Hydrocarbon Processing - February 2021 - 77

Environment and Safety
correct responses. This provides a foundation for thoughtful compliance. A summary of the OD program characteristics and
their relationships is shown in FIG. 3.

IMPLEMENTING EFFECTIVE
OD PROGRAMS
Implementing an effective OD program or improving an existing program
depends on the starting point and intended goals. Key activities, which will be
discussed in following sections, include:
1. Focusing on OD improvement
2. Raising awareness and value
for OD
3. Evaluating OD performance
4. Identifying, prioritizing
and pursuing improvement
opportunities
5. Sustaining and renewing
OD program activities.
Focusing on OD improvement. Management should consider improving OD
for the following reasons:
* A required part of effective safety
programs, as shown in FIG. 1
* Poor performance either
creates the desire to improve
or allows continued problems
* Good performance creates the
desire to avoid complacency.
Benefits of an effective OD program
include:2,8
* Process (and other) hazards
and risks are identified, evaluated
and managed
* Equipment and facilities are properly
designed, operated and maintained
* Management systems are well
designed, implemented, executed
and supported
* Operating problems, incidents
and near misses are consistently
investigated and addressed.
As a result, process safety, environment,
health and safety (EHS) performance,
productivity and cost, and product quality
performance should improve. To achieve
or improve these results, appropriate
management focus on improving OD is
required to get started due to the need to:2
* Demonstrate personal attention
and commitment to the effort
* Provide appropriate resources to
support program execution
* Develop effective processes to
facilitate employee awareness,
understanding and involvement

Leadership focus
Employee engagement

Knowledge
Commitment

Procedural principles

Following effective
systems and procedures

Awareness
Housekeeping and
workplace standards

Organizational OD
Resources, systems
and environment

Personal OD
Actual work process

Performance
Desired results

FIG. 3. Relationship of OD program characteristics.2

* Implement, improve, standardize
and maintain needed systems
and activities
* Support, evaluate and monitor
performance, including frequent
observation of work tasks.
OD-related requirements should be
added to appropriate process safety, incident investigation, auditing, and other
standards and guidelines to support consistent implementation of OD activities.
For example, incident and near-miss investigation standards should be revised to
include the identification of OD-related
causal factors, which can be used to help
reduce incident frequency and identify
potential OD improvement opportunities. OD learning opportunities can be
also identified from investigating EHS,
quality, productivity and other operational problems, in addition to process safety.
Failure to implement or sustain effective OD programs can be catastrophic.
For example, the 2005 Texas City refinery explosion investigated by the U.S.
CSB16 resulted in 15 fatalities, 180 injuries and major facility damage, as shown
in FIG. 4. While the CSB identified many
causes, some of the OD issues identified
in the CSB investigation of the incident
are highlighted below. Subsequent investigations17 of several company refineries
found " instances of a lack of OD, tolerance of serious deviations from safe operating practices, and apparent complacency toward serious process safety risks
at each refinery. "
Examples of OD issues identified by
the CSB refinery investigation include:16
* Management did not emphasize
the importance of following
procedures as evidenced by its
(1) lack of enforcement of the

FIG. 4. The aftermath of the 2005 Texas City
refinery explosion and fire.16

MOC policy, (2) acceptance of
procedural deviations during past
startups, and (3) failure to ensure
that procedures remained up to
date and accurate, contributing to a
work environment that encouraged
operations personnel to deviate
from procedures.
* Inadequate training for operations
personnel contributed to causing
the incident. The hazards of unit
startup and for abnormal situations
were not adequately covered in
operator training.
* A " check-the-box " mentality
was prevalent, where personnel
completed paperwork and checked
off on safety policy and procedural
requirements even when those
requirements had not been met,
contributing to a culture of " casual
compliance. "
* Managers did not effectively
implement their pre-startup
safety review policy to (1) ensure
nonessential personnel were
removed from areas in and around
process units during startups,
and (2) verify the adequacy of all
safety systems and equipment,
Hydrocarbon Processing | FEBRUARY 2021 77

Hydrocarbon Processing - February 2021

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