Golden rules for process safety
HF Integration Pty Ltd
Human Factors Consultancy based in Perth, Western Australia.
Many organisations have developed a set of “Golden Rules” or “Life-Saving Rules” for personal safety, or adopted those from industry associations, such as those published by the International Association of Oil and Gas Producers (IOGP, Report 459, 2018).
The IOGP rules were selected from a review of data reported by industry and relate to the activities most likely to lead to a fatality.
These rules focus on actions within an individual’s control, for example - always wear a seatbelt when driving, or never walk under a suspended load. Since they have been in place, these rules and the behaviours that support them have contributed to a reduction of fatal accidents.
However, several major incidents have highlighted that process safety requires a separate focus over and above personal safety. Some of the existing Life-Saving Rules are relevant to process safety (such as change management, or permit to work), but there was an opportunity to create a set of specific process safety rules.
To support this, APPEA (The Australia Petroleum Production & Exploration Association) produced a set of Golden Rules for process safety behaviours. Each Rule has a set of associated life-saving behaviours and assurance questions.
Unlike the original Life-Saving Rules, the behaviours are not just aimed at front-line individuals. And many of the “behaviours” are not really behaviours at all, but process safety principles, or best practice. This should address some of the concerns that you may have around the focus on human behaviours in other safety initiatives.
For example, one of the Golden Rules is “Design for safe operations”. This Rule addresses a range of expectations, including:
The document also includes example metrics that may be used to assess the effectiveness of the Rule in practice (such as the number of deviations or open process safety actions).
Given that there is more to the management of risk than individual behaviours (particularly in a safety-critical industry), you may find this guidance helpful.
The Process Safety Rules are organised by the key stages of a project lifecycle, supporting how an asset should be designed, constructed, commissioned, operated, maintained, and decommissioned.
These additional rules focus less on individual behaviours, and instead support the design and management of safe plant, equipment, and systems of work. As such, they could complement your existing approaches.
It’s perhaps unfortunate that this guidance uses the term “rules” as this does suggest compliance and the associated links to disciplinary measures. I think of them more as fundamentals or principles.
Although developed in 2016, our network outside of Australia may not be familiar with this document.
NB. From Sept 2023 APPEA became Australian Energy Producers (AEP).
Martin Anderson is a Principal Consultant, working at the intersection of human factors and process safety.
Principal Human Factors Consultant and Certified Professional Ergonomist
2moVery little or no evidence that adherence to BBS based golden rules correlates with process safety outcomes. On the contrary, focus on BBS outcomes and metrics detracts/distracts from process safety q.v. DWH/Macondo. Many elements associated with process safety require more abstract thought and are less observable - keeping it in the pipe! There are also interesting contradictions that arise. Golden rule - always wear gloves. Maintenance on intricate electrical components necessary for process safety means gloves prevent or interfere with fine motor control necessary for task completion.
Active
2moPersonal safety lifesavers are essential in many high-risk activities. However, their effectiveness depends on how well they are communicated and ingrained into daily practices. During a meeting a group of service providers were asked if they were familiar with their client’s lifesavers. Surprisingly, only 50% had heard of them, and of those, only half understood their purpose. When asked why, the most common response was that these lifesavers were often perceived as mere 'themes' or 'posters,' without proper induction or integration into their work routines. The client CEO once stated, 'I can’t understand why we’re providing the tools to enhance safety (one of these was the lifesavers), but we still have fatalities.' This underscores a critical issue: simply providing safety tools isn’t enough. As demonstrated earlier, initiatives like lifesavers must be embedded and thoroughly understood across the entire organization and its service providers. Furthermore, managers must ensure these initiatives are properly implemented and this should be demonstrable at the executive level—or they must be held accountable for any oversights or omissions. Unfortunately, in one instance, this was not the case.
Health Safety and Environment Risk Management Practitioner
2moIts been my experience that 'Golden rules' whilst good in theory can result in investigator bias and worker targeting during investigation if the culture is not right ('Us and 'Them' culture). This results in the organisation not focusing on the latent issues present. Then similar incidents occur again and again. Its tempting to over simplify things by introducing the next annual safety initiative like golden rules etc. with all the bells and whistles. Instead there needs to be more focus on effective risk management, communication and consultation, clear processes, effective training, supervision and critical control assurance. These remain key as every major incident investigation has shown. Safety industry seems to be drowning in paper and processes. More process and paper won't 'cover your ass' or prevent incidents. Keep it simple, make sure people understand, and make sure its working.
Make Process Safety Plausible
2moThe golden rules around process safety practices, needs: - Leadership commitment - Competence mapping towards Safety Critical Tasks - Culture where process safety practices are followed and risk is managed Leadership: The conduct of operations, i.e. Safe Operations or No operations, needs to be the message. The Operation Duty holders need to be influenced to: - challenge the Green, and capitalize measures on the Red. - seek about Process safety targets as much as production targets - walk the talk. Competence: Statistically, around 51% of Tier-1 incidents is during Operations and the remaining is due to Mechanical Integrity and Design inadequacies (ref. EPSC). Competence mapping across Safety Critical tasks, and competency assurance management across project lifecycle is needed to bring about an error tolerant operations. Thanks
Human Factors and Safety Consultant, Ergonomist (political views are my own).
2moI think some organisations already think they do but never really seen them being effective even for occupational safety. They only work when there is a clear "owner" of the golden rule and aligns with the management system.