructions. • Data on operating conditions can also be obtained from shift logsheets, where critical conditions are often recorded, or by conducting a survey of conditions in the control room and in the field. 2. Estimate Potential Hazard Areas Different materials pose different hazards, including: thermal radiation, explosion overpressure, and toxic and flammable vapor clouds. Some materials pose only one hazard, while others may pose all four. For the purposes of ranking facilities you will need to estimate the largest area affected by the potential hazards. You can arrive at such an estimate by calculating the greatest downwind distance to a particular level of hazard. The following thresholds are commonly applied: Thermal radiation 5 kW/ m2 (severe burns to bare skin within 30 seconds) Explosion overpressure 0.1 barg (minor structural damage, injury from falling masonry, glass etc.) Toxic hazard IDLH (immediately dangerous to life and health) concentration Flammable vapor cloud Lower flammable limit Each of these criteria represents a level at which injuries can occur. In addition, some other criteria may be appropriate, for example where existing hazard calculations are in use, corporate policy defines different standards, or local regulation sets criteria. In many plant sections a mixture of materials will be present. Since very few hazard models can handle mixtures, you will need to select a single representative material. For flammable materials it is generally most appropriate to choose the material whose boiling point is closest to the average normal boiling point of the mixture. For toxic materials you can select the most toxic material, but the initial concentration must be reduced to reflect the concentration in the released material. Once you have selected the quantities of material, hazard criteria, and representative materials, consequence models can determine the potential hazard zone. Generally, several of the releases will be very similar and it may be possible to reduce the number of modelling runs by grouping similar releases together. The modelling package you choose will provide guidance on how to set up and run the models.

3. Ranking the Facilities Facilities can be ranked based on the sum of the maximum hazard distances for each release. Only one hazard distance should be used for each release, even if there is the potential for more than one hazard (thermal radiation, explosion overpressure, toxic cloud and flammable vapor cloud). The highestranked facility will be the one whose potential releases would reach the greatest total distance. Keep in mind, however, that ranking facilities on this basis does not account for the impact of the potential hazards on surrounding communities. It may be that your most hazardous facilities are located in remote, unpopulated areas where there is little probability of any injuries outside the plant perimeter. To factor location into the rankings, multiply the total distances by the average population density in the area surrounding the facility. Where population varies with distance, you may need to vary the density by distance. One effective approach is to consider population density in concentric circles of 1 km, 2 km, 5 km, and 10 km radius.

APPENDIX 5-2: EXAMPLE OF MANAGEMENT PRESENTATION ON PSM PLAN PSM Implementation Program Tasks and Schedule Assign teams

Develop management systems

Pilot test

install

Propose teams Receive approval Initial system start Propose systems Receive/review comments Final systems Final system complete Initial system start Recruit sites Install Review results Final system complete

All sites complete

PSM Implementation Program Resources Requirements Assign teams

2 staff-weeks

Develop management systems

220 staff-weeks

Pilot test

15 staff-weeks

Install

30 staff-weeks

PSM Implementation Program Reporting & Accountability Assign teams

Prime Mover J. Miller

Reporting Confirming letter

A. White

Monthly progress report

A. White

Pilot test analysis summary

F. Jenkins

Monthly summary report Monthly progress reports

Develop management systems

Pilot test

Install

Plant Managers

PSM Implementation Program Results Assign teams

Develop management systems

Pilot test

Install

Assignment of resources

Management system descriptions and related tools

Validation of systems Buy-in from sites

Installed PSM systems

6 DEVELOP SPECIFIC PROCESS SAFETY MANAGEMENT SYSTEMS 6.1 SELECTANAPPROACH The way you approach designing specific PSM systems depends on the nature of the gaps the overall system must address. As discussed in Section 5.3.2, the levels of PSM compliance your assessment has revealed can take many forms: 1. 2. 3. 4. 5.

a formal system exists and is operational; an informal system is in place; a system exists but is not followed; an incomplete system is in place but needs upgrading; no system exists.

A review of these thresholds can help you select the best approach to systems design for your company's needs. Also consider other factors, such as: • Available Resources. The staff, expertise, and funding you can call on may influence the approach you choose, and, as in other areas of PSM implementation, you must work within the restrictions you have identified. • Company Practice. Some companies have clearly defined methods and practices for systems design; these can range from a very team-oriented approach to a highly focused effort directed by a single individual. In others, systems design reflects the task at hand and does not follow a formal protocol. • "Customer" Expectations. Keep in mind that the output of your PSM systems design must address the needs of a range of "customers/' including senior management, facility and other operating personnel, and the PSM team itself. As you approach designing the PSM system, you may want to revisit their expectations. Systems will also have to reflect issues such as plant size, location, type of operation, and types and quantities of materials used. Keeping these variables in mind may help you consider the following discussion of some available methods for PSM systems design in terms of your company's requirements: Total Quality Management (TQM) techniques, use of model programs, and business process redesign. Each of these methods has advantages and disadvantages in terms of application; in fact, you may decide to adapt features of each to create your own "hybrid" approach.

6.1.1 Total Quality Management (TQM) Techniques Many companies have adopted Total Quality Management as a way to promote continuous improvement in a broad range of business applications. TQM considers all business activities as processes, each one of which involves specific customer-supplier relationships. These relationships maybe entirely internal, defined in terms of the process under study. For example, delivering efficient electronic mail service is a "process" in TQM terms. The "customers" for your company's electronic mail system are the employees who use it; the "supplier" may be office services, MIS, or other support personnel. Similarly, if you consider the preparation and updating of P&IDs as a process, customers would be those employees who use P&IDs for engineering, design, or training. Suppliers would be all personnel (engineering, operations, others) who have responsibility for assuring the accuracy and dissemination of P&IDs. TQM calls on project teams to analyze business processes in terms of customer satisfaction, and begins with an understanding of who the customers are and who is responsible for meeting their expectations. In relatively simple processes (such as the electronic mail example), the customer-supplier relationship is fairly clearcut. In more complex processes that affect many people in different ways, there may be multiple customer and supplier categories, each requiring its own analysis. TQM untangles these processes by identifying the subprocesses, activities, and customer-supplier relationships they comprise. This analytic approach tends to be most successful when an existing system requires incremental improvement. For example, if a PSM teamdetermined that the company's management of change process does not cover trial batches of new products, they can strengthen the PSM system through an incremental improvement. If, on the other hand, they found that the management of change process in the company was inherently flawed, or nonexistent, another approach would probably be more productive. In other words, TQM can be extremely effective when applied to readily definable process gaps or areas that require specific intervention or modification to meet PSM needs. To illustrate this, consider the management of change example outlined above, where the gap in system coverage has been clearly identified. The charter for this TQM effort is "to improve our management of change process by assuring review of all appropriate changes." If you selected TQM techniques to address this gap, you would first assemble a TQM project team. (See Section 6.2 for more discussion of forming and managing teams.) Such a team would include representatives of the functional group that "owns" the process (that is, the people responsible for its operation), as well as of other groups who are the process's customers and suppliers, for example:

Management of Change TQM Project Team • • • •

Engineering department—process owner Operations groups—supplier Purchasing—customer Maintenance—customer and supplier

Another way to consider the customer-supplier relationship is in terms of those who have input into a process (suppliers) and those who use its output (customers). As this sample team suggests, very often a single group (in this case Maintenance) functions as both a customer and a supplier, having input into the process as well as need for its output. With all of the management of change process's key constituents represented, this TQM team can focus specifically on the problem of applying the system to trial batches of new products. Assisted by a facilitator, members use

Customer/Supplier Needs—Management of Change Engineering Speedy review Minimal paperwork Feedback to process safety information Operations Speedy (minimize downtime) Purchasing Clear specifications Flexibility in suppliers Maintenance Clear rules on applicability Interface with work scheduling Safety Thorough review Clear paper trail FIGURE 6-1. Simplified Example of TQM Team Results: Customer/Supplier Needs

techniques such as brainstorming, flowcharting, and statistical analysis of performance results to: • • • • •

identify customer requirements (see Figure 6-1) identify supplier needs (see Figure 6-1) describe the current process (see Figure 6-2) identify process breakdown points (see Figure 6-3) determine the root causes of the breakdowns (see Figure 6-3)

Current Process Flow: Management of Change

Request for maintenance

Comparison against MOC review triggers by maintenance supervisor Review required

Work order processed

No review required

Engineering sign-off obtained

Safety sign-off obtained

Operations sign-off obtained

FIGURE 6-2. Simplified Example of TQM Team Results: Current Process Flow

Request for maintenance

Comparison against MOC review triggers by maintenance supervisor

Work order processed

Engineering sign-off obtained

Safety sign-off obtained

Operations sign-off obtained

Changes in process and materials do not trigger MOC review Causes: MOC system design gap Operations sign-off often assumed Causes: Pressure to close work orders makes delay undesirable; only Ops Superintendent authorized to sign; no audit/enforcement of procedure No linkage back to process documentation Causes: No process for information flow; no assigned responsibility for updating documentation FIGURE 6-3. Simplified Example of TQM Team Results: Identification of Breakdown Points

Based on this analysis, the team then recommends modifications to the process that will address the root cause of the problem while meeting customer and supplier needs. For example, in this case the TQM team might determine that changes to operating procedures were not addressed by the management of change process, which focused solely on hardware changes (process breakdown). Further study might indicate that process engineers had never been made aware of the management of change process (root cause). The team would then modify the process to include explicit treatment of procedural changes, communicate these process modifications to both operators and engineers, and revise the company's Standard Operating Procedures to reflect the changes they had made. By this means the TQM team would strengthen the company's existing management of change process by expanding it to cover a broader range of changes. One strong advantage the TQM approach offers is the opportunity to involve process customers and suppliers in problem-solving and to capitalize on their expertise and varying perspectives. This in turn helps generate buy-in for the solutions that result. At the same time, as suggested earlier, TQM may be less effective when the desired result exceeds incremental change, for example when a process does not exist or requires radical redesign. TQM techniques tend to encourage micromanagement rather than broad rethinking of business processes and thus are most applicable to very specific, definable problems. There are many good sources of additional information about TQM, some of which are listed in the bibliography of this book. 6.1.2 Using Model Programs Also known as the "don't reinvent the wheel" approach, using model programs can offer significant efficiencies in PSM system design. Model programs take many forms; you can find them in other companies, in your own company, or in reference materials that document industry practices. The CCPS Plant Guidelines book, for example, provides useful information about how numerous companies have addressed various elements of PSM. Other sources include your counterparts at other companies, who may be willing to share their experience, either in the form of detailed process or program descriptions or as useful anecdotal information. And, of course, you should not overlook experience within your own company, which your PSM assessment may have identified as applicable across divisional or other organizational boundaries. For example, you might have found that one plant's approach to accident investigation could, with minor adaptation, serve as a model for installation throughout its sister divisions. (See Figure 6-4.) If, after considering the advantages and disadvantages, you decide to use model programs, the following steps should be followed:

First responder notifies supervisor

Emergency response

Secure area

Assess severity

Non-serious

2nd level supervisor completes incident analysis

Report sent to safety department

Serious

Assistant plant manager appoints investigation team

Investigation proceeds

Report to plant manager

Adaptation to General Use Throughout a Division First responder notifies supervisor

Emergency response

Secure area

Assess severity

2nd level supervisor completes incident analysis

Report to plant manager

Assistant plant manager appoints investigation team

Conduct investigation

FIGURE 6-4. Simplified Example of Adaptation of a Model Program

Forward report to division safety department

• Understand the model. Review the model program and develop an understanding of how it really works. It is often useful to draw a flow chart of the model process to be sure you completely understand it. • Reconcile the model with your own business processes. Think about how things are done at your company or facility. Compare your approach to communications, information-handling and recordkeeping, training, and reporting to those assumed by the model program. Adjust the model program to be consistent with your organization's way of doing things. • Reconcile the model with existing roles and responsibilities. Each role called for in the model program will have to be filled by someone in your organization. What are the roles and responsibilities required? To whom will they be assigned? • Reconcile the resource requirements. The model program will involve some time requirements and may also call for some materials or information. Determine how the time will be made available, and where the materials and information will come from, before trying to use the model program. Troubleshooter: Beware the temptation to adopt model programs wholesale. Before installing "ready-made"programs, be sure to screen them against the criteria you have established for the PSM system you plan to design (see Chapters) to assure that they properly meet your company's needs.

Using model programs offers the advantage of efficiency. Installation can be accomplished relatively quickly, often with minimal investment of staff time. Since model programs evolve from the experience of others, many of their kinks have already been worked out, which can facilitate implementation. At the same time, relying on model programs has its share of pitfalls, in large part because a PSM system cannot succeed unless it can be properly integrated into the management systems in place for other activities. By definition a model program reflects the specific needs, operations, and practices of a given company, all of which may be quite different from your own. A related limitation of the model program approach is that these "transplants" rarely take full advantage of opportunities to link PSM into other company systems, for example, using existing human resources systems to manage process safety-related training. Hint: Use model programs to trigger ideas and focus or expedite the systems design effort. Look for opportunities to learn from the experience of others, but in most cases try to emphasize "adapt" rather than "adopt"

6.1.3 Business Process Redesign For PSM systems that warrant dramatic reconfiguration, or where systems do not currently exist, business process redesign may offer the most effective approach. Like TQM, business process redesign is team-oriented but its thrust is very different. TQM's focus on incremental improvement presumes that the system under review is essentially sound and studies ways to improve its efficiency and/or effectiveness. Business process redesign presumes nothing about what may be already in place, focusing instead on the process's goals and rationale as the starting point. For example, employee training might be found to be an area without an adequate PSM system. If a TQM team were commissioned, they might start with the question, "how can we improve documentation of safety training?" However, a team charged with redesigning the training process might begin with the question, "how can we assure that employees are equipped with the knowledge and skills to do their jobs safely?" In essence, business process redesign approaches systems design from the foundation level, challenging the status quo and encouraging creative application of team members' skills and experience. For this reason, the team assembled for business process redesign may be different from a TQM team, in that this approach requires a broad perspective on PSM and the processes it governs. (See Section 6.2 for further discussion.) With the goal established (e.g., "assuring that our employees and contractors are fully equipped to perform their jobs safely"), the team then works toward achieving it through a series of steps, including: • Identifying the Process Stakeholders or Constituents. These are the groups or individuals who will participate in the process, or otherwise be affected by it. Using Training and Performance as the example, process stakeholders might include operators, operations management, human resources or training staff, and executives who are accountable for the company's safety record. • Identifying the Requirements of Each Stakeholder Segment. The process under review affects different job categories in different ways; the more complex the process, the more diverse its stakeholders' needs will be. For example, facility managers want training to be time- and cost-efficient; those reporting to them need a curriculum that's relevant to their jobs. Understanding these needs is critical to business process design, which, like TQM, is "customer"-driven. See Figure 6-5 for an example. • Defining Process Barriers. If a business process does not exist or simply doesn't work, the redesign team needs to know why. In some cases, the reason may be simply that no one recognized the need for a given system; similarly, a system may remain "broken" because no one realized it needed fixing, or knew how to go about it. In others, the team may

Stakeholder Needs for Employee Training Operators Communicate appropriate knowledge and skills Be interesting Include take-away documentation

Supervisors Provide qualified operators Involve minimal time away from job Be practical

Human Resources Communicate effectively Be regularly updated Provide documentation of training

Plant Manager Minimal cost and time commitment Effective transfer of skills and knowledge

FIGURE 6-5. Simplified Example of Stakeholder Needs

uncover other barriers, such as insufficient management support, lack of funding, or a company tradition that resists any form of structure. Since business process design begins with the foundations, the underlying obstacles must be understood and addressed to assure that the resulting system will work. One technique for identifying barriers, the " fishbone" diagram, is shown in Figure 6-6. • Defining Specific Roles and Responsibilities. By defining specific roles and responsibilities, the team creates a framework for process definition. This framework essentially creates job descriptions with respect to the process safety management system, for the individuals who interact with the system. For example, Figure 6-7 shows a case where the line supervisor's responsibilities with regard to training are defined to include providing input to the content of curriculum design, while the human resources department was given responsibility for scheduling sessions.

Why Have Past Efforts at Training Been Unsuccessful?

Materials

Methods

No system for documenting, OJT

Training is totally lecture

No testing or validation

No written materials used Post training ineffective

No linkage of training to

Supervisors left shorthanded if

management of change

employees sent for training

Transferred employees

Supervisors too busy to arrange

scheduled at supervisor option

for training schedule

Processes

FIGURE 6-6. Simplified Example of Identifying Barriers

People

Employee Training Program Operator Develop and maintain training programs

E

Human Operations Supervisor Resources

E

R, A, W

Schedule training session

R, A, W, E

Document completion of training

R, A, W, E

Conduct training sessions

E, W

R, A

Send employee for training

R, A, E, W

E, W

Safety

E

FIGURE 6-7. Simplified Example of Roles Definition R E A W

= Responsibility = Expertise = Authority = Work

• Documenting the Process. The net effect of these steps is a process description, defined in terms of customers and suppliers and their interaction. Next, the team can summarize that description in the form of a process flowchart, to illustrate the roles and responsibilities of each process stakeholder (see Figure 6-8). This chart provides the basis for developing standard operating procedures, or other process documentation, that the company can incorporate into existing practices. A key advantage of the business process redesign approach is that while it draws on past experience (in the form of the team's collective expertise) it is not bound by it. This helps minimize the risk that inadequate practices may become institutionalized through habit or neglect, and forces the team to take a fresh look at the critical processes under review. At the same time, this approach requires more concentrated effort than either TQM or model programs and may not be necessary in cases where incremental improvement is all that's required to address PSM gaps.

