Regulations and reliability are the easy parts of risk management

Companies invest substantial amounts of money and time in developing risk management plans that are designed primarily as reactive response procedures for events that happen and little in plans or actions specifically designed to prevent the disasters.

By R. Keith Mobley

Every company strives to prevent environmental, health and safety violations that could result in an event or accident causing injury, health degradation or death of its employees or surrounding community. Companies invest substantial amounts of money and time in developing risk management plans that are designed primarily as reactive response procedures for events that happen and little in plans or actions specifically designed to prevent the disasters. In addition, most plants have an environmental, health and safety (EHS) function or functions that are charged with preventing events or accidents that result in an environmental release or accident.

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Few of these functions are effective. Most, if not all, merely focus on compliance with existing regulations and laws. The EHS staff fills out the correct forms and maintains the required records, but they spend little time on a full understanding and management of the risks that the company faces in its day-to-day operation.

If one were to evaluate the environmental events and accidents that result in employee injury or death, you’d find that the obvious root cause of the event is a direct violation of some regulation or standard procedure that wasn’t detailed enough to provide employees with instructions for the specific operation. While most companies have procedures, such as lock-out or HAZMAT, that are intended to control the potential risk in operations that could result in an event, few of these procedures have sufficient detail or cover all of the variables that increase the probability of an occurrence.

Manufacturing or production asset reliability is a fundamental requirement of environmental, health and safety assurance. Most recorded events during the past 10 years have been caused, at least in part, by failure of one or more critical components within the plant’s production or auxiliary systems. Most of these failures can be traced to improper operation or maintenance over an extended period.

Patterned after Six Sigma, the concept of reliability excellence includes tools specifically designed to identify and manage risks, including environmental, health and safety. The process begins with a thorough simplified failure modes and effects analysis (SFMEA). This analysis identifies potential failure modes for critical plant assets that could result in any event that affect capacity, cost and EHS problems. The SFMEA identifies the risk and provides a priority scale that permits the company to reduce risk systematically.

Data from the SFMEA is then used to develop standard operating and maintenance procedures that provide specific, step-by-step instructions for proper operation and maintenance. Such procedures for critical assets can limit, if not eliminate, the potential for an event that could affect operations, including environmental problems. These procedures then become the primary control for preventing potential problems or events.

Reliability excellence also includes culture change, another critical factor that is mandatory for preventing environmental events. While the SFMEA can identify and serve as the source for standard procedures that minimize risks, you can’t assume the workforce will automatically or universally adhere to procedures. All your employees must follow these procedures exactly as written to ensure environmentally safe operation. To accomplish this, the entire work culture, including how employees perform their daily responsibilities, also must change.

This requisite change must be achieved through workforce re-education, single-point accountability, and clearly assigned and understood roles, responsibilities and expectations. Accountability must be universally enforced and requires direct involvement of supervision and management at every organizational level to check and confirm the quality of work and compliance to standard procedures.

The final component of reliability excellence that directly contributes to a safe environment, as well as high performance, is an effective proactive, rather than reactive, risk management process. The risk management process, implemented and administrated by reliability engineering, should be designed to constantly identify, evaluate and eliminate risks that could impact plant performance, with a central focus on environmental, health and safety issues.

E-mail Contributing Editor R. Keith Mobley, CMRP, principal consultant at Life Cycle Engineering, at kmobley@lce.com.

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