ESSENTIAL PRACTICES FOR CREATING, STRENGTH ENING, AND SUSTAINING PROCESS SAFETY CULTURE P U B L I C AT I O N S AV A I L AB L E F R OM T H E C E N T E R F O R C H E M I C A L P R O C E S S S A F E T Y of the AM E R I C AN I N S T I T U T E O F C H E M I C A L E N G I N E E R S ESSENTIAL PRACTICES FOR CREATING, STRENGTH ENING, AND SUSTAINING PROCESS SAFETY CULTURE C E N T E R F O R C H E M I C A L P R O C E S S S A F E T Y of the AM E R I C AN I N S T I T U T E O F C H E M I C A L E N G I N E E R S New York, NY WILEY This edition first published 2018 © 2018 the American Institute of Chemical Engineers A Joint Publication of the American Institute of Chemical Engineers and John Wiley & Sons, Inc. All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, except as permitted by law. 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Description: New York, NY : American Institute of Chemical Engineers, Inc. : John Wiley & Sons, Inc., 2018. | Includes bibliographical references. | Identifiers: LCCN 2018023924 (print) | LCCN 2018024176 (ebook) | ISBN 9781119515142 (Adobe PDF) | ISBN 9781119515173 (ePub) | ISBN 9781119010159 (hardcover) Subjects: LCSH: Chemical engineering--Safety measures. Classification: LCC TP150.S24 (ebook) | LCC TP150.S24 E87 2018 (print) | DDC 660/.2804--dc23 LC record available at https://lccn.loc.gov/2018023924 Cover images: ©jimmyjamesbond/iStockphoto; ©crisserbug/iStockphoto Cover design by Wiley Printed in the United States of America 10 9 8 7 6 5 4 3 2 1 Disclaimer It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry; however, the American Institute of Chemical Engineers (AIChE), its consultants, the AIChE’s Center for Chemical Process Safety (CCPS) Technical Steering Committee and the Process Safety Culture Subcommittee members, their employers, their employer’s officers and directors, AcuTech Group, Inc. and its employees, and Scott Berger and Associates LLC and its Principal, do not warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in this book. As between (1) the AIChE, its consultants, the CCPS Technical Steering Committee and Subcommittee members, their employers, their employer’s officers and directors, AcuTech Group, Inc. and its employees, Scott Berger and Associates LLC and its Principal, and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequence of its use or misuse. | vii TABLE OF CONTENTS SUPPLEMENTAL MATERIAL AVAILABLE ON THE WEB XIII ACRONYMS AND ABBREVIATIONS XV GLOSSARY XVII ACKNOWLEDGEMENTS XIX PREFACE XXIII NOMENCLATURE XXVII EXECUTIVE SUMMARY XXIX 1 INTRODUCTION 1 1.1 Importance of Process Safety Culture 1 1.2 Definition of Process Safety Culture 2 1.3 Warning Signs of Poor Process Safety Culture 11 1.4 Leadership and Management Roles and Responsibilities 13 1.5 Organizational Culture, Process Safety Culture, and Business Success 15 1.6 Corporate Climate and Chemistry 17 1.7 Summary 17 1.8 References 20 2 PROCESS SAFETY CULTURE CORE PRINCIPLES 23 2.1 Establish an Imperative for Process Safety 25 2.2 Provide Strong Leadership 29 2.3 Foster Mutual Trust 32 2.4 Ensure Open and Frank Communications 35 viii | Table of Contents 2.5 Maintain a Sense of Vulnerability 42 2.6 Understand and Act Upon Hazards/Risks 49 2.7 Empower Individuals to Successfully Fulfill their Process Safety Responsibilities 54 2.8 Defer to Expertise 57 2.9 Combat the Normalization of Deviance 59 2.10 Learn to Assess and Advance the Culture 67 2.11 Summary 72 2.12 References 73 