On Rolling HSEMS Procedures

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					                  On Rolling Out HSEMS Procedures
                           The STR Process
                           Dr. Tariq A. Aldowaisan
                          CSP, CQM/OE, CQE, CQA

              Gulf Lead Consultants – Industrial & Management
                            tariq@glc-im.com

Abstract

Procedures are a key component of any HSE Management System (HSEMS)
documentation structure; they represent the "HOW-TO" of the Expectations of
the HSEMS Standards. They link between "WHAT" is required and
"PROOFS" of compliance. Therefore, any weakness in HSEMS procedures
would lead to chaotic implementation, and eventually a poor HSE
performance.

Rolling out HSEMS procedures is not an event; rather it is a PROCESS. In
this paper, we describe a proposed Setup-Train-Reinforce (STR) process for
rolling out HSEMS procedures. In preparing this manuscript, the author
reflects on his extensive practical experience in assisting with the rolling out of
HSEMS procedures in local major oil companies through company-wide
seminars.

A. Importance of Procedures

Procedures are a key component of any HSE Management System structure.
They link between the EXPECTATIONS and the RECORDS and REPORTS
(Figure 1). The expectations are general requirements or standards that detail
the HSE Policy Statement. Procedures, in turn, describe how expectations are
to be met or realized in the organization. Implementation of the procedures
result in generating reports and records (i.e. completed forms). Records and
reports are invaluable tools for management, auditors, regulators, insurance
people, and investigators; they are used to verify compliance and measure
performance.




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                                   Figure 1

Procedures are usually classified as per elements of the HSEMS. A
procedure may address part-of, one, or more expectation. For example, a
Permit to Work Procedure in API 9100 EHSMS Model addresses Element 8:
"Operations, Maintenance & Management of Change", Expectations 2: "EHS
rules and a work permit system are in place, communicated, documented,
and enforced …"; whereas a single procedure on Incident Reporting and
Investigation may addresses Element 11: "Incident Investigation, Reporting,
and Analysis" in its entirety.


The role of the majority of HSE procedures is to specify the necessary
provisions to mitigate/control the risks associated with hazardous activities.
For example, the purpose of A Permit to Work (PTW) Procedure is to control
the risk associated with non-routine work. Note that compliance with a PTW
procedure for hot work, for example, would result in a completed work permit
(i.e. generation of a record). The work permit record would then be used to
verify compliance. Some records are used to calculate HSE performance
metrics; e.g. incident reporting records.

     It is clear that procedures play a key role in ensuring successful
                        implementation of the HSEMS.

B. Common Shortcomings & Countermeasures

Procedure documents may suffer from shortcomings related to content or
format.

Content

   Procedure is cumbersome/ overprotective.
   Procedure is inaccurate/ under protective.


                                              On Rolling-Out HSEMS Procedures, 2 of 10
     Procedure is invalid/ impractical.

An overprotective procedure is generally long and cumbersome to implement.
Employees will either not have time to read them, or they would carelessly
complete their associated forms. A common complaint of employees is that
they don't have time to attend to their duties due to the time required to
implement such procedures.

         HSE professionals need to understand that a cumbersome
    overprotective procedure is as bad, if not worse, than a procedure that
          falls short of providing the necessary level of protection.

Inaccuracy or inadequacies of procedures commonly result from lack of
knowledge of HSE industry and regulatory standards. For example, when
developing an environmental impact assessment procedure, it is critical to be
aware of EPA requirements. Similarly, it would be useful to learn of OSHA
Standard 1904 when preparing a procedure on Incident Reporting and
Investigation.

Invalid procedures are impractical. They tend to have provisions or
requirements that are difficult to implement by responsible parties. For
example, a permit to work procedure that requires an operator to do
preparatory activities for radiography work or conduct gas testing may not be
realistic, in light of the operator's current level of competency.

Format

     Procedure does not follow standard format.
     Procedure is difficult to read.
     Procedure is long.

