Process Safety Progress - 2023 - Olsen - Why The Term Operational Discipline Is Not Helpful and Better Options For

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Received: 24 March 2023 Revised: 20 June 2023 Accepted: 20 June 2023

DOI: 10.1002/prs.12505

ORIGINAL ARTICLE

Why the term “operational discipline” is not helpful, and better


options for instilling positive process safety culture

Jody E. Olsen

JE Olsen Consulting LLC, Anchorage,


Alaska, USA Abstract
Language matters for effective leadership and culture. And the language embedded in
Correspondence
Jody E. Olsen, JE Olsen Consulting LLC, the term “operational discipline” is not helpful. This term is inconsistent with decades of
Anchorage, AK 99509, USA.
learning on cause analysis, systems thinking, and human performance. Humans typically
Email: jodyo@jeolsenconsulting.com
do not fail because they are not disciplined enough. Failures occur for other reasons that
stem from the systems within which the humans are working. For many people, the
term “discipline” has a negative or punitive connotation. And the term “operational”
focuses the spotlight on operations. The two terms taken together may imply to some
people that willful operator deviations are the root cause of some incidents. Failures
typically involve a range of management processes and functional groups. Thorough fail-
ure analysis can identify systemic causes, and follow-up corrective actions may be tar-
geted at the upstream sources. Healthy culture requires a positive, inclusive, and curious
environment that seeks to continuously learn and improve without casting blame. Even
if the term “operational discipline” is not intended to place blame, the choice of words
defeats that aspiration. When seeking to improve process safety culture, choose lan-
guage that supports a positive learning environment of ownership and empowerment
by the workforce. And support those words through management actions.

KEYWORDS
conduct of operations; culture; human factors; human performance; operational discipline;
process safety; root cause analysis, RCA; systems thinking

1 | I N T RO DU CT I O N work settings, human error is rarely caused by lack of discipline. Fail-


ures occur for other reasons that are baked into the systems within
The term “operational discipline” has been espoused as a means of which humans are working.
achieving process safety goals. However, this term, and what it stands Language matters for effective leadership. And leadership lan-
for, is inconsistent with decades of learning on root cause analysis guage sets the tone in establishing culture. Operational discipline can
(RCA) systems thinking,1–3 human factors, and human performance. In sound punitive and point blame at the operator or operations. When
incidents occur, deficiencies are generally found throughout a range
of work management processes and functional groups. And, impor-
tantly, the deficiencies span vertically through company management
This article was originally presented at the American Institute of Chemical Engineers
as well as laterally through functional disciplines and process safety
2023 Spring Meeting and 19th Global Congress on Process Safety, Houston, TX, March
13–15, 2023. management (PSM) practices.

This is an open access article under the terms of the Creative Commons Attribution-NonCommercial License, which permits use, distribution and reproduction in any
medium, provided the original work is properly cited and is not used for commercial purposes.
© 2023 The Author. Process Safety Progress published by Wiley Periodicals LLC on behalf of American Institute of Chemical Engineers.

70 wileyonlinelibrary.com/journal/prs Process Saf Prog. 2024;43:70–79.


