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Management Discipline: Defining a Process Safety Strategy

Jerry J. Forest
1601 W. LBJ Freeway, Dallas, TX 75234

Prepared for Presentation at
American Institute of Chemical Engineers
2013 Spring Meeting
9th Global Congress on Process Safety
San Antonio, Texas
April 28 May 1, 2013


AIChE shall not be responsible for statements or opinions contained
in papers or printed in its publications
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Management Discipline: Defining a Process Safety Strategy

Jerry J. Forest
1601 W. LBJ Freeway, Dallas, TX 75234

Keywords: Conduct of Operations, COO, Operating Discipline, OD, Engineering Discipline
ED, Management Discipline, MD, strategy, strategic planning


We often associate operational discipline with conduct of operations and define discipline as the
tools to achieve repeatable results. While discipline in operations is primarily focused on the
operator, engineers and management contribute to the success in achieving consistent results. A
Plan-Do-Check-Act (PDCA) model, or Deming Cycle, can be used to represent the relationship
among operational, engineering, and management disciplines. The management discipline part
of the cycle involves making decisions (act) based on the output of the operations, and planning
for success.
This paper will describe a modified strategic business analysis planning tool that managers can
apply to process safety in order to achieve a desired vision and objective. Too often we are
reactive to incidents and create activity lists from year to year in order to achieve objectives and
goals. The process safety strategic business analysis tool is a structured approach of data
analysis. It helps us to understand the companys internal and external environment in order to
set strategic alternatives that will bring a company from its present state to the desired future
state. By planning for and following a strategy, consistency in operations is achieved, and
repeatable results can be obtained.

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1. Introduction

In order to be successful in reducing process safety incidents, the causes of those incidents must
be understood and eliminated. Since our manufacturing facilities are designed and operated by
people, many of the causes are due to human error. Conduct of operations (COO) concerns the
cultural aspects of an organization that are in place to define structural operational tasks designed
to ensure that tasks are done correctly each time they are performed [1]. Management defines
the process safety culture by setting expectations, providing accountability for performance, and
allocating resources to achieve that performance [2]. Management must plan for success and set
the strategic direction. This includes the COO tasks that are designed to eliminate human error.

This paper discusses a modified strategic business analysis process and tools to help the process
safety manager define strategic alternatives for continuous improvement.

2. Management Discipline Model

COO is most often associated with the tasks that operators do when operating a processing or
manufacturing facility. These tasks are actually elements of operating discipline (OD). They
include making shift relief, writing shift notes, evaluating equipment, proper communication,
and giving and receiving operating instructions. Haesle et al., and the Center for Chemical
Process Safety (CCPS) concept book Conduct of Operations and Operational Discipline present
good overviews of OD [3][1].

But COO is more than OD. It also includes an element that consists of technical evaluation of
process data, including data collected by operators in evaluation rounds and shift notes. These
COO activities are often called engineering discipline (ED). Engineers or technical people bring
predictability to OD by checking the human performance and acting on that data [4].

Managers often make the decisions to act on the data collected in OD and ED. In addition to
acting on the data, managers should be planning for continuous improvement based on that data.
Management discipline (MD) describes the activities that managers do to act on data and plan for
continuous improvement in COO [4].

COO is therefore a combination of OD, ED, and MD; the combination of which describe a Plan-
Do-Check-Act (PDCA) cycle as shown in Figure 1, first published in Process Safety Progress in
2012 [4]. When each element is in place, human error causes of incidents can be reduced.

3. Process Safety Strategic Planning

Planning for success can take many forms. It seems that often we are reactive to incidents and
create long lists of items to correct. By being busy we think that we must be improving
something. Another complaint often heard is that it is difficult to justify capital or expense
spending for risk reduction. One cause might be that as technical people, we tend to
communicate in technical terms rather than in business terms most often used by the decision
makers who control budgets.

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Figure 1: Conduct of Operations Model.

A way for mangers to plan for continuous improvement, break from the reactive cycle of activity
lists, and provide a tool that is understood by business managers is by using a strategic business
analysis (SBA) applied to process safety planning.

3.1 Strategic Business Analysis (SBA)

Strategic planning is having an understanding where you are as an organization; setting a vision
for where you want to be; and developing strategic alternatives on how to achieve that vision.
There are many tools that business managers use to understand the internal and external business
environment, the competition, and other forces that might affect the vision or strategic
alternatives. In this example the term SBA is used to collectively refer to the tools used to set the
strategic plan, and these come from different sources and experience [5][6]. Analogous to Lean
Six Sigma, no one tool is better than another and different tools might be used in different
situations. For purposes of this paper, an 8-step process safety SBA is described. Table 1
illustrates the steps. The inputs, outputs, and process methodology for each are described and a
case study is given at the end.