3 LEADERSHIP FOR PROCESS SAFETY CULTURE WITHIN THE ORGANIZATIONAL STRUCTURE 77 3.1 Definition of Process Safety Leadership 77 3.2 Characteristics of Leadership and Management in Process Safety Culture 83 3.3 Leadership Vs. Management 96 3.4 Consistency of Process Safety Messages 97 3.5 Turnover of Leadership, Succession Planning, and Organizational Management of Change 98 3.6 Summary 103 3.7 References 104 4 APPLYING THE CORE PRINCIPLES OF PROCESS SAFETY CULTURE 107 4.1 Human Behavior and Process Safety Culture 107 4.2 Process Safety Culture and Compensation 109 4.3 Process Safety Culture and Ethics 113 4.4 External Influences on Culture 124 4.6 Summary 153 Table of Contents |ix 4.7 References 154 5 ALIGNING CULTURE WITH PSMS ELEMENTS 157 5.1 Senior Leader Element Grouping 160 5.2 Risk Management-Related Element Grouping 170 5.3 Process-Related Element Grouping 181 5.4 Worker-Related Element Grouping 190 5.5 References 201 6 WHERE DO YOU START? 203 6.1 Introduction 203 6.2 Assess the Organization’s Process Safety Culture 204 6.3 Improving the Process Safety Culture of the Organization 225 6.4 Summary 236 6.5 References 237 7 SUSTAINING PROCESS SAFETY CULTURE 239 7.2 Sustainability of Process Safety Culture 241 7.3 Process Safety Culture and Operational Excellence 248 7.4 Summary 251 7.5 References 253 APPENDICES 255 Appendix A: Echo Strategies White Paper 257 Appendix B: Other Safety & Process Safety Culture Frameworks 259 B.1 The Seven Basic Rules of the USA. Naval Nuclear Propulsion Program 259 x | Table of Contents B.2 Advancing Safety in the Oil and Gas Industry – Statement on Safety Culture (Canadian National Energy Board) 261 B.3 References 271 Appendix C: As Low as Reasonably Practicable 273 C.1 ALARP Principle 273 C.2 References 275 Appendix D High Reliability Organizations 277 D.1 The HRO Concept 277 D.2 References 286 Appendix E: Process Safety Culture Case Histories 287 E.1 Minimalist PSMS 287 E.2 – Peer Pressure to Startup 288 E.3 Taking a Minimalist Approach to Regulatory Applicability 290 E.4 Not Taking a Minimalist Approach to Process Safety Applicability 291 E.5 What Gets Measured Can Get Corrupted 291 E.6 KPIs That Always Satisfy 293 E.7 Abusing ITPM Extensions/Deferrals 295 E.8 The VPP Defense 296 E.9 Double Jeopardy 297 E.10 Best Case Consequences 298 E.11 New Kid in Town 299 E.12 The Blame Game 299 E.13 Conflicts of Interest 300 E.14 No Incidents? Not Always Good News 301 Table of Contents |xi E.15 Check-the-Box Process Safety Management Systems 302 E.16 There’s No Energy for That Here 302 E.17 Not Invented Here 303 E.18 PHA Silos 304 E.19 Knowing What You Don’t Know 305 E.20 Bad News is Bad 306 E.21 The Co-Employment Trap 306 E.22 Stop Work Authority/Initiating an Emergency Shutdown 307 E.23 SWPs by the Numbers 308 E.24 Incomplete MOC 309 E.25 Post-MOCs 310 E.26 Mergers & Acquisitions 310 E.27 Poor Understanding of Hazard/Risk Leads to an Even Worse Normalization of Deviance 311 E.28 How Many Explosions Does It Take to Create a Sense of Vulnerability? 313 E.29 Disempowered to Perform Safety Responsibilities by “Omniscient“ Software 315 E.30 What We Have Here is a Failure to Communicate 316 E.31 Becoming the Best 317 E.32 High Sense of Vulnerability to One Dangerous Material Overwhelms the Sense of Vulnerability to Others 319 E.33 Not Empowered to Fulfill Safety Responsibilities? Maybe You Were All Along 321 E.34 Normalization of Ignorance 323 E.35 Spark and Air Will Find Fuel 324