It is important that procedures for a given organization follow a standard
format (e.g. heading titles, numbering system, etc.). Format inconsistency is
largely due to the involvement of several people in the process of authoring
procedures, or due to benchmarking with more than one source. This problem
can simply be resolved through developing a procedure on "How to Write a
Procedure" and/or assigning a technical writer to do the final check on the
manuscript.

Equally important is to write procedures in simple and direct language. This
enhances their use, and promotes their integration with operational duties.
Furthermore, brief procedures (not more than 10 pages) encourage
employees to read them. A long procedure may be shortened by appending
detailed descriptions of selected tasks or including them in separate work
instruction document(s). For example, the detail on how to do gas testing may
be included in a work instruction that is simply referenced by the Permit to
Work Procedure.

C. The STR Cycle



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Rolling out HSEMS procedures is not an event; rather it is a process. This
process can be modeled through the quality cycle of: Setup, Train, and
Reinforce (Figure 2). Feedback arrows between the three activities ensure
learning and continual improvement.




                                   Figure 2

Setup

The setup stage consists of the following tasks:

1. Ensure Procedure Quality. We have already discussed in the previous
   section the common shortcomings and countermeasures associated with
   the process of developing procedures. Additionally, we emphasize here
   the need for implementing scenario-based checking, and practicality
   testing. The purpose of scenario-based checking is to ensure
   completeness and accuracy of the procedure. Whereas, the purpose of
   practicality testing is to ensure validity and ease of implementation.

2. Establish a reliable Interpretation Authority in the company. The role of the
   Interpretation Authority is to respond to queries. Some queries are direct;
   i.e. their answer can readily be obtained from the procedure text itself.
   Other queries are either oversights or special cases. Oversight queries
   address issues that are overlooked by the procedure's author; and
   therefore should be included in future revisions. Whereas, special case
   queries address issues that pertain to rare situations or to peripheral type
   of work. For the sake of simplicity and brevity, it is not recommended that
   special cases are included in the procedure. Nevertheless, like other
   queries, they should be responded to by the Interpretation Authority. The
   Interpretation Authority should keep a file of interpretations for future
   reference, and development of frequently asked questions (FAQ). It is
   important to require a written response to all types of queries (verbal and



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     written) in order to avoid any misunderstandings, and to ensure
     seriousness and accountability on the part of the Interpretation Authority.

    The Interpretation Authority responds to direct, oversight, and special
                                cases queries.

3. Select Competent Trainers. Competent trainers are subject experts and
   skillful communicators. If procedures are already in practice, trainers –
   especially external – should visit the sites to learn how they are
   implemented. It is highly recommended that trainers are involved in
   relevant audits. This gives them invaluable insight, and boosts their
   credibility among employees.

     Competent trainers are subject experts and skillful communicators.

Train

Like any training program, success depends on the trio of trainer, venue, and
material. The following highlight some special points that are specific to the
rolling out of HSEMS procedures.

    Document-Driven Presentation. A key learning objective in the rolling out
     of procedures is to motivate employees to frequently access procedure
     documents. This can be supported by designing the presentation around
     the procedure's table of content, and frequently referencing the procedure
     document during the presentation.

    Seeing the Big Picture. As explained in the introduction of this paper, the
     procedure is developed to control risks associated with specific
     expectations/elements of the adopted HSEMS Model.

    Focusing on Forms' Completion. This is also apart of "seeing the big
     picture"; completing forms and producing reports are an inseparable
     activity of the process of implementing procedures. They ensure proper
     procedure compliance and provide objective evidences of implementation.

    Message 1: "Compliance or Guidance". I sometimes get bewildered when
     I hear an HSE professional advising an employee to use his/her judgment
     to implement a certain aspect of the procedure, and/or to utilize the
     procedure as he/she sees fit. This of course is totally inaccurate.