Table 1. The Process Safety SBA Process
Step Description Purpose
1 Beliefs Align organization on fundamentals
2 Future State Answers where we are going
3 Data Analysis Answers where we are at
4 Risks Analysis Pressure test; what could go wrong
5 Strengths, Weakness, Opportunities, Threats (SWOT) Defines what we think of ourselves
6 Strategies Preferred path and alternative paths
7 Action Plans How we get there
8 Monitor & Improve Check that plans are working

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3.2 Beliefs & Future State

In order to make a strategic plan, an understanding of the existing organization is obtained to
align the planning team on the fundamentals of where the organization is and how much work is
required to achieve some future state. Therefore, define and write down what the organizational
beliefs are.

For example, does your company really believe that all process safety incidents are preventable?
If not, define exactly what the belief about incident prevention is so that you will align actions
consistent with that belief. Other topics to examine in beliefs include: management systems,
people and training, organizational structure, and process safety leadership. Use a simple
brainstorming process. The output of this step provides a foundation for future steps, and helps
define the organizations leveraging beliefs.

All strategic planning processes should include some definition of the desired future state, or
vision. As Yogi Berra is often quoted, If you dont know where you are going, you might wind
up someplace else. The initial inputs to this process are a definition of company constraints
(capital and expense, resources, etc.) and alignment with the overall company vision. The
process can be a brainstorm session, or simply the given direction of senior management. The
output is more than the vision, however. It should also include a consensus belief of where the
organization believes it is going relative to peers, key performance indicator(s) (KPIs) to
measure progress, and possible future scenarios that affect achieving the vision.

3.3 Data, Risk, and SWOT Analysis

3.3.1 Data Analysis
Data can come from several sources including process safety audits, incident investigation root
cause analysis, and other leading indicators. It is not uncommon to complete an audit, develop a
gap closure plan, and complete it. Similarly, after an investigation of a process safety incident is
complete, we develop solutions that address causes and complete those actions. By stepping
back and looking at this data as a whole, we can quickly identify common failure modes and
management system weaknesses. Analysis of these lagging indicators should quickly surface the
low hanging fruit from which to develop a strategy for improvement.

A methodology to group and objectively analyze and identify systemic management system
failures was published in Process Safety Progress in 2011 [7]. It consists of structuring audit
reports in a database type structure such that the subjective findings can be queried into logic
groups. These groups can be used to describe the common systemic management system

A simpler and more common type of data analysis is of the lagging indicators. Most companies
document the results of incident investigation with various causal factor analyses. Various
descriptive statistics coupled with graphical analysis can be performed on groups of data that will
point to areas for improvement [8].

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3.3.2 Risk Analysis
Understanding hazards and risks should be a part of any process safety strategic analysis. The
inputs include the key beliefs developed earlier, industry data, and major risks from process
hazard analysis. Typically, this tool involves a detailed look at data in order to expose scenarios
that must be avoided, the critical process safety success factors, and what the competition is
doing to be successful.

3.3.3 SWOT Analysis
A SWOT analysis is used in strategic planning to get a better understanding of both the internal
and external business environment. Examination of a companys strengths and weaknesses
results from analysis of existing internal beliefs. Similarly, analysis of the external business
environment exposes external threats and opportunities.

This same type of analysis can be performed on process safety systems in order to surface
existing beliefs in the company. In fact, by identifying beliefs, we are getting an idea of the
process safety culture since culture is defined as a commonly held set of values, norms and
beliefs [1]. Methodology to complete this type of survey includes use of a 5 point Likert scale
and has been described in Process Safety Progress [9].

3.4 Develop Strategic Alternatives, Action Plans & Performance Monitoring

The results of the combined data, risk and SWOT analyses should show obvious areas for
improvement. At this point, the strategic development team should analyze what strategies have
worked in the past, and which have failed. Also note that the analysis will surface several areas
to improve and therefore the team should develop strategic alternatives. Future conditions and
assumptions may change. The organization needs to be in a position to change the strategy to
match current conditions.

Note that strategic alternatives describe the overall improvement direction. Action plans define
the activities aligned with the strategy, key milestones and KPIs to track success. The final step
in execution of the strategy is monitoring performance so that changes in strategy and action
plans can be made to optimize performance.

3.6 Process Safety SBA Summary

Table 2 summarizes the key inputs, processes, and outputs for each SBA step described.

Table 2. SBA Inputs, Processes, & Outputs
Step Inputs Process Outputs
Beliefs Experience, trends, fundamentals Brainstorm Common foundation for future
work; Leveraging beliefs
Future State Definition of company
constraints, existing company
Brainstorm Consensus beliefs of future
scenarios, KPIs, overall vision
Data Analysis Process Safety audit data, incident
investigation root cause analysis,
leading indicator data
Descriptive statistics,
Pareto and other
graphical analysis
Common failure modes, systemic
Risks Key beliefs, industry data, major Sub-team analytical Scenarios to avoid, critical process
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Analysis risks from PHA work safety factors, successful
Results of the data and risk
Survey Key opportunities and strengths,
competitive assessment, leveraging
areas for improvement
Strategies Results of data, risk and SWOT
Assess past failures and
successes, develop
strategic alternatives,
team meeting format
Defined process safety strategy and
strategic alternatives
Action Plans Strategic Alternatives Team meeting format Milestones, KPIs, action plans,
communication plan
Monitor &
Strategy, action plan Existing performance
monitoring processes
Update plans or strategy or choose
new strategic alternative based on

4. COO Strategic Planning Case Study

This SBA strategic planning process was used at Celanese to determine the process safety
elements that needed most attention for the largest improvement. Discussed here are a few of the
outputs from the tools used and one year results.