Human Resources

Operations Supervisor

Safety Staff

Schedules training

Performs classroom training

Signs in new employee

Documents training

Performs OJT

Conducts qualifying test

Notification of employee qualification

FIGURE 6-8. Simplified Example of Redesigned Process Flow

6.2 SELECTATEAM Note: You may want to revisit Section 3.3, beginning on page 50, which discusses basics of team selection, composition, and management, since many of these suggestions can be usefully applied to PSM system design.

As the previous discussion suggests, interdisciplinary teamwork often benefits the design of PSM systems, both by spreading out the work involved and by drawing on multiple perspectives. In addition, the team approach can expedite buy-in from PSM end users, if only because it's harder to resist the findings of a team than the conclusions of a single individual, however well-respected he or she may be. If you are not in a position to mobilize a formal company team to focus on PSM system design, you should at least consider: • identifying qualified advisors within your company: colleagues, subordinates, and/or superiors whose judgment you trust and whom you can tap as sounding boards for your ideas; and/or • calling on outside consultants for assistance, either to supplement your own efforts with additional staff or to advise you on specific components of system design. If you decide to adopt a team approach, the following discussion may be useful in guiding your efforts. Choosing the Right Team for the Task The teams selected to design PSM systems should reflect the approach you have chosen. However, regardless of the approach you use, keep in mind some general characteristics of effective process design teams, which include: • Relevant Expertise. Whether a new system is being created or an existing one modified, the people responsible must have enough experience and judgment to provide meaningful input. • StakeholderRepresentation. As previously noted, every process has owners, customers, and suppliers, and wherever possible all of these stakeholder groups should be represented on the PSM system design team. • Sufficient Authority. PSM system development often requires working across organizational boundaries and in some companies this requires specific authority. In addition, to be effective, the design team and its leader should be adequately empowered to undertake the task at hand without needing multiple approvals every step of the way.

• Clearcut Mission. As with other team structures discussed in this volume, the design team needs a clearly articulated understanding of its mission, responsibilities, and limits. If you apply them to the three approaches presented in Section 6.1, these characteristics may yield different team compositions. For example, the expertise required for a TQM-style process modification differs from the broader, more creative perspective you would need for business process redesign. Similarly, the level of authority necessary to create a brand-new process will probably be higher than if the task is simply a matter of refining a model program that already exists. Stakeholder representation varies according to the complexity of the process under review, and the team mission should clearly reflect the specifics of the work it is expected to do. You will also want to consider consistency of effort in selecting the process design team. Depending on the specifics of the PSM plan you have developed, it may be feasible to assign the entire PSM system design process to a single group that will be responsible for seeing it through to completion. On the other hand, you may find it either more practical or time-efficient to assign individual design components to different sub-teams that can then work in parallel. In the first instance consistency is assured, since the same people will be focusing on the system design from start to finish. In the latter case, you will need to manage the various sub-teams fairly closely to make sure that their various assignments coalesce into a coherent system. One way to accomplish this is to select and assign a single facilitator to serve all the sub-teams. Another way involves occasional plenary meetings where all the sub-teams meet to compare notes and report progress. In considering team composition, you will probably find that many candidates have emerged through your PSM work to date. Members of the PSM assessment team, because of their exposure to the initiative, are logical leaders for design teams and sub-teams; their continuing involvement also helps reinforce consistency.

Great Expectations As with other project teams, those selected for PSM system design need a clear understanding of what your company expects from them. Regardless of which approach you've chosen, team members need to know: • What Is the Expected Process for Their Work. This requires a clear presentation of the approach (TQM, process redesign, model programs, other), which will to some extent dictate the working process. In addition, specifics about team leadership, the role (if any) of facilitators or advisors,

location and frequency of meetings, and other matters need to be thought out and communicated to the team. • What Is the Expected Output or Work Product. The specific form of the finished product will vary according to your company's practices and needs. However, if s reasonable to expect that the team's efforts will ultimately produce a set of documented Standard Operating Procedures (SOPs) for the management system, or their equivalent within your organization (see Section 6.3). Interim work products may include progress reports (see Chapter 8), documentation of discussions and analyses, flowcharts, or other materials. • What Support or Resources They Can Expect. You should consider in advance what the design team's resource needs might be and how you can address them realistically. For example, if funds exist for travel, outside consulting services, or project management software, these maybe useful expenditures. Similarly, administrative support can expedite the team's efforts. Whatever the level of support your company can provide, if s important to make it clear; if you must undertake systems design as a bare-bones effort, the team needs to know it in advance to avoid unrealistic expectations. • What Deadlines or Other Constraints Apply. Your PSM implementation plan should include some treatment of schedule and you should have a clear sense of the gaps that must be addressed in systems design. In addition, you have devoted considerable attention to the question of resource requirements. Translating this information into team-specific guidelines helps keep the team on track. In addition to establishing deadlines and resources, your plan may involve other requirements that will affect systems design. For example, you may have determined that the documentation function should be addressed in concert with all the other PSM elements rather than as an independent component, which would dictate the way you structure and manage a team charged with designing PSM documentation. • What Incentives and/or Performance Criteria Apply. Participating in PSM system design may be its own reward; however, this may not always be entirely realistic, especially when an assignment falls outside a team member's usual job description. Consider what incentives may apply to the design team's contribution to your company's PSM initiative. These need not necessarily be monetary; they maybe incorporated into performance reviews, which should recognize extra effort. Whatever the method, incentives (and disincentives) need consideration in advance and should be communicated clearly to team members.

6.3 DEVELOPTHESYSTEM With the approach selected and the design team(s) designated, you can now begin to develop the PSM systems you have planned. A good place to start is with a team briefing that covers: • the approach you plan to use (see Section 6.1); • discussion of expectations (see Section 6.2); and • team training. Training needs will vary according to team members' familiarity with the approach you have selected. In a company with an active TQM program, you may need only a refresher course or briefing. For others it maybe worthwhile to provide a more formal introduction to TQM techniques and processes. In many cases, the use of a trained facilitator (either from inside your company or an outside consultant) can greatly expedite the team's preparation and reduce the amount of individual team member training required. As suggested earlier, the format for the design team's work product depends on your company's style and practices. Some companies produce SOPs against a consistent format or template (see Figure 6-9 for an example).

1. Purpose What is the objective of this program? 2. Scope What is covered? 3. Definitions Description of any special terms used. 4. Responsibilities Who is responsible for what? 5. Process What steps must be carried out? 6. Documentation What documentation and reporting is required? 7. Training Is any special training required? 8. Control How will system performance and level of compliance be periodically assessed? FIGURE 6-9. Sample Outline for Management System SOP

If this is the case, it's wise to consider this format as an effective way to present the team's work product, since it is likely to be widely understood and recognized as an official company document. Other organizations present their policies and procedures in a less formal manner, and/or with considerable variation. In some companies, each functional area, division, or business unit may have its own preferred format; in others, the format depends on the topic presented. In cases such as these, it is particularly important to identify the "process owner/' since this determination may drive the form of the team's work product. Keep in mind as you develop formats that the real priority is a work product that will be recognized and used by the people whose work habits the PSM system is intended to influence. This means understanding your company's practices (as assessed in the goalsetting stage described in Chapter 2) and adapting your work to them. This doesn't mean that you should feel constrained by formats for their own sake, or obliged to follow traditions that may not apply to the process you're undertaking. It does suggest, however, that to the extent possible you should try to draw on what already exists rather than needlessly revamping a proven method.

6.4 RECHECK AGAINST CRITERIA As you near completion of each PSM element's modification or redesign, it's useful to check results against the criteria you established as part of developing your plan. You may find it helpful to review the plan at intervals, and to revisit Section 3.2, which discusses PSM criteria. Similarly, you will want to assure that the modifications you devise address the priorities you identified as part of the planning process (see Section 5.3). By checking against these criteria incrementally you can make any necessary refinements or adjustments before undertaking full installation. You should also consider a final, global validation of all the system components, to make sure they integrate properly. You can choose any of a number of methods for conducting these checks. One involves developing a systematic checklist or grid that displays the criteria themselves and checks each modification against them. In addition, as with previous exercises, it's often useful to call on your colleagues on the PSM team, or on other advisors, and ask them to play devil's advocate. It's often useful to combine methods such as these, because together they yield both a quantitative assessment ("Does this modification do what we said we wanted it to do?") and a more qualitative judgment ("Will this modification work in actual practice?").

7

PUT THE SYSTEM INTO PRACTICE Putting the PSM systems you have developed into actual practice provides the true test of all your work to date. If you have "front-loaded" the development by devoting careful attention to detailed planning, you have helped close the gap between theory and practice. To maximize the value of that upfront investment, it's wise to devote the same care to initial installation. The implementation plan you and your team developed (Chapter 5) provides the framework for the installation phase; it defines your strategy, priorities, resources, and timetable. The specific PSM systems you have designed (Chapter 6) provide the substance; they are the activities you plan to install. What remains is the series of tasks required to translate words on paper into tangible action. Key considerations include where to begin the process and how to manage it. For companies with a few very similar facilities, these decisions may be relatively straightforward; for those with many, highly varied operations, setting priorities can be far more complex. Either way, you should consider the available alternatives in terms of your company's PSM goals, available resources, and management style. At the same time, never lose sight of the fact that ultimately your goal is to optimize companywide safety performance.

7.1 PILOTTESTING Successful installation, or roll-out, of your PSM systems requires sound planning and effective execution. No matter how diligent you have been, or how receptive and well-managed your company may be, no system as complex as PSM can work perfectly the first time. As every project manager knows, it's impossible to anticipate every outcome or contingency—especially when human behavior is involved. Pilot testing a new system provides the opportunity to identify weaknesses under controlled conditions; this in turn enables you to fix problems before the system becomes fully operational. Once these problems are corrected, the pilot test produces a template for installation that can be replicated elsewhere. In the case of PSM, pilot testing yields other benefits as well; this approach can: • Strengthen "buy-in" through increased participation and awareness. Up until now, your company's PSM efforts—even if they have been well publi-

cized internally—have been confined to a small, highly focused group. Putting your plans into operation means involving more people—and creates the opportunity to generate interest and enthusiasm, locally and throughout your company. • Improve immediate-term opportunities to cross-fertilize good practices. Pilot tests highlight good ideas and practices as well as bugs and problems. Once you've put plans into action, you may identify certain procedures or practices that can be replicated elsewhere—right away. • Enable management to accurately re-estimate resource requirements. A pilot test helps take a great deal of the guesswork out of forecasting timetables, staffing needs, and costs for full PSM implementation. 7.1.1 Factors to Consider in Pilot-Site Selection Choosing the right facility for a pilot test requires balancing several factors, and there are no hard and fast criteria. However, you may find it helpful consider questions such as the following as you make your selection. • Opportunities for learning —Is this site unique within our company in terms of its processes, or is it fairly representative? —JHow many of our proposed PSM systems directly affect this site? • Opportunities for local improvement —What is the current level of PSM performance at this site? —Where does this site rank in terms of hazard? —Are there specific priorities for safety improvement for this site? • Opportunities for cooperation —Would local management be receptive to participating? —Would local staff be able to support the effort? A good candidate for selection as a pilot site would offer opportunities in each of these categories. Once you have identified several possibilities, ask the team to consider the benefits of each: • Would a test at this site yield results that could be meaningfully applied throughout our company? • Would the pilot test process yield specific benefits for this site? If the answer in both cases is "yes," then consider the local climate. Local cooperation—or lack of it—may be the single most important determinant of site selection, since without it you cannot field a valid test. However, if you have kept facility managers informed or involved as the PSM process has gone forward, you should have some ideas about which of them would be particularly enthusiastic—or otherwise. In addition, having identified site-specific benefits may help you win the support of a manager who might otherwise be reluctant to participate.

Hint: Note that the site selection process need not be lengthy or complex. Team members' regular job responsibilities, as well as their PSM work to date, will have thoroughly acquainted them with a range of your company's facilities. It's more than likely that logical candidates for the pilot site will have emerged naturally from the process and may already have been proposed. Hint: Involving nonmanagement employees in the PSM pilot can be very helpful. Involvement at early stages encourages buy-in from people who will ultimately be important to the success of PSM. If you select a unionized facility, it may be wise to involve the local representative in advance of the test. Consult with the facility manager to avoid misunderstandings.

7.1.2 Gaining Local Support for the Pilot Test Once the PSM team has agreed on a potential pilot site, you should reaffirm that the facility manager is fully on board. Your expectation of cooperation should have been a factor in site selection, but you need to be sure that the facility manager fully understands what's coming. Depending on the nature and the quality of the contact you've had with him or her concerning the PSM initiative, this may involve anything from a friendly phone call to a full court press. Either way, before you undertake this you may want to consider outlining precisely what your team is requesting—and what it is offering. That way, you can make your case clearly and convincingly, and, more important, the facility manager will clearly understand what he or she is agreeing to do. This outline of roles and responsibilities, which need not be exhaustive, can be readily expanded to apply to full-scale implementation. In preparing the outline, keep in mind that the mote effort you are requesting, the greater the incentives or benefits you must offer. Depending on how you structure the test, the facility manager's responsibilities may range from simply monitoring and reporting progress to overseeing and directing the entire pilot test. You must also factor in any demands on local staff and be prepared to address the facility manager's concerns about meeting productivity requirements. Hint: In recruiting facility managers for the pilot test, be sensitive to your company's chain of command—and the preferences of the individuals involved. In most organizations facility managers report up the line. In some companies a request for this kind of assistance must be cleared at a higher level; in others, facility managers have considerable autonomy and do not take kindly to its being underestimated.

Hint: A key consideration for many facility managers will be the cost (in dollars and in time) of their participation. To the extent possible, consider devising some means of providing subsidies, or otherwise sharing costs; this will not only help overcome resistance but will also underscore the company's commitment to PSM.

7.1.3 Implementing a Successful PSM Pilot Like any other effective test, your company's PSM pilot should be neither too difficult nor too easy. A "successful" pilot test is one that (1) thoroughly exercises the PSM system you have developed so that you can identify its strengths and weaknesses, and (2) is sufficiently well-designed and -executed that it can act as a model for full-scale implementation. For example, testing a management of change system in a way that ranks changes would be appropriate. In short, consider the pilot test as a microcosm—and treat it with the same attention you would devote to a companywide installation. This means the pilot exercise requires a number of specific activities, all of which will be replicated (with appropriate adjustments) on a larger scale. These include: • Defining goals and parameters. Like any other initiative, a PSM pilot test needs definition of its purpose, methods, objectives, and duration. This need not be a complex exercise; a simple way to accomplish this task is to answer these questions: What are we doing, and why? When and where are we doing it? How are we doing it, and who is responsible? This enables you to summarize the test project in clear, simple terms, as shown in Figure 7-1, as well as to establish some criteria by which to measure success. In addition, it also creates a framework for generating interim progress reports by establishing topic areas for discussion. Hint: In considering the duration of the test, try fora balance: long enough to fully exercise the system and gain meaningful results, but not so long as to diffuse attention to the larger challenge of companywide installation.

• Clarifying expectations. Everyone involved needs a clear sense of what is expected and what their responsibilities are. This includes the facility manager, local employees, the PSM team, the PSM champion, and company management. One way to accomplish this is to define the roles of all the groups and individuals participating in the test through simple job descriptions and /or organizational charts. Figure 7-2 shows an example.

Following is a memorandum prepared by a corporate division's PSM team, describing the pilot test they plan to undertake. To: From:

All Facility Managers, Safety Engineers, and EHS Staff PSM Task Force

As you know, the Task Force has spent the past five months reviewing the division's process safety management (PSM) systems as part of our company's corporate PSM initiative. We are pleased with our progress to date, and your support has enabled us to expedite the process ahead of expectations. [What are we doing and why?] The next step for this effort is to put our ideas to work. We have decided that the best way to do this is through pilot testing of the new PSM system. This will allow us to closely monitor the system itself and make any adjustments needed; it will also provide a wealth of information we can use as we install the system throughout all division facilities. [Where will it happen?] We have selected the Marwood plant as the test site, in consultation with Facility Manager Ray Leonard, who will play a key role in overseeing the installation. All Marwood employees will participate, either directly or indirectly, and we will actively solicit their feedback about the system based on their experience with it. [Duration and expectations] The PSM pilot test will begin in three weeks, on May 15; we expect to maintain it for six to eight weeks to ensure that we get full benefit of this exercise. At the end of this period, the Facility Managers' Council will review what has been learned, recommend any changes needed, and report our findings to senior management. [Next steps] In the coming weeks, we will provide occasional updates on the pilot test, to make sure all of you are fully informed. We invite your comments and suggestions. Many thanks for your continuing support.

FIGURE 7-1. Summary of PSM Pilot Test Goals and Parameters

In addition, you may also want to revisit some of the flowcharts and other documentation you developed during systems design (Chapter 6). • Training. Pilot participants must be properly trained; otherwise the results of the pilot can be very misleading. Don't assume that you can defer training until later or that it doesn't pay to invest in training just to do a pilot.

