EHS Journal | 19 October 2015

Key Performance Indicators for HSE Audit Programs

There continues to be intense discussion in the health, safety, and environment (HSE) audit community over how to evaluate the performance of audit programs. Senior executives in both private and public sector organizations want to know whether audit programs are meeting expectations and resulting in compliance improvements. Further, they are looking for clear measures that help them make that determination. Unfortunately, all too often, the focus is on reporting the total number of findings on audits as a simple and easily understood metric—and it is both of these. But is this metric meaningful?

The short answer to the question is no, principally because all findings are not created equal. For example, as discussed in a previous article by this author, “Let’s say that an audit team finds that a regulatory program does not exist at a site because the site erroneously believes that the program does not apply to them. One finding. A second team visits the site 2 years later and finds that much work has been undertaken and the program has been largely implemented. However, there are still four administrative requirements that are not being met completely. Four findings. It’s pretty clear that the one finding on the first audit far outstrips the importance of the four findings on the second audit. Hence, if one were using total number of findings as a measure, the results would be quite misleading.”

As also discussed in the previous article, similar fallacious logic is sometimes applied to other outcomes that might be anticipated by the implementation of an audit program, including a reduction in environmental releases and workplace injuries or improved compliance as defined by a reduction in fines and enforcement actions. And, in fact, even expecting a reduction in the number of overall findings on audits year-on-year can be misleading as well. This is principally due to change, which could include, among other factors, changes in management at the site, changes in the products manufactured and chemicals used, changes in physical facilities and equipment (e.g., decommissioning and startup of new process equipment); or changes in the volume and severity of regulations affecting the site. It’s interesting to note that federal US HSE regulations alone (i.e., Titles 29 and 40 of the Code of Federal Regulations) have increased by more than 3,200 pages in the past 5 years. This has consequences in meeting the goal of full compliance.

  • If all of the above factors aren’t the best measures of success, how then should one approach this issue of assessing the performance of HSE audit programs? First, it might be valuable to identify the five fundamental questions that one would ask of any audit program in order to assess its effectiveness. They are:
  • Has the universe of auditable facilities been identified?
  • Are the facility audits being conducted at appropriate frequencies based on the risks posed?
  • Are the audits conducted professionally using independent, qualified auditors supported by appropriate audit tools (e.g., protocols, regulatory databases)?
  • Are audit reports issued promptly and are the identified audit findings corrected in a timely fashion?
  • Is there a sense from the outcomes of the audits that the sites are actually improving?

Defining key performance indicators (KPIs) that would help to answer these questions might go a long way toward understanding the value that an audit program provides. This article attempts to do that by posing a set of eight KPIs, which are summarized along with candidate annual performance metrics. Five of the KPIs focus on how well the program is managed, and three focus on the actual outcomes of the audits. The remainder of this article explains the nature of each of the KPIs and their metrics in much more detail. The entire set of KPIs can help to answer the question: “Is the audit program meeting its objectives and is it making a difference?”

LinkedIn | 15 October 2015

Column: Shark-Infested Safety—Re-Evaluating Risk and Finding Freedom From Fear

At a dinner party last weekend, the conversation turned to work. When asked what I did for a living, I replied “I work in safety.” My inquisitor responded promptly with “Ah, I see. So you’re that guy that stops people doing things because they might be a little bit risky … .”

It seems that our reputation continues to precede us wherever we go. How many times have you, as a practitioner or leader in OSH, found the profession at the center of a joke that concludes that we are “risk-averse, action-stopping do-gooders?”

Sure, while I am happy to see people enjoying a good laugh, there’s a massive misconception here.  If we are to truly do our job of protecting people, planet, and profit, we must face toward risk, not away from it.

I was recently asked to give a TED talk to share my views on safety and risk. Using a very personal experience, my central point was that life is not about avoiding risk at all cost but rather it is about developing the confidence to manage risk appropriately and enable great things to happen.

Despite the society most of us live in being safer and more comfortable than ever before, we seem to have built a culture of fear that promotes hesitancy and over-caution. We see this manifesting every day in our working lives. From organizational leaders anxious of anything and everything that has the most remote possibility of causing the slightest injury, to even our professional peers over-zealously ramming the “safety first” mentality to the top of corporate agendas, often causing great rifts as they jam safety head-to-head with productivity.

What happened? Fear. Our perspectives on risk have slid to a point where we often struggle to see the true picture. Media manipulation sideswipes objective thinking and skews robust decision-making. We can all think of stories about “how safety has stopped something:—whether it be hanging flower baskets taken down for fear of them falling on someone’s head or children’s playgrounds razed. The modern mantra associated with these “safety risks” is always “But, what if … ?”

Offshore Energy Today | 15 October 2015

Offshore Safety: Don’t Fall in the Paperwork Trap

Day 2 of Offshore Energy Exhibition & Conference (OEEC) being held in Amsterdam started with a technical session with offshore safety as a topic.

