Speech by Jordan Barab of OSHA on Process Safety Management

At a speech by an OSHA official Jordan Barab,the following have been highlighted by the speaker:
"First: Effective process safety programs and strong workplace health and safety culture are critical for success in preventing catastrophic events.
Second: Industries need to learn from their mistakes. We know the major causes and we know the remedies. Yet lessons learned are not applied and the same problems surface to threaten workers again and again.
Third -- and I'm not telling you anything you don't already know: Numbers don't tell the whole story. Focusing on low DART rates alone won't protect you from disaster. New metrics are needed.
Now, let's explore these ideas a bit more.
Let's look at Concept number one: Effective process safety management systems and workplace safety culture are critical for success in preventing catastrophic events.
In the Baker Panel Report, issued after the BP Texas City explosion, the panel devoted considerable space to the importance of effective process safety systems and the need to build a strong corporate safety culture.
Process safety failures are typically low-frequency but high-consequence events. Our PSM systems have to be strong, and we cannot wait until we have an incident to discover that they were not.
What it comes down to is organizational culture. To paraphrase Professor Andrew Hopkins (whose work I'm sure you are all aware of): Workplace culture is not just an educational program that gets everyone to be more risk-aware and think "safety first." It's deeper and more ingrained than this. Hopkins and the Center for Chemical Process Safety have defined culture as "the way we do things around here."
What I'm talking about is a set of practices that define the organization and influence the individuals who make up the organization. This kind of pervasive, systemic organizational safety culture must come from the top -- and it must be expressed with transformative action, not just simple slogans.
Next: Concept Number Two: Industry must learn from its mistakes.
For three years now, OSHA has had in place a Refinery Process Safety Management National Emphasis Program. We are deeply troubled by the significant lack of compliance we are finding in our inspections, and with the number of serious refinery problems that continue to occur.
Time and again, our inspectors are finding the same violations in multiple refineries, including those with common ownership -- a clear indication that concerns and findings are not being communicated across corporations or throughout the industry or even within different units in the same refinery.
Consistently throughout the course of the Refinery NEP, we have found that over 70 percent of the citations fall into the top four PSM elements:
• Mechanical Integrity
• Process Safety Information
• Operating Procedures
• Process Hazard Analysis
Let's talk about these top four elements:
1. In MECHANICAL INTEGRITY, problems include failure to perform inspections and tests, and failure to correct deficiencies in a timely manner. This is a particular concern given the aging of refineries in the United States.
2. PROCESS SAFETY INFORMATION, including failure to document compliance with Recognized and Generally Accepted Good Engineering Practices to keep process safety information up to date, and to document the design of emergency pressure relief systems.
3. OPERATING PROCEDURES: failure to establish and follow procedures for key operating phases, such as emergency shutdowns, and using inaccurate or out-of-date procedures.
4. PROCESS HAZARDS ANALYSIS, including lack of attention to human factors and facility siting, and failing to address PHA findings and recommendations in a timely manner -- or, all too often, failing to address them at all.
More than a year ago, OSHA sent a letter to every petroleum plant manager in the country, informing them of these frequently cited hazards. Yet, a year after this letter went out, our inspectors continued to find the same problems in many facilities.
And, finally: Concept Number Three: The problem with numbers.
In any business or organization, one of the problems we find when trying to measure performance is determining how and what we measure.
Unfortunately, as we've discovered, having good numbers on your OSHA 300 logs doesn't correlate with having an effective process safety program.
The classic example of this is BP-Texas City, which had very good injury and illness numbers prior to the 2005 explosion that killed 15 workers and injured 170 others. This tragedy, of course, revealed serious process safety and workplace culture problems at the facility despite the good numbers the company had on paper.
It was noted in press reports that many of the workers killed at BP Texas City had just finished a meeting that touted their safety record. More recently, it was noted in the press that BP executives were on the Deepwater Horizon drill in platform in the Gulf of Mexico, celebrating their excellent safety record shortly before the explosion and fire that led to the deaths of 11 workers. In the days following that catastrophe, company officials continued to wave their low injury and fatality rates as a defense while workers widows planned funerals.
There's a message here: Boasting about favorable safety rates while workers are dying doesn't make a company look like a serious employer; and trade organizations that give awards to their members based solely on a lack of slips, trips and falls doesn't make them look like they are seriously addressing serious problems.
Don't misunderstand me: We need to keep reporting and tracking the numbers -- DART rates are useful -- but employers must not let those numbers lull them into a false sense of security. Looking only at these numbers doesn't warn us about pending doom from cutting corners on process safety
To ensure strong PSM systems, we need to do a better job of identifying useful leading indicators. We all recognize the stock market's investment warning that "past performance is no guarantee of future success." This also applied to the low-frequency, high-consequence events that process safety programs guard against.
The chemical and petrochemical industries must continue to develop and track leading indicators to measure the performance and continuously improve process safety management systems".
In my experience, the points that have been highlighted by the speaker are time and again found lacking in many industries.
Read the full speech in this link