Following is a sample description of roles and responsibilities circulated with regard to a division's PSM pilot test. To: From: cc:

All Facility Managers, Pilot Site Employees PSM Task Force Corporate Safety Director GM-EHS

As we move closer to beginning our PSM pilot test at Marwood, we thought it would be useful to provide this outline of roles and responsibilities. Facility Manager Ray Leonard is the task force's primary contact for the test. Ray is now assisting us with designing the pilot, and will be responsible for all communications, administration, and other management functions associated with its installation. He will provide weekly progress reports, and will be a strong contributor to the system review and refinement process once the test is complete. Facility Safety Manager Andy Zahner is responsible for overseeing all aspects of PSM training in connection with the pilot. Andy will report to Ray. The PSM Task Force will oversee the pilot throughout its duration, monitor its progress, and develop recommendations for improvement. Individual task force members will actively participate in the pilot test, to support Ray's managerial responsibilities and to provide specific input as needed. The Task Force reports to the division's Vice President—Environmental, Health, and Safety. Company X's Corporate Safety Director, who has acted as a consultant to the Task Force, will continue as an advisor during the pilot test. As the company's PSM champion, he will be actively involved in the monitoring, reviewing, and recommendations phases. The Safety Director reports to Company X's General Manager—Environmental, Health, and Safety. In addition to these specific responsibilities, we want to emphasize that Marwood employees' participation will be critical to the success of the PSM pilot test, and to the company's PSM initiative as a whole. It is you who will determine the value of our work so far, and your cooperation and input are very much appreciated.

FIGURE 7-2. Pilot Test Roles and Responsibilities

• Developing mechanisms for soliciting feedback. Pilot participants' feedback and input are crucial not only for the test itself, but, more important, to enable the PSM team to refine the system for full implementation. Experience shows that the more quality feedback you receive, the more responsive you can be to customer requirements. The way you solicit

feedback may depend on your company's style and available resources; among the more common methods are: —Questionnaires (for an example, see Figure 7-3) —Suggestion boxes —Regular debriefing meetings with site managers —Group meetings with site employees Regardless of the method(s) you select, it's important to get feedback from the full spectrum of people affected by the pilot. No matter how " tuned in" facility managers may be, they may lack the day-to-day perspective you need Following is a questionnaire format developed by a divisional PSM Task Force to elicit feedback from a plant's employees about the PSM pilot test. The Task Force designed it to be adaptable to a range of activities and plans to use it at the conclusion of each one. At the request of the plant manager, responses are sent directly to the Task Force rather than directed to him. To: From:

All Participants Ray Leonard, Marwood Facility Manager

To make the most of our participation in the PSM pilot test, the PSM Task Force needs your help. One of the main reasons we are conducting this test is to make sure our new system for managing process safety is practical and that it gives each of us what we need to do our jobs safely and effectively. We can't do this without your input. That's why the pilot test plan calls for getting your feedback on a continuing basis, and one of the ways we'll be asking for it is through questionnaires like this one. 1) Do you understand the PSM system and the tasks it requires? 2) Do you think it makes sense? 3) Does it apply to your job? How? 4) Do you understand what's required of you? 5) How do you think it will change the way you do your job? 6) Does the information you have received meet your needs? 7) What suggestions do you have for making it better? 8) How would you change the PSM system to improve it? We will be asking these and other questions at key points during the pilot test, such as the completion of specific activities like PSM training. Your responses will be kept confidential and you will forward them directly to the Task Force. What's important is your honest assessment of whether the PSM system works, and your suggestions for making it better. Many thanks for your help.

FIGURE 7-3. Sample Pilot Task Feedback Questionnaire

to make meaningful adjustments. Frequency depends on the scope and duration of the pilot test, as well as your own sense of the local environment. Ideally, you want to get as much information as possible without unduly intruding or creating significant additional paperwork. Hint: Remember that in soliciting feedback you have the opportunity to open dialogue with facility personnel about PSM and the new systems. Be sure to let participants know that their input is valuable and their suggestions are appreciated. If you find that comments tend to cluster on specific concerns, consider addressing them directly during the test rather than waiting until completion. This may help encourage feedback by demonstrating that it is being heard and understood.

• Monitoring progress. The feedback mechanisms you develop will do double duty by providing you with a means of monitoring progress. For example, if trainees complete a brief questionnaire after every operator training session, you can gain a quick assessment of your effectiveness, while helping you maintain records of training provided. Supplement these with some other monitoring techniques to assure a balanced perspective and to fully assess performance. There are many ways to monitor effectiveness (see Chapter 8 for a detailed discussion). You may find it most useful to consider several key indicators, such as: —Compliance. Compare achievement in specific PSM elements against previous audit findings for the site. This helps indicate the effectiveness of the management system. For example, if previous audits found that preventive maintenance was not kept up to date on pressure relief systems, has the system weakness (or absence) that allowed this to occur been corrected? —!Process improvements. Measure progress against previously identified goals. For example, if completing capital project safety reviews within two weeks of submittal was a facility's objective, is this now being achieved? •-Resource requirements. Maintain careful records of staff time and other costs involved in using the system for comparison with resource requirements projections. If certain aspects of the pilot test require more time than you had anticipated, does this suggest that the system can be further streamlined? If less time is needed, does this mean the system isn't getting proper attention? —Schedule. Compare progress to date with timelines established in the implementation plan.

• Reporting progress. Many people within your company will be interested in the progress of the PSM pilot test. Those with a specific need to know include senior management, the test-site facility manager, and the PSM sponsor; they will almost certainly require regular, detailed updates from you and the PSM team. The scope and frequency of your reporting depend on your company's preferred style as well as the pattern you have established at the outset of the PSM initiative. It's reasonable to expect that you will need to generate interim reports on the pilot test. Such reports would logically include discussion of progress to date, organized to include the key indicators you have been monitoring. In addition, you may wish to include other topics, such as: • • • •

Significant deviations from the PSM implementation plan Nature and extent of feedback received Implications for companywide installation Unexpected developments (positive or negative)

A sample interim report appears as Figure 7-4. Hint: Interim reports document the installation process and provide a way to flag opportunities and problems to management's attention in a timely manner, which helps avoid surprises. At the same time, be careful that your interim reports are precisely that; don't try to second-guess final reports, or extrapolate from local findings prematurely.

In addition to those to whom you must report, others at your company may have keen interest (or even anxiety); for example, facility managers and employees at other locations may wonder about the progress of the test, and when their turn will come. Even though you are probably not required to report formally to them, you should consider keeping them informed. If you have established a PSM communications effort (as discussed in Chapter 2), consider giving special attention to the pilot test and highlighting facility progress. If not, you might consider other means, such as circulating interim reports (or summaries) to facility managers, to assure that employees are kept informed. Figure 7-5 shows a sample of such a report. Hint: Never underestimate the power of the grapevine. Facility-based personnel (at every level) talk to their counterparts at other sites, and both news and opinions about the pilot test will almost certainly be a topic. This suggests that it's wise to pay close attention to how the test is received locally since this can affect smooth installation elsewhere.

This sample interim report on one division's PSM pilot test displays a format for monthly update memos. To: From: Re: cc\

Corporate Safety Director PSM Pilot Test Task Force Monthly PSM pilot test report: Month #2 Plant Manager—Marwood

Major Activities 1) Second shift training begun 2) Changes to documentation procedures finalized 3) Employee feedback reviewed 4) Resource requirements re-estimated 5) Management of change element nearing completion Unexpected Developments A systems crash in the Safety office destroyed work in progress, requiring that much of our data concerning process hazards analysis findings will need to be reconstructed. An unannounced visit from a major supplier coincided with a group training session, which gave the Plant Manager the opportunity to brief him on the division's work in PSM. Variances from Plan Training is still somewhat behind schedule, because "train the trainer" activities took longer to get right than we had expected. Now that the model has been corrected and staff scheduling has improved, we expect to complete training close to original timetable. Documentation procedures have proven more "user-friendly" than we had anticipated and have been well received by Marwood users. This has enabled us to install these changes ahead of schedule and with less demand on staff than called for in the plan. Significant Feedback Marwood employees, on the whole, continue to be helpful and cooperative, despite some initial pockets of resistance. Employee feedback confirms that the confusion reported at the outset had more to do with our communications skills than the substance of the PSM system. Even though "train the trainer" had some early glitches, this concept has proven very popular with Marwood personnel; a number of questionnaires single this out as a program they would like to see replicated in other areas. Notes for Future Reference 1) Spend more time designing training before providing it. 2) Look for additional ways to involve local employees. 3) Use project management software to organize work schedules. 4) Make sure to use clear language in introducing the PSM system locally—we tend to forget that to newcomers it may seem very complex. FIGURE 7-4. Sample PSM Pilot Test Interim Report to Management

This sample demonstrates a format for periodic updates to all facility managers and safety directors. Note that an actual memo of this type might usefully include more operational detail. To: From: cc:

Facility Managers and Safety Directors PSM Task Force Division VP—EHS, Corporate Safety Director

As the PSM pilot test at Marwood ends its second week, we thought you would be interested in the following summary of progress so far. Marwood's facility manager and his team have done a great job of keeping the pilot on track and all of us can learn from his experience. Launch. We initiated the pilot on schedule on May 15 with a series of group orientation meetings with all three shifts at Marwood. Members of the Task Force, plus the facility manager, conducted these meetings, where we explained the PSM system, discussed the pilot test, and outlined expectations of Marwood personnel. Focus. The Marwood pilot emphasizes PSM's Management of Change element for two reasons: 1) this element is fairly complex, which means the pilot will properly exercise the new system, and 2) the facility manager had identified MOC as a priority for review and improvement. Activities to date have included: 1) Starting up a "train the trainer" program to enable selected Marwood personnel to provide PSM training; so far one shift has received training, with the second coming on line next week. 2) Establishing employee feedback systems, to get users' input about the PSM system. This seems to be working well so far; at the facility manager's request, feedback comes directly to the Task Force to encourage candor. 3) Revising some of Marwood's documentation procedures to conform to the new system. So far, this has progressed a little ahead of schedule. 4) Frequent interaction between the facility manager and the Task Force to focus on progress and problems. Lessons Learned. It's very early in the game to make predictions about what changes may be needed as a result of the Marwood test. However, there are already some useful insights that the Task Force expects to factor into the PSM installation plan for the division. These include: 1) We need to be very clear in introducing PSM to our employees, and take time to answer their questions. Orientation meetings should be at least 90 minutes, not the one hour we had scheduled. 2) Getting valid feedback takes some effort; personnel need to know we mean it when we say we want constructive criticism. 3) Close collaboration between the Task Force and the facility manager is absolutely vital. Next Steps. In the coming weeks, the pilot will continue to focus on Management of Change as a priority and begin installation of systems for Process Hazards Analysis. Training should be completed within the next 14 days. The Task Force will continue to keep you advised of progress at Marwood; in addition, we ask that if you have questions, comments, or suggestions that you think would be useful, you'll pass them along to us for consideration. FIGURE 7-5. Sample PSM Pilot Test Interim Report to Facility Managers

• Organizingresults. Continuous monitoring improves your ability to assess final results by providing early indications of strengths and weaknesses. In addition, the methods you adopt for gathering information help you stay organized, so that you're not faced with a room full of raw data once the pilot test is complete. One way to organize results is to use the indicators you selected for monitoring and mesh them against the PSM system features the pilot has tested. While not every indicator may apply to every system, this exercise should help isolate areas that warrant particular attention. Hint: Assembling the pilot test results can be assigned to one or two PSM team members, rather than needing the full group'participation. Consider holding a debriefing with the facility manager to assure that you have anecdotal as well as quantitative information.

7.1.4 Assessing Pilot Test Results Once results are organized, the assessment can begin. At this point, it's wise to involve the full PSM team; you may wish to consider distributing pilot test results in advance of convening a plenary meeting. In this process, you will be looking both for areas that need improvement and for those where results exceed expectation. Most important, you will need to determine what the test results suggest about the PSM system as a whole, and devise solutions. As part of this process, you should explore the reasons for particular successes or failures; it's important to distinguish findings that apply to the system as a whole from those that may be unique to the pilot site itself. For example: you may show a breakdown in a given system requirement because: 1. staff did not understand what was required (suggesting the need for improved communication); 2. the facility experienced a work-stoppage that disrupted progress (in which case the finding is inconclusive and further testing maybe needed); 3. the system did not apply to facility processes or equipment (indicating a need for greater specificity); 4. the system didn't work when applied (indicating the need to redesign the system); 5. employees did not properly document their activities (suggesting that documentation requirements be stressed or improved); or 6. the system was ignored (indicating a local management problem and suggesting the need for improved communications and oversight).

The point here is that there may be any number of reasons for any given result. For this reason, in assessing results, the PSM team must ask why as well as what, since the answer will dictate how you refine the system. As you do so, take particular care to be impartial; more important than who may have made a mistake is figuring out how to improve the system so it won't recur. Hint: To the extent possible, involve local facility management and employees in the assessment process. If appropriate, discuss your preliminary findings with the facility manager before compiling a final report.

7.2 PLAN AND MANAGE INSTALLATION

7.2.1 Where to Begin Installation While you may wish to defer a firm decision about where, specifically, to start rolling out the system until the pilot test is completed, it's wise to consider a number of options as part of the planning process. The priorities you identified in Chapter 5 (both facilities and elements) provide useful guidance; similarly, the implementation strategy you have adopted (companywide, facility-specific, or hybrid) will affect these decisions. If you have chosen a companywide strategy, you may want to begin with priority facilities; another approach would involve launching the installation simultaneously throughout the company. If you're considering the latter, keep in mind that a companywide implementation strategy requires significant involvement of corporate staff. For facility-specific installation, it may make sense to start the installation process everywhere at once, paying particular attention to priority facilities. However, if your company is a decentralized one with many sites, you may wish to subdivide the installation by, for example, product lines or types of operations. In addition to these tangible factors, you should not overlook less tangible—but equally influential—considerations. Factors such as local management styles can create either barriers or opportunities that will affect the installation process, and should therefore be incorporated into your planning. If, for example, you believe there are pockets of resistance to the PSM initiative, you may—all things being equal—prefer to begin with the more receptive facilities where you have better assurance of success. In companies that tend to be consensus-driven, this gradual conversion proves highly effective. In others, with more autocratic traditions, it may make better sense to start with the tough ones in order to set an example.

As this example illustrates, there is no single right answer. The key determinant must be your judgment as to the most effective allocation of resources (time and energy) against the goal of improving overall safety performance. Hint: The shortest distance between A and B is not always a straight line. Keep in mind as you consider intangible factors that you must influence behavior in order to improve companywide safety performance. Achieving this may require a combination of skills and tactics, some of which may not be directly related to explicit PSM requirements.

Once you have determined where to start, you can begin to develop a schedule. However, it's prudent to wait until the pilot test is complete before firmly establishing your timetable, since the results may well affect your estimates. In setting the installation schedule, be sure to take into account variables such as: • • • •

the complexity of the facilities involved; the availability of local staff resources; the availability of corporate staff support; location and travel requirements.

In addition, make sure to build in sufficient time for monitoring (Chapter 8), as well as for administration (meetings, reporting, etc.) Also, consider building in specific milestones throughout the schedule; these interim deadlines, reflecting completion of key tasks, help keep the schedule on track. Hint: Keep in mind that the pilot test may have taken more time than a comparable facility would need for installation once the system has been refined. At the same time, take care not to be unrealistic; it's always better to beat a deadline than to miss it.

Other considerations to take into account in scheduling PSM installation include: • Opportunities for time- or cost-efficiencies. If several of your company's facilities are concentrated in a relatively small geographic area, it may make sense to focus on them as a group, particularly under a companywide approach. • Business and production cycles. Certain types of operations and facilities have predictable production cycles; for example, some facilities may have scheduled annual turnarounds or a seasonal production peak. You are likely to get better cooperation and results if you're able to schedule the installation during moderate periods rather than at peak times.

7.2.2 Who Should Manage Installation Leadership and direction for PSM roll-out depend on the implementation strategy you have selected (Chapter 5). For example, if your plan calls for a facility-specific approach, it makes sense to ask the facility manager to be responsible for managing the installation, with the PSM team acting as a resource base and monitor. On the other hand, a centralized (or companywide) approach indicates corporate or divisional management; under this plan, the company PSM champion or designate oversees installation, with input and support from local personnel. In a hybrid situation, local and corporate managers might co-direct the effort, or, as an alternative, decide among themselves who should take the lead. No matter which manager you choose, what's important is that he or she: • • • • • •

understands the role and what is required; has the knowledge and experience to do the job; commands the respect of local personnel and the PSM team; has the authority to commit resources, or the support of those who do; has continuing access to the PSM champion as needed; is recognized by the team and your company for his or her efforts.

Through your PSM work so far, you have undoubtedly identified likely candidates for managing the installation process, within the team itself or from among local managers. Regardless of whom you choose, you will greatly improve his or her effectiveness if you develop a written description of the manager's responsibilities, as well as those of the PSM team and relevant local personnel. Doing so will help improve: • • • •

clarity of roles; clarity of tasks; accountability; measurement of performance.

An example of such a job description appears as Figure 7-6.