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OLSEN 71

This article will define the problem, provide background, and offer dealing with a flood of alarms, hazards may not have been identified,
several stepping stones to support moving an organization toward a communication processes may have failed, new electronic work man-
more positive and effective safety culture. We look at tools from lean agement systems may not have been fully functional, and many other
manufacturing that have driven improvements in reliability. We look reasons.
at sectors outside of the processing industries—including the And what about the other people?
U.S. Nuclear Navy and the airline industry— to find examples of where What about the engineers who signed off on incomplete techni-
high-reliability practices have been institutionalized. Although not all cal reviews or poorly performed process safety reviews on changes
processes are directly transferable, these successes offer opportuni- and projects? Did they do those things because they lacked engineer-
ties to learn and implement better practices. ing discipline or because the management systems allowed them to
fail? Were there sufficient checks and balances in the process? Did
the process require technical reviewers with defined skills, training,
2 | T H E P R O B LE M and qualifications perform those reviews? Was the purpose for the
checks and balances understood and reinforced?
For many years, operational discipline (OD) has become a popular tag- What about managerial discipline?
line for the culture that needs to be in place to ensure sound work What about supervisors who signed off procedures during 3-year
practices and safe operations. The term “operational discipline” was reviews that do not reflect the way work is performed in the field?
coined in industry by the mid-2000s4 and adopted by the Center for Did the review process require operational and technical reviewers to
Chemical Process Safety (CCPS). The term was referenced in the sign off in conjunction with the supervisor? Did the supervisor ensure
5
CCPS Guidelines for Risk Based Process Safety (RBPS) in conjunction that all reviews occurred? Were onsite reviews conducted? Did the
with the Conduct of Operations element. In Chapter 17 it says, “[Con- supervisor have sufficient knowledge or resources on how to align
duct of operations] is also sometimes called ‘operational discipline’…” work activities with usable procedures? Did they understand human
A CCPS book dedicated to that chapter was published in 2011.6 The performance models?
terms have been moderately redefined over the years but remain What about the managers accountable for effectiveness of the
close to the original descriptions.7 The current definition of opera- PSM systems? Are they aware that the procedures are incomplete
tional discipline according to the CCPS website is “The performance and unusable? If not, why are they not aware? What steps have they
of all tasks correctly every time.”8 This definition is consistent with taken to correct those systemic deficiencies? Have they engaged
prior OD mantras of “Everyone, Do It Right, Everytime.” 4
operating and technical staff in the process for improving those proce-
These words imply that, if only the personnel were doing the dures? Have they allocated budget and prioritized that work? Is a pri-
work as the procedure and the process prescribed, incidents would oritization system in place to address deficiencies that involve the
not occur. However, many times when we perform root cause failure highest risk scenarios ahead of less critical work?
analyses for incidents in industries regulated under PSM, we find that How were these operating procedures certified annually, as
no quality procedure exists. The procedures may be nonexistent, out required by OSHA PSM, as being “current and accurate”10 if the pro-
of date, incomplete, unclear, hard to read or use,9 or contain errors or cedures are not aligned with the way “work is done” in the field?
have other flaws. And it is not unusual that the causal factors for the Managers who preach the need for operational discipline believe
incident may have stemmed from personnel attempting to comply that it is possible to stamp out the normalization of deviation that is
with a poorly crafted procedure. In addition to potential procedural preventing their company from achieving the stated goal of “Every-
deficiencies, the circumstances at the time of the incident may have one, Do It Right, Everytime.”4
prevented or disincentivized the operator from using the procedure. Importantly, they seem to misunderstand the wider systemic
If discipline were the problem, the RCA would find that causes and fail to recognize the fallacy in the simplistic statements “Do
operator(s) made willful choices not to do something that they knew It Right, Everytime” or “perform tasks correctly every time.” What is
they were supposed to do and were able to do. Consider a broken “right” or “correct” when the systems are strewn with defects and
New Year's resolution to stop eating candy or workout every day. when successful performance may require adaptation by humans?1,3,11–
13
When we break our resolutions, we willfully deviate from what we The more productive stance is to acknowledge that defects exist
know we should do and what we— ourselves—want to do. We seem because systems are not perfect3 and that human error is normal.1,2,14
to lack the discipline to keep our own resolutions. However, even in The goal should be to find and eliminate defects, to equip the humans
this case, the truth may be that there are root causes that set us up with tools that make mistakes less likely,9,13 and to reinforce systems so
for failure. Perhaps, we have set unrealistic or unachievable resolu- they have more capacity, that is, resilience, to absorb errors.3,12,14
tions. Perhaps we set those goals without having the tools to form In a series of articles on Admiral Hyman Rickover's building of
new habits and to make positive changes. the first—and potentially only— high-reliability organization, the U.S.
When operators are found to have not conformed to procedures Nuclear Navy, Mark Paradies takes the unusual stance that normaliza-
or protocol that led to major incidents, the incident reviews will gener- tion of deviation is in fact everywhere!15,16 He is correct! It is embed-
ally find reasons that contributed to the operator not using the proce- ded in the human condition to not perfectly follow the rules,
dure or not being able to use the procedure. Beyond issues with instructions, advice, and guidance that we are given, not to mention
deficient procedures or processes, the operator may have been our own plans, such as those New Year's resolutions. To achieve
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72 OLSEN

incremental improvement in moving toward more perfect confor-


mance, we must understand the realities and the barriers to getting
there, and we should replace the “stick” with the “carrot.”