As the EU Offshore Safety Directive came into force in July 2015, this session looked at the consequences of the new directive and shared the experience of different stakeholders in implementing the changes.

It also looked at the challenges of diverging safety regimes between countries, partners, and industry organizations and explored the need for collaboration.

This session was a journey of implementation of the EU Offshore Safety Directive from the perspectives of operator, drilling contractor, and independent verifier.

The session’s moderator was George Galloway, director at WellSpec, and the speakers were Gert-Jan Windhorst, deputy secretary general, NOGEPA; Jürgen Joosten, HSE manager NL operations, Centrica Production Nederland; Ben Oudman, head of gas consulting and services, DNV GL— Oil & Gas Netherlands; and Bram Leerdam, HSE&Q manager, Paragon Offshore.

Windhorst reminded the audience how the industry got here after the Piper Alpha and Macondo accidents. Windhorst said that accidents could be prevented and that the focus should be on smaller companies and operations and on what prevents accidents to happen. Windhorst emphasized: “Don’t fall in the paperwork trap.”

Hydrocarbon Processing | 6 October 2015

CSB Probe of DuPont’s Deadly Chemical Leak Finds Process Safety Lapses

An ongoing investigation by the US Chemical Safety Board (CSB) of the 15 November 2014 toxic chemical leak that killed four workers at DuPont’s insecticide plant in La Porte, Texas, has uncovered flawed safety procedures, design problems, and inadequate planning.

Nearly 24,000 lbm of deadly methyl mercaptan escaped in the middle of the night through two valves in a poorly ventilated manufacturing building. In one area of the plant, operations personnel attempted to clear blocked piping. Later, in a different area, two workers opened valves in response to what they believed was a routine, unrelated pressure problem.

The two workers were killed when liquid methyl mercaptan drained from the open valves, filling the room with toxic vapor. One of those workers made a distress call, and two additional workers died responding to that call.

Ocean News & Technology | 25 September 2015

BSEE Conducts Unannounced Oil Spill Exercise With Gulf of Mexico Operator

Analysts and engineers from the Bureau of Safety and Environmental Enforcement’s (BSEE) Oil Spill Preparedness Division and Gulf of Mexico Region recently conducted an unannounced spill drill of Arena Offshore. The 9-September 1-day exercise simulated a loss of well control event from a platform in shallow water, approximately 35 miles south of Port Fourchon, Louisiana. These exercises test an operator’s response to an incident using their oil spill response plan.

Arena Offshore currently operates more than 30 oil and gas fields on the Gulf of Mexico Shelf, comprising approximately 95 platforms and more than 190 producing wells. The company typically drills 20 to 30 wells per year and has operated more than 200 offshore drill wells in the federal waters of the Gulf of Mexico. Image courtesy of Arena Offshore.

As part of the drill, Arena Offshore was required to respond to a simulated loss of well control due to a potential blowout of the well. During an exercise, an operator demonstrates successful notifications and implements other elements included in its oil spill response plan. The operator worked from its offices in The Woodlands, Texas, while coordinating simulated response actions with its contracted spill response company in Slidell, Louisiana, throughout the exercise. BSEE staff observed the operator’s response in both locations. The US Coast Guard and US Fish and Wildlife Service also attended the exercise.

Offshore Energy Today | 25 September 2015

BSEE Makes Waves for Oil Spill Response Research

Ohmsett, the National Oil Spill Response Research and Renewable Energy Facility, recently hosted a Bureau of Safety and Environmental Enforcement (BSEE)-contracted team of scientists from the New Jersey Institute of Technology (NJIT) who evaluated the ability of the test tank wave generator to produce breaking waves at designated areas in the tank.

BSEE maintains and operates the Ohmsett facility, which is used by numerous government agencies, private companies, academic organizations, and international organizations to conduct oil spill response research, testing and training. According to BSEE, the Ohmsett facility houses the largest wave/tow tank in North America; marine energy-related technologies are also tested there.

BSEE is working to develop a means of generating predictable and reproducible breaking waves in the tank to be able to quantify and compare the effect of the energy from breaking waves on oil mitigation systems and energy-capturing devices. The NJIT team experimented with two methods for generating breaking waves at preset locations and time intervals, while collecting wave data to be analyzed with a fluid dynamics software program.

The Denver Post | 17 September 2015

Feds in Colorado Launch Huge Oil and Gas Worker Safety Study

An unprecedented study of the hazards rooted in America’s largest oil patches will be launched next year by federal health officials in Colorado, who hope to cut the dangers faced by oil and gas workers.

Scientists from the Denver office of the National Institute for Occupational Safety and Health—which is part of the Centers for Disease Control and Prevention—will distribute questionnaires to 500 oilfield workers in North Dakota, Texas, and another unnamed state.