Most interesting were the results of the data analysis combined with the SWOT analysis.
Descriptive statistics were applied to three years of loss of primary containment (LOPC) root
cause studies. In summary, about half of all causes were human error, COO related. Of
particular concern are the incidents involving operator line-up, operator evaluation, and failure to
respond to alarm; all direct OD topics. This analysis also surfaced two additional areas for
improvement: Mechanical integrity human error failures, and the need for improvement in
incident investigation and assignment of causes. Audit finding analysis confirmed management
system weaknesses in some areas of our COO implementation. Figure 2 shows a high level
Pareto chart of the results of this analysis.

Figure 2: LOPC Causes Conduct of Operation Related
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Analysis of lagging indicators also showed that for the time period studied, 80% of all incidents
occurred at 5 sites.

The SWOT analysis surfaced a surprising result that the company, across the globe, indicated
that there was an opportunity for improvement through internal networking with other sites and
improving the process safety competency at the sites. The SWOT also showed a weakness in the
area of process safety training and the need for improvement in how corporate procedures are
executed at the site level. Once the strategy was set, the SWOT analysis helped define the action

The data analysis gave rise to several strategic alternatives for process safety improvement.
Table 3 illustrates four strategic alternatives for improvement.

Table 3. Strategic Alternatives
Objective Strategy Action Plan
Reduce # incidents Human error reduction
1. COO workshops
2. COO Networks
3. Lessons Learned Project
4. Focused Site Support
Improve process safety
Management system
1. Reformat procedures
2. Improve management process
Improve leadership
1. Targeted annual training
2. New leader process safety
certification process
Improve operator
1. Improve and rollout process safety
training for front line supervisors,
operators and crafts.

Of course, each action is detailed with specific assignments, milestones, and KPIs.

Of particular interest for COO is the large number of incidents that are directly attributable to
human error and the development of a targeted action plan to reduce human error. The overall
improvement plan involved collection of COO best practices from across the company and
development of a 2 day workshop to share those practices. Participants were asked to complete a
gap analysis of their own site practices to the best practices and develop a closure plan specific
for their site. We then followed up the action plans with network sharing of the practices,
successes, and failures.

The result of implementation of the human error reduction strategy and action plans is reduction
of COO related causes for process safety incidents from about half of the incidents to about one
third in a one year time period. Most notable were improvements in operator line-up causes with
various targeted programs on walk-the-line and pre-job focus on line-ups. While these results
are encouraging, we recognize the need for continuous monitoring to show continued
improvement, and make minor changes to the action plan and path forward based on the current

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5. Conclusion

Conduct of operations is more than the operational discipline topics. In order to be most
effective, it should include a management discipline element as well. The MD element acts on
OD data and plans for continuous improvement.

A modified strategic business analysis can be used for process safety strategic planning. By
analyzing incident and audit data, the common management system failures and human error
related failures can be surfaced so that management can target specific COO areas for
improvement. Tools such as risk and SWOT analysis will surface effective ways to implement
action plans based on organizational beliefs and what has worked before.

Since the second law of thermodynamics is still in place, it requires energy to monitor, maintain,
and make changes to the strategic plan in order to achieve continuous improvement in process

6. References

[1] Center for Chemical Process Safety, Conduct of Operations and Operational Discipline,
American Institute of Chemical Engineers, Newark, NJ. 2011.
[2] OECD Environment, Health and Safety Chemical Accidents Programme, Corporate
Governance for Process Safety, June 2012
[3] J. Haesle, C. Devlin, and J. McCavit. Improving process safety by addressing the human
element, Process Safety Prog 28 (2009), 325-330.
[4] J. Forest. Management Discipline. Process Safety Prog 31 (2012), 334-336.
[5] Krajewski & Ritzman, Operations Management Strategy and Analysis, 4
ed., Addison-
Wesley Publishing Company, Inc., Massachusetts, 1996
[6] Hutt & Speh, Business Marketing Management A Strategic View of Industrial and
Organizational Markets, 5
ed., The Dryden Press, 1981
[7] J. Forest. Objective Analysis of Process Safety Audit Data with Microsoft Access.
Process Safety Prog 30 (2011), 221-231.
[8] J. Forest & K. Kessler. Correlating Process Safety Leading Indicators with Performance.
Process Safety Prog (2013), on-line edition.
[9] J. Forest. How to Evaluate Process Safety Culture. Process Safety Prog 31 (2012). 195-