3 | W E H A V E A L O N G WA Y T O G O , … H O W
D O W E G E T T H E RE ?

Unless you are working within a handful of industries that instituted


high-reliability practices many years ago, such as the Nuclear Navy,
the civilian nuclear industry, NASA, the airlines, or perhaps the post
office, the concerns raised above may likely ring true for your organi-
zation. If your company has not had major or serious near-hit inci-
dents (recently), is it because these issues are not present in your
organization, or have you been lucky? Investigation after investigation
by the U.S. Chemical Safety and Hazard Investigation Board (CSB)
reveals management system failures that span a wide range of PSM
elements and process safety practices. So where would a company
start and how do we address a large number and broad range of sys-
temic deficiencies?
How can we replace the “stick” of operational discipline with a
more positive—and potentially more effective—“carrot?” How do
we move toward better practices that will engage the workforce to
migrate toward more excellence as Rickover strived for and
achieved in the Nuclear Navy? Interestingly, as described in the
Paradies article series, neither in the 3 overriding tenets that Rick- F I G U R E 1 Admiral Hyman G. Rickover, known as the “Father of
over espoused nor in the more detailed 18 building blocks refer- the Nuclear Navy,” directed the original development of the Nuclear
Navy and controlled its operation for three decades as director of
enced in Rickover's testimony do we see the term “operational
U.S. Naval Reactors.19 The rigorous standards that he required enabled
discipline.”16,17 Strict conformance with specific expectations was the high-reliability performance that the Nuclear Navy has achieved.
and is an essential part of the nuclear naval program. Those
requirements are prescribed in defined terms,17,18 not as a vague
reference. Non-conformance is enforceable by disqualification. So, what is to be done? … Can we even make a dent?
This means the standards were and are rigorously developed so I am not in favor of eating elephants, but as the saying goes, the
that conformance is achievable (a portrait of Admiral Rickover is only way to do it is to start … one bite at a time.
shown in Figure 1). One starting point, perhaps we replace the term “operational dis-
Outside of the military, industry faces several obstacles to cipline” with “operational excellence” in the lexicon.
achieving the high-reliability performance that Rickover put in
place. Those obstacles include the fact that he built those elements
into the organization from its inception. The extraordinarily high 4 | STEPPING STO N ES
level of technical training, qualification, and re-qualification
required by personnel from the top to the bottom of the organiza- Here are several key stepping stones to making improvements. They
tion is well beyond the requirements that exist in typical industrial all relate to operational excellence through better understanding of
settings. Extensive resources are dedicated to the entire program human performance models. Operational excellence could be sup-
including procedure development and improvement. Importantly, ported by work in the following areas:
the cost structure within the Nuclear Navy, which is driven by
safety imperatives, does not resemble the budget allocations in 1. Insist on full management accountability
other industries. Although the cost of incidents is understood to 2. Perform rigorous technical review and validation
be high, the day-to-day cost of doing business in a manner com- 3. Foster employee ownership by enabling the workforce (at all
mensurate with the Nuclear Navy is a barrier to industry. And the levels)
culture of organizations outside of the military is not likely to be 4. Develop usable procedures by integrating human factors learnings
conducive to the rigorous expectations placed on personnel at all 5. Prioritize like a demon (based on defined parameters)
levels, including the knowledge that termination is the result of 6. Conduct failure/cause analysis early and often
failure at any checkpoint along the way. 7. Reward proactive continuous improvement efforts.
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OLSEN 73

