Plant safety jeopardized by misunderstanding of risk

Why process safety must come first

21 April 2008 00:00  [Source: ICB]

The former chairwoman of the US chemical safety watchdog says firms focus too much on personal injury at the expense of catastrophic accident risk

Guest columnist
Carolyn Merritt/Consultant

DURING THE many years I served in environmental health and safety (EHS) management in industrial settings, I repeatedly observed a strange phenomenon.

I worked with many managers and executives who understood that proper fiscal oversight and control required proper accounting of cash flow, income and accounts payable. They also understood the need for control systems to prevent fraud, theft and other practices that have caused fiscal ruin in corporations. They accepted and complied with regulations written to ensure that corporations certify compliance with these generally accepted practices to provide accurate reporting, and to control risk to their stock holders and to the government.

TRACKING INJURIES IS NOT ENOUGH

However, I was met with stares of disbelief when I explained to these same managers and executives that proper management of safety risk required not only the tracking of employee injury rates (the Lost Time Injury Rate, or LTIR) or even all injury rates, but also the installation and tracking of management systems to assure that all safety and process risks were identified and controlled.

The cost for controlling process and safety risk was just too great for operational managers, and the ability to track such items too time-consuming. In their view, the safety department should focus on keeping down the costs of workers' compensation and track the LTIR to keep it below industry averages.

Process risks remained unaddressed or untracked.

Now, I admit that it has been a few years since I was part of the industrial community. However, in my years as chair of the US Chemical Safety and Hazard Investigation Board (CSB), I oversaw about 40 investigations of industrial catastrophic incidents where facilities were destroyed and employees killed or seriously injured. In just about every incident, the various cause factors included the failure to investigate prior, similar warning events at the facility.

The value of, and need for, good management systems tracking to prevent catastrophic incidents was emphasized over and over in the CSB reports.

Managers of destroyed facilities often indicate to investigators and others that the low injury incident rate of a facility is proof that their safety record is excellent, even though poor training, inadequate written procedures and the failure to investigate near-miss incidents were prevalent, and the facility and its employees suffered a devastating, life-changing event that could have been predicted and prevented. They quote the number of personal injuries experienced on the shop floor - not a measure of the risk of catastrophe resulting from process failures in their facilities.

For example, interviews were recently reported with the management of the Imperial Sugar refinery in Georgia, where a horrific sugar explosion claimed the lives of 13 workers and left many ­others in critical condition. The managers noted that they had a good safety record and did ­everything that was required. Was the ­explosion that destroyed their facility ­therefore unavoidable?

No. Sugar-dust explosions in the sugar industry are not a new phenomenon, a fact of which the management seems to have lost sight. The information needed to prevent this kind of tragedy is readily available and has been for many years. The National Fire Prevention Association and many international coding agencies have excellent code documents that provide engineering and management standards to control such hazards. Not one of them is tied to personal injury rate, although at many companies it is often the only safety number tracked, and the Occupational Safety and Health Administration regulations are the only code followed, if any is followed at all.

The management of the Imperial Sugar refinery appears to have been under the misapprehension that the control of process risk is reflected in shop floor safety numbers. However, LTIRs only reflect control of common work hazards such as confined space, lock out, slips, trips and falls - not process hazard risks.

PROTECT YOUR ASSETS

The investigation by the CSB of the 2005 explosion at the massive BP refinery in Texas City, Texas, vividly revealed the danger of focusing on personal injury safety statistics and ignoring the components that build good management and control of catastrophic process risk. As a result of this investigation, as well as many others, the CSB has recommended that the industry develop leading indicators for predicting risk of catastrophic events rather than lagging indicators such as LTIRs.

The most important indicator is, in my opinion, a system for identifying and reporting abnormal process situations. This one factor would uncover many hazards that could lead to a catastrophic event. Tracking and correcting such hazards would reduce the potential for destructive incidents such as those investigated in the past several years. Awareness of the risk of catastrophic events will necessarily lead any prudent manager to implement corrective actions to prevent such an event from reoccurring or leading to a more serious and deadly incident.

Managers who rely only on the LTIR are not using the most important tool available to protect the assets they have been entrusted with. Their fiduciary and physical assets and their employees are at great risk of loss, and it makes no more sense than forgoing standard practices that prevent fraud and financial loss, and failing to ­identify and control leading indicators of fiscal disaster before a potential disaster becomes a reality.

 

Carolyn Merritt chaired the the US Chemical Safety and Hazard Investigation Board from 2002 to 2007. She has held environmental and safety management positions with Champion International Corporation and the Tennessee Chemical Company, and served as senior vice president for environment, health, and safety for IMC Global from 1994 to 2001.