7.3 SELLTHESYSTEM By now your PSM system has been developed, tested, and fine-tuned, and you have planned and scheduled its installation. Once more, it's time to sell. This time around, selling PSM should be easier—you have a tangible "product," with specific benefits. You also—based on the test pilot—should have some satisfied customers. Why is it necessary to sell PSM inside your company? Because PSM improvement requires individual as well as corporate commitment. Effective process safety management relies on individual behavior on the job, and

Schedule PSM roll-out. Develop communications to facility staff about PSM systems. Oversee training of facility staff on PSM systems. Monitor installation of PSM systems (schedule, budget). Monitor effectiveness of systems as installed (functionally). Define and issue initial system modifications during roll-out as required. Turn over PSM systems to line management. Consult weekly with PSM task force. Prepare monthly reports for company management. FIGURE 7-6. Example of Job Description for Managing PSM Pilot Test

behavior depends on influences like perceived value and benefit and an understanding of the consequences of nonperformance. 73.1 Describe System Benefits The PSM team has by now devoted considerable attention to the question of PSMbenefits. In Chapter 2, you defined these benefits in terms of the company as a whole, positioning PSM in general as a means of supporting corporate goals. These might include improving efficiency by consolidating a range of safety-related activities, reducing maintenance costs, or improving customer satisfaction. As part of developing the PSM implementation plan (Chapter 5), you and the team identified benefits unique to the approach you selected, using them to help win management's approval. For example, your plan may focus on priority elements because the assessment you conducted suggests that this method will yield the greatest overall improvement in safety performance. And, as part of the pilot test described in this chapter, you focused on facility-specific benefits to enlist the support of local management and staff. This experience will serve you well as you begin the installation process. Many of the activities and tasks will be very familiar, and rely on information you have already gathered. In particular, the pilot test will have yielded valuable tools for selling PSM; if properly conducted and documented, the test will have generated a range of ideas and materials that can serve as the core of your efforts. As a way to start, you may find it useful to assemble all of the documents the team has produced that discuss PSM benefits; use this as a springboard for brainstorming, asking such questions as:

• Were we right about this benefit? • Were we wrong? • Why? • What do we know now that we didn't then? • What other benefits have emerged since then? As with previous, similar exercises, encourage your team to be creative. Like any sound management system, your PSM system probably creates unexpected side benefits over and above those related specifically to safety performance. For example, the pilot test may have demonstrated that a new system, once installed, enabled the facility to reduce unplanned downtime with better planning and use of preventive maintenance. Or perhaps the pilot test process itself may have helped improve relations between the facility and corporate staff. Use this exercise to create a comprehensive, current inventory of the benefits that are unique to your PSM system. The next step is to describe these benefits in terms of the people you want on board. Think about each one in terms of the people whose support you need. These will probably fall into several categories, and it's important to distinguish them from one another, since, as in any sales situation, you must personalize benefits and make them relevant to the customer's interests. For example: senior management, facility managers, shift supervisors, and line personnel all have a role and an interest in PSM, but their perspectives are very different, reflecting the nature of their jobs. To help focus your thinking use a simple grid exercise (as shown in Figure 7-7) to translate the benefits you have identified into the interests of each of the interested groups. Through your work so far you will have gained a much clearer understanding of their various perspectives; in particular, the user feedback you received during the pilot test should be very helpful in making PSM benefits relevant. An exercise such as this can yield themes, or key messages, that you can use in selling the PSM system, in addition to focusing your thinking about your customers' needs.

7.3.2 Reinforce Buy-In from Management Management buy-in for the PSM system depends on how clearly executives understand how the system supports corporate goals and business strategies. It is your job to make these correlations, as you did in your initial selling (Chapter 2). The difference is that you now have more tangible information to support your case. If you have diligently kept senior management informed (either directly or through superiors) of your team's progress throughout the effort to date, your job at this point will be far easier. Management will have a solid baseline of

Consolidated safety activity

Reduced downtime

Improves image

Better performance

Fewer headaches

9

Minimizes redundancy

9

Improves local performance

Clarifies responsibility

Better guidance

Saves money

Improves customer service

Improves productivity

Improves morale

Fewer layoffs

Operators

Limits liability

Shift Supervisors

Plant Managers

Compliance

Sales/ Marketing

Benefit

Senior Management

Following is a grid devised by a PSM team to identify PSM benefits in terms of customers' needs.

FIGURE 7-7. Example of PSM Customer Benefits Grid

knowledge, both about your efforts and about PSM itself; this means that whaf s required now is a "refresher" session, rather than starting over. The completion of the PSM pilot test presents an ideal opportunity to reinforce management's buy-in by providing a specific focus for discussion. Consider scheduling a briefing that includes the same group whose endorsement you initially sought in Chapter 2. Such a briefing might include the following topics: • Introduction. Briefly revisit the rationale forestablishingthePSMinitiative in your company, highlighting its relevance to corporate goals. • Progress report. Where we are today, compared with initial estimates and detailed plan. Use your original presentation (Chapter 2) and the implementation plan (Chapter 5) for comparison purposes, focusing on tasks, timetables, and resource requirements (projected vs. revised vs. actual). • What we have learned. Discussion of variances (positive and negative) from plans. Detailed report on PSM pilot test: strengths, weaknesses, implications, how the PSM system has been refined based on experience. (Note: be prepared to justify any increase in resource requirements or any significant slippage in timetable.) Include discussion of local feedback— mechanisms and content—and acknowledge the contribution and cooperation of facility management and staff.

• What we have done. Outline installation roll-out plan: schedule, responsibilities, milestones. • What we need now. Discuss need for visible senior management support to assist in winning employee buy-in. Outline plans for communicating the PSM system as part of installation, emphasizing the need for management's input and endorsement. • Conclusion. Summary of benefits derived to date and those anticipated. Formal acknowledgment of senior management's role in making the effort to date a success. Reiterate the team's commitment to seeing the initiative through completion of the installation. Hint: As with previous presentations to senior executives, consider involving the entire PSM team. This tangibly recognizes their contribution while reinforcing the team-oriented nature of the effort. Hint: An outline such as this can be easily adapted to your company's style, as with other presentations discussed in these Guidelines. It's a good idea to involve your PSM sponsor in advance, since the sponsor has a significant investment in your success. Hint: Once you have won top-level endorsement, dont be shy about using it—but be judicious. Concentrate on creating and maintaining a positive climate, not one that conveys a heavy-handed, top-down mandate. Instead, emphasize the participatory, collaborative approach that your company has adopted.

7.3.3 Reinforce Buy-In from Participants Starting from the Top Management approval and buy-in translates into many forms. Internal publicity is second only to continuing resource allocation in its value to your efforts. Effective ways of using management buy-in include: • • • •

articles in company publications, by-lined by a senior executive; executive communications, such as employee letters; executive participation in media interviews: general, trade, and technical; publicity in support of management participation in industry, business, or technical conferences concerning PSM.

Communications methods such as these send a positive message, conveying management enthusiasm for the PSM initiative and pride in your company^ accomplishments. Gaining Broad Support As every experienced manager knows, for systems to work, they must be "ours;" they are endorsed, or "owned," by the people who use them. In fact, virtually every management system—PSM included—is effective in direct proportion to the degree of this sense of ownership or investment. Since the PSM system will affect so many people in your company, it's important that you make the effort to gain their understanding and support. For these reasons, in addition to executive communications, you should consider the advantages of other internal communications methods to gain participants' buy-in. The installation process presents a natural opportunity; in fact, employee communications should be a priority as you begin the roll-out. Hint: In addition to the activities described here, don't forget that training (discussed in Section 7.4) has a significant communications component. The goal of both is to convey information in a way that influences behavior. Sound communications can help lay the groundwork for effective training and subsequent performance.

The specific internal communications methods you use will depend on your company's culture and resources. You may find it useful to revisit the discussion provided in Section 2.3.2 (page 28), which covers some general principles of effective communications that apply here as well. Whaf s different is that now you are: • • • •

working with specific information requesting specific support (i.e., participation) able to answer specific questions familiar with specific benefits—and disadvantages

This means that while the process you undertake will be essentially the same as that discussed in Chapter 2, the results will be far more focused. If you have maintained internal communications about PSM up until now, more specific information will represent a natural evolution. The degree of that specificity depends on the number of sites and processes involved, as well as what resources are available to you. You should in any case consider internal communications in two distinct but related forms: broad information applicable companywide, and information specific to a given

facility. Companywide communications create the background, and facilityspecific information fills in the details. Taken together, they answer the question, " What does our company's PSM system mean for me?" The techniques described in Chapter 2 apply equally to the challenge of conveying information about the PSM system throughout your company. The same vehicles you used to publicize general PSM concepts can be used to advantage in presenting details of the system the team has designed; these include: • • • • •

employee letters newsletters and other publications electronic mail bulletin boards information packets for facility managers

Consider supplementing these relatively static media with in-person presentations—especially as you undertake facility-specific communications. In some companies, it maybe feasible to develop a core presentation that a number of PSM advocates—the PSM team, for example—can use to provide an overview and introduction to the PSM system. This helps bring your company's PSM system out of the ivory tower (or research lab) and into the field; in addition, it helps encourage dialogue with participants—present and future. Hint: You will greatly enhance the effectiveness of any communications medium if you are able to incorporate favorable anecdotes from participants in the pilot test. First-person accounts of positive experience lend considerable credibility, and you may wish to consider recruiting the test-site facility manager (or other personnel) to assist the team. Hint: If you developed a presentation for management, as described in the previous section, you will probably find that much of it can be adapted for use at the facility level. Just be careful to refine discussion of benefits to reflect your audience's interests and information needs.

If you decide to conduct orientation sessions such as these, be sure the presenters are prepared to: • • • •

encourage dialogue; answer questions candidly, especially the tough ones; maintain a record of questions and concerns; and follow up on them.

Hint: If you present to unionized facilities, consider briefing union representatives in advance to gain a sense of any questions or issues they might raise and address them as thoroughly as you can. Also, it is important that they attend the presentation.

7.4 DESIGN AND PROVIDE TRAINING No system as complex as PSM can be installed without sufficient training for the people expected to use it and abide by it." Sufficient" in this context means that PSM system training should: • • • • •

recognize and address a range of needs; provide specific, detailed information; support principles of continuous improvement; incorporate measurements of effectiveness; and encourage compliance with the intent as well as the letter of the PSM system.

As these criteria imply, the goal of PSM system training is to assure that everyone whose job requires interacting with the system receives the tools he or she needs to do that job properly—and understands and uses them. Emphasis is added to reinforce the concept that training programs (of any kind) are only as effective as they are understood and put into practice. Many programs fall short of their potential because the people designing them rely solely on their expert knowledge of the topic, overlooking or underestimating the need to understand—in equal depth—their trainees. Just as you tailored the PSM system benefits you identified to different interests, your training curriculum should apply PSM system procedures to specific job requirements. This begins with understanding how each trainee category will interact with the system, and then gaining a sense of current skills and knowledge levels in the applicable categories. This does not have to be an exact measurement; you need, rather, a general—but objective—idea, which you have probably gained through your work to date. Hint: Note that in many companies levels of skill and knowledge may vary widely, even in the same facility. Since it's unrealistic to tailor training precisely to every level, a good rule of thumb is to aim for the lowest common denominator.

While you may group trainees in any of a number of ways, consider at least four broad categories: managers, trainers, employees, and others—for example, contractors. The following discussion focuses on the training needs of each of these trainee groups and some of the techniques you may want to consider for addressing them.

7.4.1 Training Managers Managers are those responsible for seeing to it that the PSM system is put into practice; their interaction with the system is primarily supervisory. For example, while managers may not personally prepare process documentation or equipment change reviews, they will direct and monitor these tasks. In this capacity, they will need a sound understanding of the system itself and its requirements. They also need training to help them perform the oversight function, to assure that they can provide guidance, answer questions, and monitor performance. Your PSM system defines a range of responsibilities for company managers, depending on which components they oversee. One way to approach training for managers involves developing two core modules, or training blocks, that can be adapted to various situations. These modules would focus on: • Training in the system. Your company's managers must be both competent and confident in terms of their ability to explain—and enforce—the PSM system. For this reason you should consider training that covers the entire PSM system, rather than just those aspects of it for which a given manager has direct responsibility. This approach may also be far more cost-effective, in that a single core module can apply to virtually every company manager. • Training in the tasks. In addition to understanding the overall PSM system and how it works, certain managers need "user training" to cover those activities that are specific to a given system component. For example, to correct a gap in operator training, a manager may need detailed information as to how best to go about designing or contracting for a training program, and guidance for monitoring its effectiveness. Under this modular approach, all managers would receive the same training for core functions, plus additional training that focuses on their responsibilities for specific activities. Structuring manager training this way may help you avoid redundancy, while addressing the full range of managers7 needs.

7.4.2 Training Trainers "Train the trainer" programs are among the most efficient and cost-effective ways to provide training for large numbers of employees. While the front-end

cost of development can be high, a properly designed program should hold up for some time and should be appropriate for multiple uses. Moreover, involving your own employees (whether managerial or otherwise) in training not only can save money but also helps promote the sense of ownership that effective management systems require. In addition, "trainer training" often carries other benefits that the in-house trainer can apply to his or her regular job and may provide opportunities for professional advancement. In addition to understanding the PSM system and its implementation, in-hou$e trainers need skills development training to enable them to fulfill their roles effectively. Everyone has had the dismal experience of listening to speakers or teachers whose command of their subject may be excellent, but who are incapable of conveying it in a useful, much less interesting, manner. To help avoid this, be selective in recruiting in-house trainer candidates; the best people for this task have confidence, enthusiasm, and an ability to communicate well. "Train the trainer" programs provide the most intensive training experience. They usually involve developing a detailed core curriculum covering both the topic at hand (in this case, your company's PSM system) and communications skills. Many companies retain consultants to develop these curricula, produce all related documents (workbooks, reference manuals, videotapes, etc.), and present the initial sessions, which, depending on the subject, can run from 1 to 5 days. Others collaborate with outside firms, which may, for example, provide some training tools to supplement company materials, while the training itself may be conducted by in-house experts. Still others develop and conduct all program components in-house. Regardless of who undertakes a " train the trainer" project at your company, keep a couple of criteria in mind: timeliness and shelf-life. Timeliness speaks to the need to develop the curriculum and get it out into the field as quickly as possible once the PSM system is finalized. Shelf-life refers to the usability of the program over time; it should be adaptable to accommodate changes or additions to the system to avoid the expense of a complete revision. 7.4.3 Training Users People whose jobs require direct interaction with the PSM system represent the largest single trainee category—and the most essential to improved PSM performance. At the same time, this category comprises a very wide range of different people with different skills, all affected in different ways by the system you have developed. Included here are shift supervisors, safety engineers, maintenance personnel, and operators, among others. How can you manage all of their training needs? Perhaps the simplest way to proceed is first to identify what aspects of your PSM system are universal. For example, everyone in the jobs mentioned above

must understand where management of change procedures apply as part of the PSM system. They can, therefore, receive the same training, which you can design as a module. Next, consider employees in categories that describe their interaction with the PSM system. For example, engineering staff (along with R&D and business unit staff) need to understand the requirements of the capital project review system. Training on these interactions can complement the "universal" modules. Hint: While not every employee will be interested in the PSM system as a whole, preferring to focus on individual tasks and requirements, it's a good idea to offer the opportunity to learn more. You may find that performance improves as people understand how what they are doing affects other parts of the system and business operations as a whole.

7.4.4 Training Others (e.g., Contractors) Like regular employees with similar jobs, contract personnel must understand and work with your company's PSM system—just as they do with other company management systems and procedures. Some companies, as a matter of policy, conduct contractor training in-house, requiring contract personnel to participate in the same programs as their employees. Others reverse this practice, requiring instead that contractors provide their own worker training; as a condition of doing business with these companies, contractors must verify that their personnel have received training that meets the company's standards. Regardless of the approach your company selects, what's important is the assurance that contract personnel, by whatever means, are as conversant as your own employees with those aspects of your PSM system with which they interact. For this reason, you may wish to consider meeting with your key contractors to discuss the system and how it may affect their personnel. As part of this discussion, you will want to review whatever training the contractor provides to determine if it meets your needs and is appropriate for the PSM system. If the system requires additional contractor training, you can then work out (either as a global policy or on a case-by-case basis) how best to provide it. If you decide to conduct contractor training in-house, apply the same curriculum you would use with your own employees. If the contractor provides the training, make sure you are confident that it meets the same standards as your own; you may also need to review contract language to assure that it properly reflects any adjustments in the contractor's obligations. In a situation that combines both approaches, use these suggestions case by case.