Each of these points could be an entire article. For the purposes of industry-wide system highly successful. Reporting is confidential, volun-
this paper, I will touch on several tools or suggestions that may help in tary, and non-punitive (see Figure 2 from ASRS website). Reports are
taking initial steps toward improvements in each area. Note that these contributed cross-functionally by pilots, air traffic controllers, mechan-
seven areas are not intended to replace or supersede efforts associated ics, and others. And the system is administered by a third party, NASA.
with all elements of PSM,10 RBPS,5 or internal company operational and It has sometimes been referred to as a “get out of jail free” card. By
safety management programs. The intent in highlighting these seven is making the report, the individual cannot be prosecuted or penalized.
to address several critical elements that may help in tackling wider sys- The system and database remain in use today along with another sys-
tem deficiencies impacting procedural conformance and the ability to tem called the Aviation Safety Action Program (ASAP) created in the
optimize human performance. These seven items can also help redirect 1990s.23,24 ASRS may eventually be phased out in favor of ASAP
the focus from discipline to ownership and empowerment. because ASAP provides more data, which allows for better analytics
and objective assessment of the events.
These programs work by acknowledging that systems are not per-
4.1 | Insist on full management accountability fect, humans make mistakes, and sharing that information is the best
way to identify hazards and implement improvements that can reduce
The need for accountability is driven home in Mark Paradies's article the likelihood of recurrence and worse outcomes. A culture that dic-
series on Rickover. Rickover does not play with words regarding the tates “Everyone, Do it Right, Everytime” is not conducive to moving
subtle distinctions between responsibility and accountability. In most toward this model.
organizations, accountability is reserved for the top levels, with lower My uncle, Robert M. Euwer, was a forward observer in the
levels having responsibility. In his Nuclear Navy, total responsibility Korean War.25 He was at the sharp end of the stick. His job was to go
starts at the top with Rickover. And responsibility for safety and tech- out to identify problems and opportunities and then report back to
nical competence is then passed down through every level in the higher ranking commanders. There was no stigma with reporting bad
chain of command.16,20 news. This was simply his job.
Again, how can we make a dent in industries that are a great dis- Changing the paradigm to a model that values hearing the reali-
tance from this model? ties on the ground involves both changing the language and changing
To be accountable (or responsible), the manager must be aware. If actions. Actions speak louder than words.
the manager has no awareness that the processes and procedures are Managers need to ask, “How can we encourage and incentivize
riddled with defects, he or she will be very surprised when failures occur. employees to speak out and to show us the errors in procedures, the unu-
One way to become more aware of those defects is to acknowl- sable procedures, and the instances when work proceeds without a proce-
edge that they are there and to regularly communicate that “we” as an dure (and needs one) as well as instances when performing work without
organization want to know about those defects. In the airline industry, a step-by-step procedure may be acceptable or preferred? What are the
the need to understand defects in the system was recognized years ago barriers that could derail new programs intended to identify these flaws?”
and the Aviation Safety Reporting System (ASRS) was created. Estab- How to get there may vary, but the goals of identifying defects,
lished in 1976,21,22 this near-hit reporting system became a mechanism rewarding finding those defects, and embedding continuous improve-
for communicating concerns, close-calls, or violations of any type that ment practices into the job should be fostered. The overriding theme
had potential safety consequences. Several key features have made the should be that defects are known to exist and expected to exist. The

F I G U R E 2 The Aviation Safety Reporting System (ASRS) was initiated in 1976 to provide a system for voluntary aviation occurrence
reporting in the United States, which would confer conditional immunity and encourage reporting.21,22
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74 OLSEN