Institute personnel will fan out to so-called “man camps”; training centers; equipment and trucking yards; wellsites; and community centers in oilfield towns.

Oilfield work is considered one of the most dangerous in the country. Between 2005 and 2009, the national occupational fatality rate for the oil and gas industry was seven times higher than the general industry rate and 2½ times higher than the construction industry rate.

Occupational Health & Safety | 14 September 2015

Optimizing Worker Safety: State-of-the-Art Flashlights Protect Against Workplace Hazards

Construction and other industrial professionals who rely on flashlights and lanterns to light their way under low-light conditions have never been safer: Recent advances in lighting technology are offering procurers and users a wide range of new lighting tools and features for keeping workers safer on the job.

The latest hand-held flashlights deliver flood light-type brightness, while new scene lights can adapt for use in any environment. And a growing number of lights offer protection in hazardous environments. Today’s professional-grade lighting products also feature an unprecedented number of safety features and applications.

Arabian Oil and Gas | 11 September 2015

The Economics of Safety at USD-60 Oil

The repercussions of the sharp decline in oil price are being felt globally, and, in this new era of cost-cutting and increasing efficiency, the industry must ensure it keeps its people safe and continues to develop the skills of the workforce.

In times of cost reduction, all too often, and wrongly, training and development budgets are prime targets for budget cuts. But such sweeping cuts in these areas are often born from ignorance of the real harm they cause and only serve as short-term measures. History shows that the true cost of cuts in training come back to haunt us later in the form of skills shortages and wage inflation.

Hazards and risk remain the same regardless of the oil price and a lower BOE must not mean that they are managed differently.

Eco Magazine | 11 September 2015

BSEE To Host International Regulators Forum Offshore Safety Conference

The Bureau of Safety and Environmental Enforcement (BSEE) will host the 2015 International Regulators’ Forum (IRF) Offshore Safety Conference “Risk Reduction: From Desktop to Deck Plate” in Washington, DC, on 19–20 October 2015.

IRF 2015 will focus on moving safety in the offshore petroleum industry from concepts discussed in the boardroom to effective implementation out in the field. It will provide a forum for industry, regulators, citizen stakeholders, and practitioners to openly discuss best practices and industry trends.

The IRF is the international forum of offshore petroleum health and safety regulators whose members are dedicated to the common cause of raising offshore health and safety standards. The IRF exists to drive forward improvements in health and safety in the offshore petroleum sector through information sharing and collaboration in joint programs.

Regulatory officials from all nations with ongoing or proposed offshore oil and gas activity are invited to attend the conference, as are offshore industry representatives, health and safety professionals, members of the academic community and the general public. The purpose of the conference is to share experiences and to explore the applicability of risk reduction techniques used by other industry sectors to offshore energy development activities.

SciTech Connect | 10 September 2015

Column: Health Safety and Environmental Features in Plant Design

Beginners at process plant design tend to see the health, safety, and environmental (HSE) features of a design as something to be sprinkled over the design after it is finished. This is not, however, the way that professionals treat it.

Why is HSE the No. 1 concern? Process engineering (especially water process engineering) saves far more lives than the best medical practitioners ever will, but we can do harm on an industrial scale as well. The worst doctor who ever lived might have killed a few hundred people over a long period of time. Bad engineering could kill tens of thousands of people in a day.

The most pressing argument for the prime importance of safety issues is the more-or-less-universal ethical one that people should not die or be injured so that we can make money. The argument for avoidance of environmental degradation is weaker.

Scott Nadler | 9 September 2015

Column: Safety Is Job 2?

Safety is not Job 1, as so often claimed. If safety were Job 1, we would never leave the house. We would never cross a street. We would never get in a car or on a plane.

If safety were Job 1, companies would go out of business rather than send employees out to drill for oil, mine iron ore, operate a drill press or a band saw, or drive a truck in New Jersey.

Let’s admit it. Doing the job is Job 1. Doing it safely is Job 1½, or Job 2, or Job 1.2, or whatever you want to call it. Are there times that the safety risks are such that the job should not go on? Sure. Is it every employee’s responsibility to make those decisions at times? Yes. Is it leadership’s job to help ensure those decisions are made properly and supported? Absolutely.

Even more importantly, it is leadership’s job to minimize the likelihood that front-line employees and managers have to make those difficult decisions about walking off the job or doing the job unsafely. But it is also leadership’s job to ensure that customers are pleased, shareholders and lenders are satisfied, employees are respected and treated fairly, and laws are obeyed. At different times, those are all Job 1. Balancing those jobs is difficult in the best of times.

That is the challenge leaders face every day, but especially in companies under stress. When the price of your product drops by half, survival is Job 1. We all know it. Companies under stress face huge demands to cut costs, reduce margins of safety, and do whatever it takes to get the job done faster and cheaper.