In addition to contract personnel, there are others who will interact with the PSM system to some extent. For example, regular suppliers and distributors may have occasion to influence process documentation and process equipment integrity programs. As a result, you may wish to consider providing some form of training or orientation about your PSM system to assure that they understand and comply with it. Note that expanding the initiative in this manner, which exceeds regulatory requirements, may also create the opportunity to strengthen these business relationships. 7.4.5 Training Methods and Tools As the discussion above suggests, there are many effective methods and techniques that you can apply to PSM system training. Often the most effective approach combines several, taking advantage of the strengths each offers. Another benefit of this approach is that it can help maintain participants7 interest level; no one can sustain attention to a talking head for any meaningful length of time. Some of the more common tools you may want to consider (along with some of their pros and cons) include: • Lecture. Useful for conveying highly concentrated information; can be static, particularly if the speaker lacks technique; can discourage dialogue and participant interaction. • Video. Very useful for enlivening lecture material, demonstrating specific tasks, or creating general interest. Costly to produce; difficult to update; does not allow for interaction. • Slides. Pluses are the same as for video, plus they can illustrate diagrams, charts, other still graphics. Less expensive and more versatile than video. Must be accompanied by a speaker. • Overheads. Same as slides; less expensive, less interesting to the viewer. • Role playing. Very effective for demonstrating management techniques, simulating system components, and stimulating interaction. Requires a competent facilitator; cannot be reproduced. • Printed materials (manuals, workbooks, etc.). Can convey comprehensive information; can be reviewed and consulted as often as necessary; can be easily reproduced. Not interactive; assumes participants willingness to read and ability to understand. • Group discussion. Highly effective for stimulating interaction, prompting questions, achievingbuy-in. Cannot be reproduced; requires a competent group leader to guide discussion. • Computer-based training. Can range from very straightforward, task-oriented information to highly sophisticated, interactive, real-time training. Capital requirements may be high, depending on your company's existing computer systems and employees' levels of computer literacy.

Similarly, there are a number of different ways you can provide training, including: • On-sitegroups. Assembling groups of employees for training at the workplace can help accommodate multiple shifts. In addition, group training on-site can be incremental—that is, for example, one session a week for 6 weeks—rather than requiring large blocks of time away from work. • Off-site groups. Off-site training provides a concentrated focus and eliminates distractions. In addition, off-site meetings can often help promote a sense of teamwork among participants. • On-the-job. Learning on the job has the advantage of being very tangible; lessons learned on the job tend to be retained. The downside can include lack of continuity and followthrough, as well as potential problems with consistency. No single one of these methods or tools provides an all-purpose answer to training needs; however, all of them have something to offer. You will probably find that a combination of several (or even all) of them will achieve your goals.

CONCLUSION Remember that installing your PSM system will not happen overnight, and it probably won't happen perfectly. Try not to become impatient; your hard work will pay off if you encourage feedback and recognize the need for continuous reinforcement—at all levels—of the importance of safety improvement.

8 MEASURE AND MONITOR INSTALLATION 8.1 INTRODUCTION By the time you have successfully tested and refined your new PSM systems and installation is underway (Chapter 7), you and your team have passed a significant milestone. Congratulations are in order—but there is still more to be done. The good news is that at this point most of the effort shifts from the PSM team to your company's facilities. As a result, your role will change from directing a project to monitoring its local implementation. During the PSM installation phase activity will be spread widely throughout your company. Whether you have chosen a centralized or a decentralized approach for PSM design and development, installation must occur at the facility level. If s important to keep in mind that individual plants will be the ultimate owners and operators of the PSM systems at their sites, and they must assume responsibility during installation. However, there is still a need during this stage to maintain an overview of progress and to assure that you are meeting the objectives of the original PSM plan. Measuring and monitoring PSM installation helps assure consistency and quality control; in addition, effective monitoring helps keep local expenditures and schedules on track. In effect, these activities protect the investment you, your team, and your company have made in the course of your work so far, and for this reason they warrant continuing attention.

8.2 MONITORINSTALLATION As part of planning your company's PSM system roll-out (Chapter 7), you have established a number of benchmarks and parameters for the installation process. For example, pilot testing should yield realistic estimates for individual facilities' schedule, staffing, and other resource requirements, as well as workable formats for reporting. The installation plan you developed should derive from these results, adapting them to the full range of your company's operations. This experience—and the plans you developed from it—helps create a framework for monitoring the installation process. This process comprises two primary components:

• plant-level monitoring, which provides individual facility managers with information about local progress; and • companywide monitoring, which tracks PSM installation against your company's overall objectives and plan. These two components, both of which are discussed below, share a number of common elements and can be organized to minimize duplication of effort. Taken together, companywide and plant-level monitoring should assure that, at any given time, both local and corporate managers have sufficient information to enable them to: • • • •

quickly understand installation status; recognize and understand significant variances from plan; initiate and/or approve remedial intervention as needed; and endorse and promote success.

Hint: Remember that your goal in monitoring PSM installation is affirmative, not punitive. "Catching" individuals who fall behind or run into problems is far less important than detecting problems—and being able to resolve them— before they escalate, and potentially jeopardize the program's success.

8.2.1 Plant-Level Monitoring Each location that is installing a PSM system needs to monitor its own progress. As part of installation planning, each location will have made commitments to a PSM implementation schedule and plant managers will need to know how their facilities are progressing. The PSM program plans (see Chapter 5) and the installation schedule (see Chapter 7) provide a framework against which facilities can monitor their progress. These plans include schedules and budgets, which facility managers can use to track actual progress and resource utilization. In considering facility-level monitoring, you may find it useful to revisit some of the formats used for these kinds of comparisons, which appear in Chapter 5. In addition to strictly quantitative measures (e.g., dollars and time), plants managers' information requirements about PSM installation will very likely include specific status reports and problem identification. The information likely to be needed includes: • new installation activity since the previous report (including program adaptation, training, pilot operation, and final "commissioning7') • anticipated activity in the next reporting period • problems encountered during the reporting period • status of costs incurred versus budget • anticipated changes to the current installation schedule

Depending on the size of the facility and its management style, such reporting may be written or provided as an oral update, e.g., at the plant manager's weekly staff meeting. Figure 8-1 shows a completed example of a written monthly status report. Regardless of what format is used, reporting within a location should allow plant management to correct problems (e.g., schedule slippage) locally before they have to be reported up the line. 8.2.2 Company wide Monitoring Monitoring the installation of new PSM systems throughout your company requires you to gather information, analyze it, and report progress for the duration of the installation phase. Regardless of the design approach you have selected (e.g., centralized vs. decentralized), effective installation happens at the operating location level and must be monitored by some oversight team or function. Your company's PSM team is uniquely qualified to take on this role; by virtue of your work so far you and your teammates have probably become your company's resident experts in PSM. At least as important during this phase, you also have developed a clear understanding of whaf s required for successful installation and ongoing implementation.

PSM Installation Status Report for Woodlawn Plant: March, 1994 1) New Activity Training for all plant personnel on the new Management of Change procedure was completed and the procedure became mandatory. 2) Anticipated Activity The process documentation system description will be completed. 3) Problems Encountered None 4) Key Personnel Changes None 5) Budget Status Costs incurred to date are 5% above budget due to the need for extra training sessions. 6) Anticipated Schedule Changes A plant shutdown has been scheduled for the week of May 16. We are evaluating the impact of this shutdown on our schedule. FIGURE 8-1. Example of a Monthly Status Report Used Within a Facility

Hint: If your company has an internal EHS audit group or function, consider enlisting its support, either to help you devise a monitoring protocol, and/or to assist with data collection and analysis.

Data Collection Gathering information on the status of program installation can take any of several forms; more important than the form is the content of the data you solicit and receive. Depending on your company's needs and customs, you can compile the necessary information by requesting regular (e.g., quarterly or semiannual) status reports from each installing location, through periodic visits by the PSM team to those sites, or by combining both of these approaches. Site visits require a greater resource commitment, which may mean less frequent monitoring. However, occasional site visits allow you to see first-hand how installation is proceeding, and to gather qualitative, impressionistic information that written status reports often fail to capture. Hint: Reports should be kept brief and as easy as possible for users to submit This will minimize the chance that the need to prepare reports ends up robbing significant resources from the PSM implementation itself. For example, if your company routinely uses electronic mail for communication, it can be helpful to accept reports in that way. Hint: In considering on-site monitoring, you may wish to revisit the priorities you defined in Chapter 5. If resources are limited, consider assigning priority for in-person monitoring to facilities you have identified—through ranking exercises—as having the greatest need for improvement in terms of risk and/or current PSM status.

• Written reports. If you decide to request formal status reporting, you should specify the format to be used and the information you expect from each location. Reports should be kept brief, and should address progress at an overview level. Figure 8-2 shows an example of a quarterly progress report. Hint: Shorter status reports that are required with greater frequency tend to be more effective than longer, less frequent reports in helping to maintain continuing momentum. The need to show progress (for example) every month tends to keep PSM installation in focus, while a quarterly submission would permit more sporadic attention to PSM installation.

PSM Implementation Status Summary as of 3/31/93

Actual

Planned

Actual

Percent of Budget Expended

Planned

Percent of Effort Complete

45

40

45

55

15

15

20

18

Management of Change

20

10

20

10

Project Safety Review

10

20

10

12

Training

20

20

30

30

Element Process documentation PHA

FIGURE 8-2. Example of Quarterly Status Report

• Site Visits. In-person data gathering enables you to learn far more than written status reports can convey by themselves. On-site visits allow you to speak with users and judge the degree of acceptance of new PSM systems. You can also assess system users7 understanding to make judgments about the effectiveness of training programs. Your objective evaluation of a facility's PSM installation can be very helpful, both to the individual site's management and workforce and to the company as a whole. Not only are you likely to have the benefit of being able to compare against other locations' programs in making judgments, but you are also less involved in the location's program than local staff are likely to be. Your independent review can provide insights that may not be apparent to those who work with the program on a daily basis. If you decide to collect information through on-site visits, it's useful to begin with a written interview format to help ensure that you collect the information you need. Using such a format also enables you to gather information consistently from location to location; in addition, it improves continuity, especially if more than one person will be conducting the interviews.

Data Collection Guide for PSM Installation 1) What is being worked on? 2) Who is involved? 3) How has management and supervision at all levels demonstrated commitment to the PSM program? 4) Are promised resources being made available? 5) Do personnel at all levels understand PSM? 6) What barriers exist to PSM installation? 7) Are installed systems consistent with the company's goals? FIGURE 8-3. Example On-Site Review Interview Format

An example of an on-site review interview format appears as Figure 8-3. A format such as this helps assure that all key issues are covered but leaves the interviewer with discretion on how to proceed in obtaining answers to the questions. When planning an on-site review, work to be sure that your visit will not be too disruptive. You do not want your visit to distract people from system installation and become the cause of a delay, so try to keep your visit brief. You should not need more than a day at a time on site, and should only do on-site reviews infrequently. Hint: PSM must be a cooperative effort to succeed. Be sure to share your observations with local staff responsible for PSM installation. In addition, look for legitimate opportunities to flag superior performance (effort and results) in your regular reporting about facilities'progress.

Analyzing Findings Analysis of the results you gather should include two dimensions: facilityspecific and companywide. As you review each facility's data, you will be gauging its performance against specific measures such as schedule and resource requirements. Companywide, the team should be looking not only for these measurements against the overall plan, but also for trends and common findings that may indicate systemic problems. If you have used a consistent format for collecting information, you and your team should find it relatively simple to organize and assess your findings. In many cases, the value added by analysis takes the form of probing the

reasons behind individual successes or failures. Very often, the "why" is at least as important as the "what," especially when patterns emerge through comparing results from multiple facilities. Understanding why a given step or task in the installation process may prove more difficult than anticipated can shed light on the solution, suggesting measures for correction. For example, if documentation of process change consistently creates a roadblock for installation, you may want to reconsider (a) the training provided to staff, (b) the clarity of the instructions developed for the facility manager, (c) the documentation procedures themselves, (d) the quality of local oversight, or (e) some other source of the delays. Analysis of results helps to anticipate facility and corporate managers' concerns, enabling you not only to report progress but to propose useful solutions to problems you identify through the monitoring process. Reporting Data Periodic reports to higher management help keep them informed of progress during the PSM installation, while maintaining their awareness of process safety management in general. Regular reporting also provides you with an opportunity to enlist help in addressing any problems that may arise during installation. For example, if priority conflicts (such as an unexpected customer demand) are slowing installation of PSM systems at a particular site, your reports can provide the means of raising the issue to a level of management that's empowered to intervene. Your reporting to senior management should be concise. In many organizations, senior management prefers "exception" reporting, which focuses solely on actual and potential problems or variances from plan. In other organizations, senior management expects reports that provide a brief status overview. As with other PSM reporting tasks, the most effective method is the one that meets your management's needs and expectations; when in doubt, ask recipients what kind of report they will want to see. Figures 8-4 and 8-5 provide PSM Installation Report: First Quarter, 1994 PSM installation is proceeding consistent with the approved project plan with the following exceptions: 1) At the Winston Plant, changes in the plant management staff have resulted in a delay. The schedule at this plant will be delayed for two months through project completion. 2) At the Highgate Plant, resources were diverted to assist with the start-up of the new unit. The plant expects to make up for the resulting delay during the next quarter. FIGURE 8-4. Example of an Exception Report to Management

PSM Installation Overview Report 1) Activity The Woodlawn Plant has completed installation of its Management of Change procedure, and the Kingston Plant is continuing to implement process hazard assessment. The assignment of a new plant manager to the Winston Plant has delayed their installation efforts by one month. 2) Plans Woodlawn is concentrating on its process documentation system, while Kingston continues to work on process hazard assessment. Winston and Highgate continue to work on Management of Change. 3) Problems Commissioning of a new unit at Highgate caused resources to be diverted from PSM installation. 4) Budget We are continuing to track within 10% of budget. FIGURE 8-5. Example of an Overview Report to Management

examples of an exception report and an overview report to senior management. These reports derive from input from individual installation sites, providing information in summary form. If your analysis of results suggests the need for intervention, or your team has devised a proposed solution to a problem you have identified, you may wish to include a "commentary" section at the end of your report. Alternatively, you may prefer to discuss these ideas informally with your PSM sponsor before committing them to a formal presentation. Either way, if s a good idea to be prepared to respond affirmatively to management questions.

8.3 "CUSTOMER FEEDBACK" AND FOLLOW-UP For a system to work effectively, users must accept it and contribute to its continuous improvement. For this reason you should consider obtaining "customer feedback" on a PSM system after it has been installed and has been operating for a short time. Such feedback, from anyone who interacts with the system by providing input, using information, or receiving reports, can greatly enhance the effectiveness of the new PSM system. System users may have important suggestions about how to improve or streamline a system, or may not clearly understand its importance or the part they play in its implementation. At the same time, soliciting—and acting on—user feedback helps underscore the collaborative nature of PSM and the fact that its success depends on the user.

The interviews conducted during on-site progress reviews provide one source of user feedback. However, it is likely that you will speak with only a small number of the people who interact with the PSM system. To acquire broader input, you should consider a formal user survey. Written surveys request feedback on the PSM system, asking about its clarity, ease of use, quality of training received on the system, perceived barriers to its effective use, perceived effectiveness in meeting objectives, and suggested modifications and improvements. These kinds of surveys typically mix open-ended and "yes/no" questions, and are distributed to all system users; they tend to be simple and brief to encourage participation. Figure 8-6 provides an example.

PSM User Feedback: Management of Change This survey is designed to help us improve our Process Safety Management systems. Please complete the survey and return it to the Safety Department. 1) Please circle the number that indicates whether or not you agree with each statement.

Strongly Strongly Disagree Agree 1 2 3 4 5

a) I've been adequately trained on the process change system b) The process change system is easy to use c) The process change system delays my work d) The process change system takes too much time e) The process change system will help prevent errors

1 1 1 1

2 2 2 2

3 3 3 3

4 4 4 4

2) Have you personally used the process change system? 3) What do you like best about the process change system? 4) What do you like least about the process change system? 5) Are there any specific changes to the process change system that you would suggest? 6) What department are you associated with? FIGURE 8-6. Example of a PSM System User Feedback Survey

5 5 5 5

Hint: The results of a user survey should not be used as a "pass/fair test of the system's success. Instead, consider the results as a way of helping to fine-tune the system. To make the most of this exercise, retain quantitative results for comparison against future surveys, to help measure progress in continuous improvement.

If you decide to conduct a PSM user survey, keep in mind that if s essential to provide feedback to respondents on the survey results and the action plans or system changes (if any) that result. If users see that their input has value and impact, they are more likely to develop the sense of ownership that will help determine the long-term success of the PSM system. Hint: Consider user surveys not only to monitor the PSM installation phase, but as a means of maintaining continuing dialogue with PSM "customers." Remember that PSM systems, if properly designed, will evolve over time and users are a valuable resource for ongoing reassessment and adjustment

The installation of a PSM system does not complete the system development; it begins the process of continuous improvement. All management systems can be improved over time. Even if a "perfect" system could be designed, changing business conditions, personnel, organizational structure, regulations, and technical knowledge require that PSM management systems evolve over time. PSM management systems should be regularly assessed to identify improvement opportunities. Assessment should be based on follow-up user feedback and on the results of PSM audits. User feedback should be obtained periodically, not just at the time of installation. As users gain familiarity with PSM systems, they may identify potential system breakdown points and improvement opportunities. In addition, evaluation of trends in the responses from survey to survey can help to identify areas needing improvement and measure your success in improving systems. Where user survey responses suggest an improvement opportunity, you should involve those users in defining the opportunity and in its analysis. The tools of Total Quality Management can be very useful in this effort. PSM audits should be conducted periodically to assess the effectiveness of the PSM systems. These audits review system design relative to existing conditions and evaluate the quality of system implementation. Deficiencies discovered in PSM audits may highlight a need for system improvement. PSM auditing is discussed in detail in the CCPS book, Guidelines for Auditing Process Safety Management Systems.

CONCLUSION With the beginning of PSM system installation, you should initiate a process of progress and performance monitoring that will last for the life of the PSM system. Initially, the focus of this effort is on monitoring the progress of installation, to ensure adherence to schedule and budget. Later, the focus shifts to monitoring user acceptance, and finally to monitoring system effectiveness. A strong monitoring process is important to achieving successful installation and for making the transition to operation and maintenance of the PSM system.

