PSM and PDCA cycle

The PDCA cycle is the core of any management system. I have seen a common trend from investigating root causes of many chemical plant process incidents - it appears that many of the root causes are due to following the PDCA cycle in a different way: DCA,no P -DO, CHECK, ACT and No PLAN! Fire fighting efforts take place to immediately attack an issue. Productivity, cost cutting and efficiency improvements often take place without undergoing the management of change process. This is why I feel that while certifications to OHSAS 18001, ISO 14001, Responsible Care etc are good, the sustainability of such certifications become questionable. This is evidenced by fatal accidents in companies that are certified. How do we solve this issue? I believe that the onus lies with the top management. If top management are clear about process safety and its implications, then you do not need any system at all! Unfortunately, there is a huge knowledge deficit about the technical aspects of running a chemical plant and the importance of PSM. Recently I had implemented PSM in a pesticide manufacturing unit where the head of the unit was a hardcore experienced chemical engineer. His understanding of the technical nitty gritties of PSM helped me greatly during the implementation. I will end my ranting by repeating two things that Dr Trevor Kletz has said and is highly relevant to Process safety management: 1.Walk the talk! 2.Keep it simple!