        Trainers should make it clear that procedures are compliance
                   documents NOT guidance documents.

    Message 2: "Aligning Procedure and Practice". This message emanate
     from Message 1. It is not acceptable for an employee to practice different
     from the procedure document no matter how experienced or
     knowledgeable s/he is. If there is a discrepancy, it has to be resolved in



                                              On Rolling-Out HSEMS Procedures, 5 of 10
     either two ways: The procedure document is modified, or the other way
     around.

     Trainers should make it clear that under no circumstances should
            practice be different from the procedure document.

    Message 3: "Not a Substitute for Reading". No matter how great the
     trainer is, s/he cannot cover all details in the documented procedure; nor
     can s/he attain 100% learning among all participants. Trainers need to
     make this 'disclaimer' message clear upfront. They should, therefore,
     request that participants read the procedures' text. A good
     recommendation would be to request participants to read the procedure
     document prior to the training program.

    Disclaimer: This training is no substitute for reading the procedure's
                                     text.

    Directing Inquiries/Recommendations. Participants should be advised
     during the training on what to do if they have inquiry or would like to
     provide recommendations. The Company should facilitate verbal, physical,
     and electronic access to the Interpretation Authority.

The following are some recommendations with regard to power point
presentations. These recommendations are not specific to HSE procedures;
however, they are doubly important for rolling-out HSEMS procedures:

    Minimize Lecturing. Procedures are supposed to describe "HOW-TO" do
     things. The lecturing mode, on the other hand, is most suitable to explain
     "WHAT" is required. Therefore, the trainer should avoid lecturing as much
     as possible. As a rule of thumb: No more than 25% of the training should
     be devoted to lecturing. The following points might be helpful in this
     direction.

    Encourage Participants to Share Experience. The trainer should invite
     participants to reflect on their relevant experience. For example, on an
     HSE Incident Reporting procedure, the trainer may invite someone in the
     audience to share his/her experience with a certain accident or near miss
     incident. Some participants shy away from doing so. An effort on the
     trainer part is needed to break the ice. Conversing with participants during
     breaks is often helpful in this direction.

    Give Case Examples/Studies. Case examples or studies are effective
     learning tools. They can be real or hypothetical. For example, the trainer
     can explain the difference between root and immediate causes using
     actual accidents such as Al-Rawdhatain or the Prudeho Bay accidents.
     Transcripts of the Investigation Reports can be used. The trainer can also
     demonstrate the process of completing an HSE Incident Reporting Form
     using hypothetical scenarios.




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   Measure Comprehension. As it is well-known, there are four levels for
    measuring the effectiveness of training:
      o Did participants like the program?
      o Did participants learn the material?
      o Did participants apply what they learned?
      o Did participants/workplace benefit from the application?

    Usually the last two levels are difficult to implement unless there is a priori
    arrangement between the trainer and the workplace. As for the first level, it
    is commonly applied by most trainers through end-of-program survey.
    However, few trainers apply the second, though it is very doable. The
    trainers should prepare review questions (multiple-choice, true/false, etc.)
    to measure the participants' comprehension. Announcing such activity in
    advance would generally encourage participants to be serious. However,
    we advise against using such an activity by the company to penalize a
    participant; unless this activity is an integral part of the program, where
    participants have to go through formal written testing to demonstrate
    competence; e.g. passing the permit to work test is one of the
    requirements for issuing an authorization card.

   Motivate & Reward. People like competition. They also like gifts! Such
    facts can be leveraged by trainers through awarding gifts to those who do
    well on the review questions mentioned in the above point. The gifts can
    be customized with some HSE messages to provide additional value.

   Draw laughs, as appropriate. A boring training is failure training! People
    simply learn more when they are enjoying themselves. Drawing few laughs
    of relevant situations is highly recommended. For example, a trainer may
    use photos of 'outrageous/funny' behaviors while talking about hazardous
    acts.