9 EXPANDING BEYOND INITIAL SCOPE 9.1 INTRODUCTION Once installation of your process safety management system is complete, you have many opportunities to leverage this effort in additional directions. PSM approaches can be used to improve management of process safety beyond the system's original scope: they can be effectively applied in other related environmental, health, and safety functions; in industries beyond chemical processing; and in geographic regions beyond your original target area.

9.2 EXPANDING BEYOND MINIMUM REQUIREMENTS In deciding on the scope for initial PSM implementation, many companies choose to limit the scope of their effort. This is often a realistic approach, since initial implementation can be complex even within a limited range of chemicals and processes. For example, initial implementation may be confined to those chemicals and processes covered by the OSHA process safety rule, which is limited to a specific list of chemicals and excludes processes that meet specific criteria. However, the OSHA regulation does not coverall materials and processes that may represent process risks. Expansion of PSM to cover other chemicals and processes can improve your overall safety management. PSM systems are useful in any chemical process plant, whether or not it handles high hazard materials. PSM embodies many concepts of sound plant operation, and the operational benefits of PSM (e.g., reduced downtime, improved quality) can help improve any operation. In a facility that has adopted PSM systems for some of its processes and chemicals, expansion of PSM may simply involve using the same management systems consistently throughout the plant. For a plant that has not adopted PSM in the initial round of design, development, and installation, expansion requires repeating the installation process described in Chapter 7. In such a case, your systems are already designed and the effort required is a continuation of the roll-out; a full pilot test should not be necessary. Another expansion of initial PSM installation is in implementing more demanding requirements. Your initial PSM design was derived from a "design basis" that included such considerations as a frequency for updating process

hazard assessments or for performing PSM audits. Once initial installation is complete, you may reconsider this design basis and modify the PSM system to provide even more stringent risk control.

93 INVOLVE OTHER ACTIVITIES Initial process safety management implementation usually focuses on your own production operations. However, there are a variety of related activities that benefit from similar approaches to safety. Both distribution and toll manufacturing may involve handling of hazardous materials, and management systems should be used to ensure safety. Production-support activities such as purchasing and research should be brought into PSM programs to integrate safety management thinking into the earliest possible stages of your company's activities. To expand process safety management to these activities, you should first identify how each PSM element relates to the new activity, as shown in Figure 9-1. You can then determine how the existing PSM systems must be modified. For example, you may find that most elements of PSM should be installed in R&D, so that pilot plant activities employ the same safety management systems as production. Where PSM is being extended to cover additional functions at a plant with installed PSM systems, the extension can be done at minimum cost. In such cases several staff-months of effort should suffice. If you apply PSM to an activity or location without existing PSM programs, the effort is greater. For example, installation of PSM at a terminal operation would require adaptation of existing systems to the nature and scope of the terminal operation, training of personnel, and roll-out of programs. The effort per employee involved in this will be similar to the effort involved in each plant's PSM roll-out.

9.4 INVOLVEOTHERFUNCTIONS Process safety management is based on the principle that appropriate management systems are needed in every area that has an impact on operational safety, from design through operation and maintenance to decommissioning. This same principle can be applied to other aspects of safety, health, and environmental control. Functions such as industrial hygiene (the protection of worker health against occupational hazards) and hazardous waste management involve the control of hazards arising from processes. As with process safety, you can attempt to use engineering-based solutions alone, but will find that ongoing control of hazards is difficult to achieve. Designing-in hazard control and

PSM Element

Applicability to Distribution

Accountability

Applies equally to distribution

Process documentation and knowledge

Documentation of hazards, equipment design, risk management decision, etc. applies

Capital project review and design procedures

Reviews of major equipment acquisition apply

Process risk management

Management of residual risk through hazard identification, risk assessment and reduction, emergency preparedness, and working with suppliers and customers (including carriers) apply

Management of change

Change reviews should apply to both equipment and procedures for material handling

Process and equipment integrity

Maintenance of storage equipment and distribution equipment applies

Human factors

Human factors considerations are very similar

Training and performance

Training needs are very similar

Incident investigation

Incident investigation needs are very similar

Standards, codes, and laws

Maintaining awareness of external requirements and development of internal standards can be applied to distribution

Audits and corrective actions

Audits of distribution safety management should be performed

Enhancement of process safety knowledge

Enhancement of distribution safety knowledge is an analogous need

FIGURE 9-1. Application of PSM Elements to Chemical Distribution Activities

managing changes helps assure that the desired outcomes (i.e., control of worker exposures or minimization of waste) are achieved. To adapt PSM systems to other functional areas, it helps to begin by listing the influence of each PSM element on the new functional area. Figure 9-2 shows an example of this comparison. Each PSM system can then be examined to determine what system modifications (if any) are needed to address the new issues. For example, the process hazard assessment system might be modified to include participation by industrial hygienists to identify potential sources of exposure. Some process safety management systems (e.g., process documentation) may require no modification to support a wider scope. The level of effort required to modify PSM systems in this way will be minor compared to the original effort required for system development and initial installation. Each PSM system can be reviewed with a few staff-days of effort and many modifications can be designed with a similar amount of effort.

9.5 EXPAND TO OTHER PROCESSES Process safety management has been applied primarily in the chemical process industries. However, the concepts of PSM, and the approaches used for implementing PSM, can be applied equally well to any manufacturing process that uses chemical products. Manufacturing industries as diverse as semiconductor manufacturing and food processing can, and do, apply PSM to improve safety and operations. The process described in this book for PSM implementation can be applied in any industry. The major difference you may encounter in applying PSM in other industries is that the availability of technical resources may vary. In implementing PSM where the required skills are not readily available, you will have to supplement these skills, either by using staff from other parts of your organization or by retaining outside consultants.

9.6 EXPAND INTERNATIONALLY When you have installed process safety management systems in your United States operations, you may want to think about expansion of the program to international sites. Conceptually, the idea that process safety must be enhanced through both engineering and management-based approaches applies regardless of location. Since major incidents adversely affect industries' operations and reputations regardless of where they occur, enhancing safety should be a priority everywhere. However, there are additional considerations in

PSM Element

Industrial Hygiene Program Impact

Accountability

Applies equally to industrial hygiene responsibilities

Process documentation and knowledge

As defined by CCPS guidelines, this element includes collection and retention of information important to industrial hygiene management

Capital project review and design procedures

Reviews should also include consideration of new or changed worker exposure potential

Process risk management

Industrial hygiene risks should be periodically reviewed as are process safety risks. Some of the process hazard assessment techniques used for PSM can be expanded to include consideration of industrial hygiene issues

Management of change

Change reviews should include consideration of changes to worker exposure that may result, and protection of workers implementing the change

Process and equipment integrity

Maintenance process and equipment integrity contributes to exposure control at the same time as it enhances process safety

Human factors

Human factors considerations can be expanded to include those of interest to industrial hygiene, such as repetitive motion

Training and performance

Training can be expanded to include coverage of industrial hygiene hazard awareness and protective measures

Incident investigation

Industrial hygiene exposure incidents and alleged work-related illness can be covered by an incident investigation program

Standards, codes, and laws

Maintaining awareness of external requirements and development of internal standards can be applied to industrial hygiene issues

Audits and corrective actions

Audits for industrial hygiene compliance can be performed concurrent with, or separately from, process safety management audits

Enhancement of process safety knowledge

Enhancement of industrial hygiene knowledge is an analogous need

FIGURE 9-2. Comparison of PSM Elements with Industrial Hygiene Management Needs

taking the PSM design, development, and installation process described in this book to other parts of the world. 9.6.1 Evaluate Local Needs In the United States, as in many European countries, there is a level of awareness of process safety based on industry history and experience, public perception (as influenced by the news media), and regulatory activity. This level of awareness provides a foundation for the process safety management implementation processes. Before beginning work on PSM in another country, it is important to understand local priorities and influences. These include regulatory issues, cultural expectations, internal company requirements, and systems already in place. Regulation governing process safety varies dramatically outside the United States. Several European countries have strong requirements calling for safety analysis of new projects, while other countries have no process safety regulation at all. Where regulations related to process safety exist, they must be understood and PSM system design must be consistent with them. For example, some countries may require that operators participate in hazard analyses and incident investigations. Where there are no process safety-related regulations, you have complete flexibility in system design. Cultural differences may have a strong influence on the approach you apply to PSM system design and to installation of the systems. In some countries (e.g., Japan) it is expected that the design process will be a participatory one, and attempts to simply install a system that had been designed elsewhere would be doomed to failure. In other countries (e.g., India), the norm is highly directive management within plants, and attempts at employee involvement in system design would be unlikely to work. The best way to ensure that your plan for PSM design, development, and installation will mesh with local culture is to rely heavily on local management in formulating your initial plan. In some situations, the best approach may prove to be direct importation of PSM systems developed elsewhere, while in other situations you may serve as a resource to a local team that engages in its own design process. System designs must recognize the differences in operator job responsibility and capability that may exist in different countries. The degree of responsibility and authority given to the operator can vary greatly. U.S. managers are accustomed to operators' having a significant degree of authority for keeping a plant running during a shift, and expect operators to have the training required to do this. In some other parts of the world, operators are much less well trained and rely more heavily upon supervisors for direc-

tion. Your PSM system design must be realistic in its assignment of roles and responsibilities. Internal company requirements should be considered in designing your PSM system. In some companies, the internal policies applicable to U.S. plants do not yet apply in all other parts of the world. Most companies are moving toward uniform worldwide internal standards, but some are still phasing in the more ambitious internal standards in places that started out with weaker programs. Your PSM design should not assume the implementation of internal standards that have not yet been introduced. As with the development of PSM systems in the United States, your PSM design in other countries should recognize and build upon related management systems that are already in place. You will want to be sure that these are identified and understood. 9.6.2 Establish Priorities As is true in PSM implementation in the United States, it is not practical to try to do everything at once; you must establish priorities for PSM design, development and installation. The priorities that were appropriate in your U.S. effort may not apply directly to international locations. For example, in some international locations, plants are required to submit risk analyses to the government before undertaking major capital projects. This existing practice may make the capital project review element of PSM a less urgent priority. The approach taken to defining priorities in your initial implementation (see Chapter 5) can be applied internationally as well. Priorities will be driven by the risks and by the existing systems that are already in place to help manage those risks. 9.6.3 Match Systems to Local Needs Once local needs and priorities are understood, the basic process of PSM implementation can proceed following the same approach described in the first eight chapters of thisbook. Once again you must begin with management commitment, and work through evaluating the present status, developing a plan, developing specific management systems, putting them in place, and monitoring the installation. The pace at which this proceeds should be realistic, in view of the availability of technical and managerial resources. In many parts of the world your plants will be far from other company activities, and your ability to provide support from headquarters or from "sister" plants will be limited. Do not underestimate the amount of effort needed to "sell" the need for process safety management. This concept has become widely recognized in

the chemical process industries in the United States; however, it is still new in many other places. Process safety management can be applied worldwide, but the implementation of PSM cannot succeed simply by taking U.S. programs and attempting to install them unchanged in other parts of the world. Management styles differ in different cultures and PSM systems must be designed to respect those differences.

CONCLUSION Process safety management concepts were developed initially for the chemical process industries. However, the use of management-based approaches to supplement engineering approaches in controlling hazards is an approach with widespread applicability. The experience you have gained in designing, developing, and installing a PSM system will make expansion of this approach an easier task.

EPILOGUE This book has described an approach you can follow in implementing process safety management systems. When you complete the steps described in this book you will have PSM installed, but your job will not be finished. Over time, changes will occur in your company. Products and processes will change; roles, responsibilities, and organizational structure will change; and in all likelihood safety management goals and objectives will change. Companies are dynamic and are continuously evolving. As changes occur in your company, corresponding changes will be required in your process safety management systems. This book has addressed the first three steps in the five-step "life cycle" of PSM systems (see Figure E-I). The first three are critical to getting things started, but the final two are equally important to achieve the full potential of PSM. Process safety management systems should evolve as does your company. However, it is important that this evolution be controlled. If PSM systems are allowed to change without careful planning and understanding of the implications of change, a system can become seriously flawed. Management of system changes, and periodic audits of system operation, help safeguard against this. Beyond the "responsive" changes that may occur as your company changes, you should seek out ways to continuously improve PSM systems. All

Design

Develop

Install

Operate

Maintain and Improve Figure E-1 Stages of Process Safety Management Systems

management systems benefit from periodic review and reconsideration. As you gain experience with PSM systems, you will undoubtedly discover new and better approaches. To facilitate continuous improvement, it should be clear who is the " process owner" of PSM systems; that is, the functional group responsible for system maintenance and improvement. The American Institute of Chemical Engineers' Center for Chemical Process Safety (CCPS) has played a leadership role in promoting the importance of process safety management, and has plans for continued activity in this area. CCPS is continuing to promote publications and conferences on process safety management, is helping to develop PSM-related training materials, is conducting research on methods to measure PSM performance and effectiveness, and is developing multimedia training (including computer-based training modules). Through these efforts and those of other interested groups, process safety management has become and will continue to be an important tool in efforts to enhance process safety.

CASE STUDY IN IMPLEMENTING PROCESS SAFETY MANAGEMENT This book has described a series of steps through which you can design, develop, and install process safety management systems. The implications of various kinds of company organizations have been recognized, the need to communicate throughout the process has been discussed, and various techniques have been identified for assessing your existing PSM status, designing new PSM systems, and installing the systems. The case study that follows describes the application of these approaches to Midwest Chemicals and Plastics, a multidivision corporation in which both centralized and decentralized management are found. At Midwest, we see an individual handed the assignment of "getting PSM done," and having to build real management commitment, identify goals, develop priorities, and finally design and install programs. The case study provides an illustrative example of how the steps described in this book come together to result in PSM system installation.

BACKGROUND Midwest Chemicals and Plastics (MCP) is a large public company with four operating groups (divisions), each headed by a Group President: Industrial Chemicals; Petrochemicals; International; and Amalgamated Specialty Chemicals (ASC). As Figure 1 indicates, each of MCP's operating groups has a distinct organizational structure. Industrial Chemicals and Petrochemicals have been MCP's core businesses since the company was formed in the late 195Os. International began as a sales office some 15 years ago, and has since expanded to include manufacturing operations in Europe and the Pacific Rim. ASC, a smaller family-owned business, was acquired last year in a negotiated transaction. Most of ASC7S former management remains in place. MCP has a Core Management Group, which comprises the four division Presidents. The "old" MCP division (Industrial Chemicals and Petrochemicals) together produce 70 percent of company revenues and 55 percent of profits. ASC has the best margins, while International enjoys the fastest

MCP CEO*

VP-Corp. Admin.

President* Industrial Chemicals

Acids

Solids

President* ASC

President* International

President* Petrochemicals

GM-EHS Corp. Safety Dir.

Intermediates

Admin.

R&D

Mfg.

Asia

Europe

Local EHS

EHS

Design Eng.

Maint. Eng.

Local EHS

Local EHS

Sales

EHS

Mfg.

Div'l EHS

Local EHS

Local EHS

Local EHS * Member, MCP Core Management Group Note: "Local" personnel report to facility managers FIGURE 1. Midwest Chemicals and Plastics, Inc.—Environmental, Health, and Safety Organization

Env. dir. H&S dir.

Local Env. Local H&S

growth. The ASC acquisition was a friendly one, designed to expand MCP7S product base. Merging ASCs operations into MCP has proceeded relatively smoothly; since the businesses complement each other, no appreciable downsizing has been necessary. At the operating level the lack of overlap between the businesses means that after a full year, ASC remains largely self-contained, with a distinct culture, structure, and way of doing things. Little in MCP7S day-to-day operations provides either the need or the opportunity for corporate teamwork. Nowhere is this more apparent than in the area of environmental, health, and safety (EHS) management, which represents a priority concern for MCP. MCP, as part of its growth plan, is in the process of decentralizing. The management group has begun to push responsibility for a range of traditional staff functions down into its business operations, whose managers are increasingly independent. Some of the operations are implementing self-directed work groups at the operating level. The decentralization process is not yet complete, but at this point MCP has a relatively small corporate staff and the trend is clear. Among this staff are MCP7S corporate EHS and engineering groups, which remain intact because the necessary functional safety management expertise is not yet in place in all of MCP's divisions. In contrast, ASC is essentially a hierarchical organization, with direction coming clearly from the top. Similarly, many key staff functions have historically been centralized, in part because ASC7S operations are concentrated geographically. In keeping with this structure, ASC maintains a full-service staff of professionals charged with EHS oversight for its five facilities. MCP7S corporate EHS staff are charged with servicing all four of the company^ divisions. Both Industrial Chemicals and Petrochemicals tend to call on corporate staff more frequently than ASC, which usually turns to its own personnel for assistance. International maintains an informal relationship with MCP7S EHS group, but more often relies on outside expertise for help in interpreting applicable regulation locally. Given this varied organization and range of management styles, undertaking a corporate initiative of any kind presents a number of challenges, especially for those employees who are charged with actually making it happen. Large-scale initiatives require top managements endorsement—and then the work begins.

INTRODUCTION After reading CCPS7S brochure A Challenge to Commitment, MCP7S Chief Executive Officer sent his EHS department a copy of the brochure, with a handwritten notation asking " Are we dealing with this?77

This initiated a process through which MCP's safety professionals and other staff address this question, for the corporation as a whole and within its domestic divisions.

GETTING MANAGEMENT COMMITMENT MCP's safety director was pleased to learn that the CEO was at least aware of process safety management, but was not sure that the CEO fully understood what's involved at a practical level. The safety director's first move after receiving the CEO's note is to take steps to solidify the buy-in of the Core Management Group (see Chapter 2). To achieve this, the safety director drafts a concise presentation for the Core Management Group that includes: • Fundamentals of process safety management —brief background on basic principles and components, provided to ensure consistent understanding of what is being proposed. • Statement of PSM goals for MCP —how these basic principles apply to MCP's business operations and structure, and support its commitment to continuous improvement. • Benefits to MCP of a systematic approach —discussion of efficiencies to be achieved through interdivisional teamwork, framed in terms of savings and/or avoided losses. • Potential downside of maintaining the status quo —discussion of potential lost savings; eroded competitive advantage as others gain leadership. • Next steps —Commitment to promptly develop detailed business plan for management review and approval, including timetable and resource requirements. The upshot of this meeting is the official endorsement of PSM by the MCP management group, with several key provisions: 1. ASC, because of its preexisting structure, will develop its own approach to implementing PSM rather than participate in a "corporate" effort. ASC believes that its operations, both structurally and culturally, are sufficiently different from those of the broader MCP that its president is concerned about a "force fit." The CEO agrees to allow ASC to develop its own plan, so long as there is continuing cooperation and interaction with the corporate effort and the end result conforms with corporate standards.

2. International's president supports the concept of PSM, but raises concerns that its structure is too new, and its operations too complex and farflung, for the division to participate effectively at this time. She volunteers the continuing involvement of International's safety director, but suggests that PSM implementation be deferred until the corporate initiative has taken hold. The CEO agrees, on the principle that if the corporate effort is properly planned, it should be readily adaptable to non-U.S. operations. 3. Lastly, the management group makes it clear that they expect more information—and sooner rather than later—about how the PSM champion plans to proceed, particularly with regard to timetable and projected expense. The safety director is pleased with the reception his presentation has received, and on the whole with the level of support that has been expressed. His challenge now is to figure out how to proceed, since the management group has essentially established the need for two parallel efforts—one for ASC and the other for Industrial Chemicals and Petrochemicals—as well as for preliminary groundwork for implementation within International.

DEFINING GOALS Having won initial endorsement from senior management, the safety director must decide which of the available process safety management models is most appropriate for the company overall (see Chapter 3). The safety director assembles descriptions of a range of PSM models developed by government, industry, and labor organizations, including OSHA, CMA, OECD, API, ILO, and CCPS. In terms of the big picture, he finds that most of these models are roughly comparable; all of them describe common elements of process safety management. Since the major PSM models are philosophically equivalent, the safety director concludes that the decision among them should be based on practical considerations, such as: • Can we apply this model effectively throughout MCP and within each of its divisions? • Could we expand this model to accommodate future acquisitions or other shifts in business strategy? • Does this model offer us enough flexibility to adapt it to diverse operations and staffing patterns? • Is this model detailed enough to provide tangible guidance for implementation at the facility level? • Does this model promote continuous improvement?

As he considers PSM in the context of MCP, it becomes clear to the safety director that practical application will require development of a more detailed system within the framework of the common PSM elements. He concludes that the CCPS model best meets MCP7S needs, in large part because it alone offers what he sees as a workable model of management system characteristics—which will save time and money. He believes that, for MCP7S purposes, CCPS7 approach provides the most tangible assistance, while allowing sufficient flexibility for adaptation. Having made this decision, the next step is to develop specific criteria for the company's PSM initiative. The safety director decides that the best way to accomplish this is through teamwork. Not only does he recognize that it is too much for any one person, but, at least as important, he wants to ensure that the end result satisfies the full range of MCP7S interests. He also feels that this initial task is a good way to begin getting consensus and cooperation within MCP in support of the PSM initiative. Although MCP does not have a strong tradition of interdisciplinary teamwork, top management actively encourages this direction, and the safety director is reasonably confident that he can get the people he wants. The safety director takes responsibility for identifying and convening a PSM task group. Fortunately, there's some groundwork in place, thanks to the informal discussions he held within MCP7S EHS organization to prepare for his presentation to the management group. In addition, MCP7S CEO recently sent out an all-staff memo, notifying employees of the safety director's role as the company^ PSM "champion.77 Since ASC plans to develop its own PSM plan, the safety directors initial concentration is on Industrial Chemicals and Petrochemicals. However, the safety director acts as a liaison to ASC7S efforts so that information can be freely exchanged. In considering the composition of a joint Industrial Chemicals-Petrochemicals task group for PSM, the safety director reviews the skills matrix he sketched out for his initial presentation. He also considers the importance of having the two divisions7 varied operations equally represented on the team to ensure that the end result satisfies all concerned. At the same time, he knows from experience that committees can easily get too big to be effective. After chewing on the problem, he decides that a workable approach would involve establishinga small core team representing a cross-section of relevant disciplines and a larger advisory group. The core team he envisions comprises key engineering, safety, and health professionals from within Industrial Chemicals and Petrochemicals, while the advisory group includes the managers and safety specialists at the two divisions7 facilities plus International's director of safety. Under this plan, the core team develops recommendations and circulates them to the advisory group for commentary. Since most of the core team works

out of headquarters, travel is reduced and scheduling is simplified. Depending on the task, the advisory group can be expanded to include other MCP professionals, such as corporate communications or human resources specialists. At its first meeting, the task team for the decentralized Industrial Chemicals and Petrochemicals divisions establishes PSM goals (as described in Chapter 3). The Industrial Chemicals and Petrochemical (IC&P) team determines that the two divisions should, within two years, have PSM systems in place that conform to the CCPS model. They decide that these systems should apply throughout their operations, even in areas in which the CCPS model exceeds regulatory requirements. The centralized ASC division defines its own goals through its preexisting Facility Managers Council led by ASCs vice president of EHS. The ASC team also selects the CCPS PSM model, setting as their goal the application of these systems to those operations covered by OSHA. The team believes a timetable of 12 to 18 months should be sufficient to meet this objective. This information is exchanged and reviewed via the safety director. EVALUATING THE PRESENT STATUS Having agreed on some basic characteristics and parameters for their efforts, each group determines that the next logical step is to identify what PSM components are already in place within MCP, and to assess their effectiveness (see Chapter 4). Each group is determined that its work should build on existing programs and activities, and neither wants to duplicate efforts or reinvent the wheel. The IC&P group's second meeting focuses on deciding how best to evaluate the company's current status with regard to PSM. One member starts the discussion by asking, "What information do we need and where can we get it?" This triggers a short brainstorming session that lists a full range of information sources, including: • "Paper" sources: audit reports, HAZOP studies, safety records, training curricula, etc., and • "People" sources: relevant individuals outside the team, such as facility personnel, EHS staff, union leadership, etc. The team organizes the full list of sources against CCPS' PSM elements to assure that no key components have been overlooked. They then consider how best to tap the information sources they have identified. Given its 15 facilities located throughout the U.S. producing acids, solids, and intermediates, the team for the decentralized Industrial Chemicals and Petrochemicals divisions decides that a survey method will be most efficient.

Three team members agree to undertake the fact-finding phase, starting with developing a comprehensive survey questionnaire. In addition to the questionnaire, the team agrees that it should include some selected interviews to assure that the effort captures anecdotal as well as quantitative information. This leads to a discussion of how to involve Industrial Chemicals and Petrochemicals facility managers: on the one hand, their input is critical; on the other, they already feel overburdened by reporting and administrative tasks. One team member, a facility manager himself, endorses the safety director's suggestion of a PSM advisory group comprising the divisions7 facility managers and local safety specialists. The IC&P team agrees that circulating its minutes and other work products for comment would help assure that facility-based personnel have an opportunity to participate without creating an undue burden. The team also agrees that the PSM evaluation should be properly introduced rather than simply started up with no advance notice or background information. One member offers to draft a memo for the team to circulate to facility managers and others in advance of fielding the survey. The three-member subteam agrees to circulate a draft survey questionnaire within two weeks, and estimates a two-month timetable for completion. The Facility Managers Council of the centralized ASC, at its regular meeting, decides to enlist the assistance of ASC's audit group to organize and conduct its PSM assessment. Based on their own experience, the facility managers are confident that ASC7S audit protocols can be effectively adapted, and that the auditors will be a valuable asset. One facility manager volunteers to coordinate with the audit group and to review the audit protocols against CCPS7 PSM elements to ensure that all points are covered. He agrees to complete these tasks within two weeks. Independently of each other, both teams note that the PSM evaluations should anticipate the information they will need to develop the PSM plans. Both groups single out resource requirements as a category of information that MCP doesn't customarily capture in safety audits or surveys, but that will be essential to planning. By thinking ahead to the planning task (covered in Chapter 5 of this book), the teams can develop evaluation methods that elicit comprehensive, relevant information.

DEVELOPING A PLAN After completing their assessments of current PSM status, the next task for both teams is to develop detailed implementation plans. For decentralized IC&P, the PSM team led by the safety director undertakes this task. For the centralized ASC division, the Facility Managers Council assigns the task to

the divisional Engineering Department. Recognizing the need to maintain awareness of PSM among senior management, the safety director prepares a progress report format that discusses activity to date, broad directions, and next steps. This accomplished, the safety director then turns his attention to the next major step: preparing detailed plans for PSM design and installation (see Chapter 5). Thus far, the two-team approach (IC&P and ASC) has functioned fairly smoothly with little significant conflict or duplication of effort. However, the safety director also realizes that the tasks to date have been primarily data collections and thus relatively easy to manage. By contrast, the planning process is far more complex, requiring more sophisticated analysis and subjective judgment. It's vital that this key stage start off on sound footing, with common goals clearly understood by both teams. To help make this happen, the safety director schedules a meeting with ASC's vice president-EHS, to discuss broad parameters for the planning task. He stresses that his goal is not to impose a "corporate" plan on ASC, but rather to assure that both teams follow a common process to achieve their respective goals. He also urges closer interaction between the PSM teams during the planning phase, so that all divisions have the benefit of fresh thinking. Both teams convene in a plenary session at which they review progress to date, beginning with a summary of the PSM goals each has established. Discussion then turns to a summary of each team's PSM assessment findings, led by a designated team member. Next, the team leader outlines next steps: first, deciding on an implementation strategy and defining priorities, then developing a program plan, a schedule, and an estimate of resource requirements. In the interests of efficiency, both the IC&P team and the ASC Facility Managers' Council tackle the question of implementation strategy while they are assembled. The IC&P team decides that a facility-specific approach makes best sense for their divisions, given both the diversity of their operations and a management style that increasingly delegates down. However, they recognize that this will require careful monitoring and oversight to ensure consistency among locations. The ASC team, which represents five facilities, believes a centralized, or companywide, strategy will be more efficient, and can capitalize on ASCs centralized safety expertise. Discussions then focus on PSM priorities. The ASC Facility Managers' Council agrees to schedule a special meeting in two weeks' time, at which each member will present an analysis of the assessment results and the PSM gaps they indicate. The IC&P team drafts three members from headquarters (who can meet conveniently) to prepare "straw man" recommendations for circulation to the core team and the advisory group of facility managers. The upshot of these analyses, not surprisingly, is two distinct sets of PSM priorities.

The team from the decentralized IC&P divisions decides to enlist the help of the two divisions' facility managers to develop the implementation plan. After matching the PSM gaps with tasks that will address them, the team circulates this information, requesting that each facility manager determine the necessary subtasks, schedule, and resource requirements as they apply to his or her facility. While this approach takes longer, the IC&P team feels strongly that facility management must be involved and invested in the plan if it is to be effective. The ASC team prepares a single, centralized plan, which has the input of facility-level personnel through the Facility Managers' Council. When first drafts of their plans are complete, the ASC and IC&P teams present them to each other, using this as an opportunity to get additional input and to rehearse the presentations they expect to make to MCP's Core Management Group.

DEVELOPING SPECIFIC PSM SYSTEMS Once MCP's management has approved their plans, the centralized ASC and the decentralized Industrial Chemicals and Petrochemicals divisions must now turn their attention to the development of specific PSM systems (see Chapter 6). The ASC team, whose centralized PSM plan is relatively simple, indicates a strong inclination to rely almost entirely on model programs that have proven successful in other companies. In contrast, the decentralized IC&P group intends to redesign the PSM systems altogether—virtually from the ground up—to the divisions' specifications. The two teams meet to discuss various approaches to systems design. ASC has traditionally handled this function in-house, drawing heavily on model programs from elsewhere in its industry sector. Its approach tends to emphasize incremental improvements rather than business process redesign. Industrial Chemicals, by contrast, has devoted considerable resources—both internal and external—to process design. Reflecting the division's changing product mix, Industrial Chemicals' approach to systems development tends toward custom design. Petrochemicals falls somewhere between the two; depending on whaf s needed, Petrochemicals may adapt a model program, improve an existing system, or design an entirely new one. The teams decide to take a flexible approach, using a mix of techniques. They recognize that any of these system design approaches can be used in either a centralized or a decentralized approach to PSM implementation. Each team will continue to emphasize its own strengths, but the team leaders agree to make sure both remain open to other methods. For example, ASC 's vice president-EHS has some familiarity with Total Quality Management (TQM) techniques, and wonders if they might be applied to PSM system design.

By the end of their meeting, each team has established several key parameters for the systems design phase, including structure, methods, and communications. The ASC effort will remain in-house, with the Facility Managers' Council maintaining its primary role. For the design phase, the Council will expand to include a Petrochemicals TQM facilitator and the safety director will continue to attend its meetings. ASC's first priority will be to research available model programs but will not confine its efforts solely to this approach, and the team leader will establish a consistent mechanism to assure that model programs are diligently reviewed and adapted as needed, prior to installation. The IC&P team will rely on a combination of TQM techniques and business process redesign. Because its PSM plan is more complex, the IC&P group will establish several sub-teams to focus concurrently on a number of PSM elements; these sub-teams will include outside consultants and selected facility managers. One sub-team will be charged with researching and evaluating model programs for consideration. The safety director will appoint a task leader for systems design, to whom the design sub-teams will report. The work product for the centralized ASC division will be a series of Standard Operating Procedures (SOPs) that strictly conform to ASC's format. The "deliverables" for the decentralized Industrial Chemicals and Petrochemicals divisions may take several forms, depending on the system element under review and the practices already in place in a given facility.

PUTTING THE SYSTEM INTO PRACTICE ASC's PSM team is first to complete the systems design phase, and they feel they are ready to begin installing new PSM systems (see Chapter 7). The IC&P team's more complex plan requires more time for systems design, but ASC wants to move on to the next phase and doesn't want to wait for the other divisions to catch up. The safety director's first reaction is to put the brakes on ASC, but on further reflection sees no real reason why the two teams must operate on identical timetables. In fact, he decides that there could be real advantages to the ASC team's moving forward now. Not only would it help preserve the ASC group's momentum, but it would also provide the IC&P team with both information and incentive. The MCP safety director believes that pilot tests can help create workable templates—models the divisions can apply to installation throughout multiple facilities. While the ASC team tends to be somewhat skeptical, they see the logic: pilot testing can help them reinforce management's buy-in to the PSM initiative and yield detailed information about resource requirements for full installation. The ASC and IC&P team leaders meet to discuss how best to organize pilot testing.

Both teams define the scope of their PSM pilots in terms of the information and experience they expect to gain, deciding for this reason to select a test site that offers the opportunity to test a meaningful range of system components. They also agree that the pilot tests must incorporate common mechanisms for measuring and monitoring progress, soliciting participants7 feedback, and assessing results. Another question the team leaders consider is the role of facility management in the pilot tests. At the centralized ASC division, facility managers have traditionally had less autonomy than their counterparts within other MCP divisions, and their PSM team doesn't see facility manager support as an issue. Looking ahead to implementation at the decentralized IC&P divisions, the safety director has concerns about facility managers' buy-in. The ASC team decides to oversee the ASC pilot themselves, while the IC&P group plans to assign responsibility for conducting its test to the manager of the site they select. Since this approach is consistent with each group's usual practice and its divisional culture, the safety director agrees. Having agreed to conduct pilot tests, and to proceed along independent schedules, the two teams convene to consider broader installation strategy. While both teams believe if s premature to make firm determinations, pending the outcome of their respective pilot tests, they want to review their options as part of the planning process. Consistent with the companywide implementation strategy they had selected, the ASC team would, ideally, launch full PSM installation at every facility simultaneously. However, they recognize that doing so would require a level of staff support that may not be available. The ASC team agrees that a more realistic approach involves a staged installation, beginning with priority PSM elements. The IC&P group, which had adopted a facility-specific strategy, believes that its installation plan should actively involve facility managers at every step of the process. Under this approach, the PSM team would take on an advisory and monitoring role to assure consistency and timeliness, but would be less involved day-to-day once installation has begun. The ASC team develops a plan for its pilot test, which they estimate will require 6 to 8 weeks of operation, plus another two weeks for assessment and reporting. They agree to share this plan with the IC&P team for future reference; by the time the ASC pilot has been completed, the IC&P group should have completed the systems design phase and will be ready to undertake its own test. The safety director drafts an update memo, informing facility managers that the PSM system is ready for testing, and describing what this may involve. He does so in collaboration with the ASC team and arranges with MCP's Corporate Communications department to run a bulletin in both the company newsletter and on the electronic mail system. As the team leaders see it, if s

time to reinforce employees' awareness of PSM, and, with any luck, generate enthusiasm for full implementation. Once the ASC pilot test is complete, the ASC team meets to assess results. Based on this assessment, they make some minor revisions to both the PSM systems and their installation schedule. This information is shared with the IC&P team and with MCP7S senior management. The IC&P team draws on ASC's experience to identify an appropriate site and conduct a pilot test of their now-completed systems. ASC begins full installation of the division's PSM system by focusing on priority PSM elements. Two of these are complete by the time IC&P concludes its pilot test. Once the results are assessed, and some modifications made, IC&P begins to install its PSM system at each of the two divisions' facilities. Throughout the pilot tests and subsequent installation, the ASC and IC&P teams continue to exchange information via the safety director and by circulating update memos. Now that ASC is a step ahead, the IC&P team hopes to learn from its experience.