   Tell stories. People like to hear stories, especially personal ones. A trainer
    can be very effective when, for example, s/he talks about a motor vehicle
    accident s/he or someone s/he knows had in the context of covering an
    HSE Incident Reporting Procedure.

Also, a trainer should watch out for "Near Misses"; i.e. participants yawning or
half-closed eyes! The trainer may utilize the following tips to deal with such
Near Misses. Again, these tips are not peculiar to rolling-out HSEMS
procedures:

   Play with the pitch of your voice. This has always worked for me! When a
    red-eye participant shows a near-miss sign, I abruptly raise my voice to
    catch his/her attention.

   Move around. By moving around, participants move their eyes/heads with
    you. This keeps them awake, and gives them some good ergonomic
    exercises!

   Ask a question. Let them talk, that always works out.


                                               On Rolling-Out HSEMS Procedures, 7 of 10
   Tell a story. As previously mentioned, people like to hear stories.

   Show a video; as appropriate. Us a good, relevant video.

   Give a break. If all fails, let them drink some coffee; that might help.

Finally, the trainer should comply with good practice in preparing his power
point slides as follows:

   Use as a Pointer. Power point presentations generally have a negative
    impact on rapport! By looking away from the audience, the trainer disrupts
    the process of establishing rapport with his/her audience. Therefore, the
    trainer should minimize the frequency and duration of 'looking away'. This
    means using the presentation slides as pointers; the detail of each point
    must to be generated from the trainer's memory using his/her own words.
    This not only promotes rapport but also establishes the credibility of the
    trainer.

   Don't Read from Monitor. I've seen this over and over again. Instead of
    presenting from the projected screen, trainers read from the computer
    monitor. This further alienates the trainer from his/her audience.

   High Contrast. Use high contrast between foreground and background.

   MFSL is 28. Use 28 as a minimum font size level. Use smaller font if you
    really have to.

   RFT is Arial & Verdana. Arial and Verdana are the two recommended font
    types.

   Max. Bullets/Slide 8.

   Use Clips (Own Photos is Best). Include pictures without compromising on
    MFSL. However, do not use irrelevant pictures. Also, photos taken from
    the worksite itself are most effective. Of course, you need to watch for
    privacy protection.

   Maintain Consistency. This rule has to be observed throughout the
    presentation with regard to colors, sizes, etc.




                                               On Rolling-Out HSEMS Procedures, 8 of 10
Reinforce

After participants go through the training, a reinforcement mechanism needs
to be in place to ensure compliance. The following are some
recommendations:

Conduct Intensive audit/inspection. Audit teams and supervisors need to be
ready to monitor implementation. For example, after completing a training
program on the permit to work procedure, supervisors must closely monitor
employees' completion of the various permits. Audit teams, must conduct
frequent audits/visits and issue corrective and preventive actions, as required.
Advanced Safety Audits can also be utilized for quick actions/results. Such
activity sends a clear message to employees who just got off training that
management is serious about implementation. Moreover, it provides the
needed assistance to break away from old habits!

Adopt Modular Implementation. This means that instead of rolling out HSEMS
procedures company-wide, they can be implemented in certain locations. This
approach is recommended for better control. Moreover, it gives the company
a better opportunity to learn and adapt, before full-fledged implementation.

D. Conclusion

A mark of a successful implementation of the STR process is where
employees send their queries/feedback to Interpretation Authority, and the
Interpretation Authority, in turn, heavily relies on such input in the process of
revising procedures, and improving/controlling the training activity. Another
valuable input to the Interpretation Authority comes from the trainers who
usually have gained a great insight from the process of preparing their
presentations and from interacting with employees during training.




                                              On Rolling-Out HSEMS Procedures, 9 of 10
Fig. 1: Procedures link between Elements/Expectations and Records & Reports.




           Fig. 2: Rolling out procedures is a process not an event.




                                             On Rolling-Out HSEMS Procedures, 10 of 10

				
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