MEASURING AND MONITORING Once ASC had completed its pilot test, the safety director met with the division's PSM team to discuss its installation schedule. At that time, he raised with the team the question of monitoring the installation to assure timeliness and consistency, and flagged the need for quality assurance. The safety director recognizes that once PSM installation is underway, his role—and the roles of the two PSM teams—will change. As he sees it, installation must be managed locally, which means that responsibility shifts from the teams to the field. While he welcomes this milestone, the safety director is still accountable to MCP management for this phase of the company's PSM initiative. Besides, he and his colleagues have too much invested not to see the process through. For ASC, quality control is a relatively simple matter. Since only five facilities are involved, and the Facility Managers Council has acted as the PSM team, the chance of major slippage in the installation phase is fairly remote. The greater challenge, in the safety director's view, lies in assuring that ASC (which traditionally has been somewhat autocratic) involves PSM users at all levels in the process of continuous improvement. The IC&P team presents a different set of priorities for measuring and monitoring. Industrial Chemicals and Petrochemicals comprise many different, geographically dispersed facilities, each of which has very independent management; consistent installation is a key concern. At the same time, these divisions have a stronger inclination toward teamwork, so the safety director is confident that user feedback will be solicited and valued.

The safety director sees measuring and monitoring as accomplishing two important goals: providing quality control for the installation phase, and promoting continuous improvement going forward. For this reason, he urges the ASC and IC&P teams to devise monitoring methods that serve both purposes and that can be incorporated into ongoing PSM system maintenance. Both teams recognize the need for monitoring at two levels: local (plantlevel) and systemwide (throughout the affected division[s]). In addition, the safety director, as PSM champion, has responsibility for monitoring companywide performance. The ASC team assigns local monitoring to facility managers, who generate monthly reports for the division's vice president-EHS. In addition, the Facility Managers Council adds PSM as a standing agenda item for its regular meetings, during which each manager provides a brief update. For systemwide monitoring, ASC enlists its in-house audit group, which agrees to conduct site visits to each ASC facility at three key points: initiation, midpoint, and closeout. The safety director suggests that ASC incorporate PSM monitoring into the division's regular audit program once installation is complete, to assure that the new systems continue to improve. He further suggests that ASCs facility managers make their monthly reports available to all PSM users and actively solicit their comments. The IC&P team also turns to local facility managers to conduct plant-level monitoring, requesting weekly "exception reports" to supplement more formal, written reporting to the PSM team. The team itself takes responsibility for systemwide monitoring. Given the number and dispersion of the facilities involved, if s not realistic to visit each one, so the team chooses a method that relies primarily on spot checks and extensive user surveys. To improve information exchange, the IC&P team plans to circulate monthly PSM reports to both divisions' facility managers and safety directors. Once installation is complete, they plan to request quarterly reports from all facilities to assure continuous monitoring. In addition, the team proposes that the divisions' performance review procedures be revised to incorporate PSM activities, as a means of further integrating PSM into business operations. For his part, the safety director agrees to provide MCP's Core Management Group with a monthly status report for the duration of the installation phase. Thereafter he will generate quarterly updates, and suggests that the Core Management Group add PSM to its regular agenda.

EXPANDING BEYOND INITIAL SCOPE Two years have passed since the safety director assumed responsibility for implementing PSM within Midwest Chemicals and Plastics. By this time, all

of MCP7S domestic divisions have installed viable PSM systems, which have become fully integrated into local operations. Regular monitoring—through PSM audits, facility managers' meetings, and user feedback surveys—enables facility managers to continue to improve and refine the PSM systems, while providing MCP7S management with consistent assurance that standards are being met throughout the three divisions. PSM has become a regular agenda item for MCP7S Core Management Group, and at one of its meetings the safety director proposes that management consider expanding the initiative beyond its original scope (See Chapter 9). Based on experience to date, he believes the PSM system could be effectively applied elsewhere within MCP, and feels that doing so would reinforce the company^ overall safety performance. International7s president endorses this view. As the sole MCP division that has yet to adopt the PSM system, International trails the others and is now eager to catch up. International's Director of Safety has kept fully abreast of the U.S. initiative, and has advised the division President that many aspects of the PSM system would benefit International's operations. The safety director volunteers to work with International to devise ways of adapting the U.S. system to operations in other countries. He recognizes that he will need considerable information about local regulations, business operations, and customs to make sure the system meets local needs. International7s president assigns her Director of Safety to act as a clearinghouse for information, and to work with the corporate safety director to customize a PSM implementation plan for the division. In addition to bringing International into the corporate PSM system, the safety director points out other opportunities for expansion, both domestically and overseas. As he sees it, PSM principles support the concept of continuous improvement, which MCP as a whole has adopted and endorsed for all of its operations. It is with this concept in mind that the safety director proposes to expand PSM coverage beyond minimum requirements, and to apply the system to a range of other activities. To illustrate his point, the safety director circulates a chart displaying the relevance of PSM to several EHS-related functions (e.g., industrial hygiene) and to other MCP business operations (e.g., distribution systems). He then revisits the original goals established by the Core Management Group, which include targets for improvement in safety performance and recognized leadership in PSM. He makes the case for expansion based on the interrelationships among the various operations and staff functions, and their collective impact on overall safety performance. In response to questions from the management group, the safety director points out that expansion could be achieved with a relatively modest investment of staff-time, since the system is now up and running and models exist for all of the major tasks. Moreover, MCP has generated and maintained a high

level of employee awareness of PSM, suggesting that getting people on board should not present a problem. The Core Management Group agrees with the concept, but would like additional information and more detail. The safety director proposes to prepare a more detailed plan for their review, pointing out that he can do so relatively quickly given all the work that has gone before. Once the plan is accepted, the safety director reviews the process he followed for MCP's initial PSM installation, and finds that much of it can be readily adapted to the expansion he has recommended.

BIBLIOGRAPHY Process Safety Management Center for Chemical Process Safety. Guidelines for Technical Management of Chemical Process Safety. New York: AIChE/CCPS, 1989. Center for Chemical Process Safety. Plant Guidelines for Technical Management of Chemical Process Safety. New York: AIChE/CCPS, 1992.

Management Systems Ansoff, H. Igor. Implementing Strategic Management. Englewood Cliffs, NJ: PrenticeHall, 1984. Anthony, Robert N. Management Control Systems. Homewood, IL: Richard D. Irwin, Inc., 1984. Anthony, Robert N. The Management Control function. Boston, MA: The Harvard Business School Press, 1988. Camillus, John C. Strategic Planning and Management Control. Lexington, MA: Lexington Books, 1986.

Quality/Continuous Improvement Crosby, Philip B. Quality without Tears. New York: McGraw-Hill, 1984. Deming, W. Edwards. Out of the Crisis. Cambridge, MA: M.I.T. Center for Advanced Engineering Studies, 1986. Feigenbaum, Armand V. Total Quality Control, 3rd ed. New York: McGraw-Hill, 1983. Garvan, David A. Managing Quality. Novato, CA: Freeperson Press, 1987. Harrington, H. James. The Improvement Process: How America's Leading Companies Improve Quality. New York: McGraw-Hill, 1986. Hayes, Glenn E. Quality and Productivity: The New Challenge. Quality and Productivity Conference Proceedings, Society of Automotive Engineers, 1985.

Auditing Center for Chemical Process Safety. Guidelines for Auditing Process Safety Management Systems. New York: AIChE/CCPS, 1993. Greeno, J. L., Hedstrom, G. S., and DiBerto, M. A. Environmental Auditing: Fundamentals and Techniques, 2nd ed. New York: John Wiley & Sons/Arthur D. Little, Inc., 1987, pp. 1-368.

Index Index terms

Links

A American Petroleum Institute (API) Approvals, plan communication and approval

48 121

Audience assessment management commitment use

29

needs selling

10

Audits, evaluation tool selection

79

B Benefits, needs selling

12

Brainstorming, company-specific attributes

63

Business process redesign, approach selection

137

C Center for Chemical Process safety (CCPS) model Centralization, sponsor selection guidelines

47 8

Charters, goal setting

25

Chemical Manufacturers Association (CMA)

48

Chief Executive Officer, sponsor selection guidelines

8

Chief Operating Officer, sponsor selection guidelines

8

Commitment, framework selection

46

Communication(s) management commitment use

28

needs selling

22

plan communication and approval

121

program plan development

119

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215

216

Index terms Communication approach, company-specific attributes Company culture, sponsor selection guidelines Company-specific attributes

Links 70 8 62

company management system approach

63

define communication approach

70

define documentation approach

69

define supervision/delegation approach

67

generally

62

goal definition

62

Companywide monitoring

177

Compliance needs selling

12

pilot testing

154

Concept selling, strategies for getting management commitment Contract personnel, training of Cost savings, needs selling

10 171 13

Culture. See Company culture Customer feedback and follow-up, installation measurement and monitoring Customer satisfaction, needs selling

182 14

D Data collection, companywide monitoring

178

Data reporting, companywide monitoring

181

Deadlines management commitment rationale team selection (PSM system) Decentralization, sponsor selection guidelines

7 144 8

Define communication approach, company-specific attributes

70

Define documentation approach, company-specific attributes

69

Define supervision/delegation approach, company-specific attributes

67

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217

Index terms

Links

Documentation approach, company-specific attributes

69

Downtime reduction, needs selling

13

E Efficiency, needs selling Elements, priorities definition Employee recruitment/retention, needs selling

13 104 14

Environmental Protection Agency (EPA) framework selection

48

needs selling

12

Evaluation of present status. See Present status evaluation Evaluation tool selection

75

audits

79

generally

75

surveys

83

Executive summary, needs selling

18 20

Expansion

187

activities included

188

beyond minimum requirements

187

functions included

188

implementation case study

210

internationally

190

overview

187

processes included

190

Expectations, pilot testing

150

F Facilities, priorities definition

101

Facility ranking process, plan development example

124

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218

Index terms

Links

Feedback installation measurement and monitoring

182

pilot testing

152

Flexibility, framework selection

46

Framework selection, goal definition

45

G Gaps and overlaps identification, present status evaluation

89

Goal definition

45

company-specific attributes

62

company management system approach

63

define communication approach

70

define documentation approach

69

define supervision/delegation approach

67

generally

62

framework selection

45

CCPS model

46

generally

45

other models

47

implementation case study overview pilot testing team establishment

201 45 150 50

composition of team

51

dynamics within team

51

generally

51

meeting dynamics

61

meeting scheduling and organization

59

participation solicitation

56

Goal setting management commitment use This page has been reformatted by Knovel to provide easier navigation.

23

219

Index terms

Links

Goal setting (Continued) needs selling Group mission statement, goal setting

22 25

H Human resources management commitment use program plan development "Hybrid" approach, implementation strategy selection

35 117 99

I Implementation

147

case study in

207

installation planning and management

159

location

159

personnel

161

overview

147

pilot testing

147

generally

147

implementation

150

local support for

149

results assessment

158

site selection factors

148

selling the system

161

benefits description

162

generally

161

reinforcement of management buy-in

163

reinforcement of participant buy-in

165

training

168

of contract personnel

171

generally

168

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220

Index terms

Links

Implementation (Continued) of managers

169

methods and tools for

172

of trainers

169

of users

170

Implementation case study

197

background

197

expansion

210

goals definition

201

management commitment

200

measurement and monitoring

209

overview

199

plan development

204

present status evaluation

203

system development

206

system implementation

207

Implementation strategy selection

95

companywide approach

96

facility-specific approach

97

generally

95

Incentives management commitment rationale team selection (PSM system) Incident reporting, program plan development

7 144 119

Information reporting and consolidation, present status evaluation performance Installation measurement and monitoring

87 175

customer feedback and follow-up

182

implementation case study

209

monitoring

175

companywide This page has been reformatted by Knovel to provide easier navigation.

177

221

Index terms

Links

Installation measurement and monitoring (Continued) generally

175

plant-level

176

overview International expansion

175 190

L Labor relations, needs selling Legitimacy, management commitment rationale Local support, pilot testing

14 7 149

M Maintenance costs, needs selling Management commitment implementation case study rationale for sample presentation document strategies for getting

14 7 200 7 39 8

concept selling

10

need selling

19

sponsor selection use of

8 23

communications

28

goal setting

23

resources

33

Management style, sponsor selection guidelines Management system design, framework selection Managers, training of

8 46 169

Measurement and monitoring. See Installation measurement and monitoring Meetings dynamics of, team establishment This page has been reformatted by Knovel to provide easier navigation.

61

222

Index terms

Links

Meetings (Continued) scheduling and organization, team establishment

59

Mission statement. See Group mission statement Model programs approach, approach selection

134

Monitoring, pilot testing

154

See also Installation measurement and monitoring

N Need selling, strategies for getting management commitment Noncompliance, priorities definition

19 104

O Objectives, goals and

23 24

See also Goal setting Occupational Safety and Health Administration (OSHA) framework selection

48 49

needs selling Outlines, needs selling

12 15 16

Overlaps and gaps identification, present status evaluation

89

P Peer company programs, framework selection

46

Pilot testing

147

generally

147

implementation

150

local support for

149

results assessment

158

site selection factors

148

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223

Index terms Plan development

Links 95

examples facility ranking process

124

management presentations on PSM plan

126

implementation case study implementation strategy selection

204 95

companywide approach

96

facility-specific approach

97

generally

95

"hybrid" approach

99

plan communication and approval preliminary plan review priorities definition

121 95 100

elements

104

facilities

101

generally

100

limitations on scope

105

resources needs estimation and schedules

106

generally

106

program plan development

107

resource plan development

112 117

schedule development

112 113

Plant-level monitoring Present status evaluation evaluation tool selection

176 73 75

audits

79

generally

75

surveys

83

gaps and overlaps identification implementation case study This page has been reformatted by Knovel to provide easier navigation.

89 203

224

Index terms

Links

Present status evaluation (Continued) objectives

73

performance of

86

information reporting and consolidation

87

results reporting

88

staffing

87

Priorities international expansion needs selling Priorities definition

193 10 100

elements

104

facilities

101

generally

100

limitations on scope

105

Process safety management system(s) elements in expansion of

2 187

See also Expansion implementation

147

See also Implementation installation measurement and monitoring

175

See also Installation measurement and monitoring management commitment for

7

See also Management commitment scope of

1 4

Process safety management system development approach selection

129 129

business process redesign

137

generally

129

model programs approach

134

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225

Index terms

Links

Process safety management system development (Continued) Total Quality Management (TQM) techniques

130

rechecking

146

system development

145

team selection

142

Program plan development, resources needs estimation and schedules Proposal preparation, needs selling

107 15 17

Q Quality assurance, needs selling

14

Questionnaires. See Surveys

R Recruitment/retention of employees, needs selling

14

Rehearsal, needs selling

19

Reporting companywide monitoring

181

incident reporting, program plan development

119

Resources management commitment use

33

needs selling

22

team selection (PSM system) Resources needs estimation and schedules

144 106

generally

106

program plan development

107

resource plan development

112 117

schedule development

112 113

Results assessment, pilot testing This page has been reformatted by Knovel to provide easier navigation.

158

226

Index terms Results reporting, present status evaluation performance

Links 88

S Schedule development, resources needs estimation and schedules

112 113

Scheduling, pilot testing

154

Site selection factors, pilot testing

148

Sponsor selection, strategies for getting management commitment

8

Staffing present status evaluation performance program plan development

87 106

Standards management commitment rationale needs selling

7 12

Status evaluation. See Present status evaluation Stockholders, team selection (PSM system) Supervision/delegation approach, company-specific attributes

142 67

Support resources management commitment use

37

team selection (PSM system)

144

Surveys, evaluation tool selection

83

T Tangible support, management commitment rationale Team establishment

7 50

composition of team

51

dynamics within team

51

generally

51

meeting dynamics

61

meeting scheduling and organization

59

participation solicitation

56

This page has been reformatted by Knovel to provide easier navigation.

227

Index terms Team selection (PSM system)

Links 142

expectations

143

generally

142

Total Quality Management (TQM) techniques, approach selection

130

Training

168

of contract personnel

171

generally

168

of managers

169

methods and tools for

172

pilot testing

151

of trainers

169

of users

170

Travel, management commitment use Travel costs, program plan development

37 119

U Unions. See Labor relations

V Vision statement, goal setting

24 26

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