goal is to find them and eliminate or mitigate them. This reality is the 4.3 | Foster employee ownership by enabling the
basis of The Manufacturing Game, which was developed to improve workforce (at all levels)
reliability through systems thinking and defect intolerance.26,27 These
ideals and this recognition apply equally to process safety. Engaging the workforce at all levels to participate and lead in
The suggestion to “ditch the term operational discipline” and problem-solving has been shown in many organizations to result
ensure full management accountability is not intended to deflect in better performance and outcomes, including in safety performance.
blame from the operator to the manager. It is an effort to move away There are many good resources available online that share these suc-
from blame. Defects know no boundaries. They exist because our cessful experiences, such as in the Sidney Dekker books and videos
equipment, processes, and systems are not perfect. The system pro- on Safety Differently.32–34 These resources cite examples of compa-
vides the bandwidth within which we can improve. So, management nies within oil and gas, health care, retail, and food and beverage
must understand where we require more bandwidth. Addressing that industries where workers were empowered to craft their own safety
need requires awareness, resources, and focus. And addressing programs and processes. In these examples, the companies improved
that need will ultimately facilitate other improvements. their safety performance while invigorating the workforce through
their ownership in developing the processes.
Although these ideas are not new, an increasing number of voices
4.2 | Perform rigorous technical review and are advocating for engaging the workforce from the bottom up. The
validation notion that “people are not the problem, people are the problem
solvers” is highlighted by many leaders in the area of human and orga-
The organization that Rickover created demanded extremely high levels nizational performance (HOP) including Dekker,32 Conklin,14,35
of technical competence that was achieved through careful selection of Fisher,13 and Edwards.36
candidates and rigorous training, examinations, qualification, drills, and If the workforce is designing the system, they are more likely to
auditing.16,28 Additionally, technical quality was and is achieved through follow their own plan. Recognizing the weaknesses of New Year's res-
integrating operations and engineering support. In the Nuclear Navy, olutions, those plans need to be achievable and well vetted.
operational procedures are technical procedures. Operating procedures The difficulty in relying on employee empowerment to design
require input from skilled operators, engineering, and supervisors to cre- safety solutions in industries handling highly hazardous materials and
ate a new procedure or to modify a procedure. These standards are well operations is that most significant process safety risks involve high-
beyond where many industries sit today. Although daunting, those gaps consequence, low-probability events that workers have not seen in
reinforce the need to take steps toward instilling high-quality technical their lifetime of work experience. So, there must be technical process
review for all critical operational tasks. safety support and input on any solutions or changes that are formu-
In PSM facilities, modifications require complete technical lated by these workers.
29–31
review no matter the size or scale of the change. Changes A long-standing gap in industry is the lack of positions that com-
include improvements to operating procedures. When operating pro- bine operations and process safety. How many operations personnel
cedures are redlined or edited, proposed changes need to be routed attend the annual Global Congress on Process Safety (GCPS)? What
through the management of change (MoC) process. Through that percentage of that audience comes from operations versus engineer-
process, the change requires technical review by all impacted func- ing versus other disciplines? Does your organization have an opera-
tional disciplines29 and process safety review by qualified tions process safety technician? The role could support day-to-day
reviewers.30,31 Many companies handle operational procedural operational work and provide embedded technical support focused
changes under alternative protocol outside of the standard MoC on process safety hazards. An individual with operational background
system. Unless the changes are purely administrative, any change to who understands process safety implications and advocates for the
operating procedure steps, tools used, equipment involved, and so use of process safety tools could help bridge the gap. This role could
on, should trigger standard MoC review requirements. In processing be a front-line resource to help catch misses potentially passed
industries, many incidents stem from these types of procedural through the system and could help support more thorough process
changes that have not gone through review by qualified personnel safety reviews.
from all impacted technical disciplines. Just as operator-generated ideas for improvements must be vet-
Critical guidance procedures such as energy control/lock-out tag- ted for technical accuracy and process safety risk, ideas conceived
out, opening and blinding, hot work, and confined space entry should from above must be vetted through frontline workers to confirm that
also involve technical and process safety reviewers in addition to implementation on the ground will work. Engaging the workforce is
review by the Health and Safety (H&S) group and Operations. And an essential part of that process. Management-generated ideas such
careful auditing of front-end systems, such as workorders generated as encouraging routine redlining of procedures may sound simple, but
through computerized maintenance management systems (CMMS), is if there are aptitude, skills, or technology barriers that make the task
needed to find modifications that are slipping through without being hard to accomplish, the idea may not work. Monetary incentives may
classified as changes. These misses will not be found if the auditor sound good, but if workers see unfairness in distributions or that the
does not have the required technical competencies. awards do not align with value-added changes, the incentive may
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OLSEN 75

backfire. Expecting new contributions to be made by employees with- McDonald's uses procedure writing best practices such as format-
out making the space in workers schedules may be seen as unfunded ting and organizing documents through information mapping, minimiz-
mandates. ing words, including critical data, providing unambiguous instructions,
Go to the workers, find their pain points, and seek their ideas. and using checklists. McDonald's visual systems provide easy-to-read
Starting the process for suggesting improvements with the personnel information in the locations where the information is needed, such as
doing the work, as shown in Safety Differently,32–34 is far more ener- storyboards above the counter, abbreviated laminated procedures at
gizing to the workforce. Also recognize that with any change or new workstations, and preventive maintenance and cleaning instructions
initiative, trial and error should be expected. Potential solutions, on laminated tabbed cards—stored in locations where the procedures
whether generated by workers or by management, must be continu- are used. All procedures, signs, and labeling make ample use of color
ally revisited and tweaked or fully reinvented if they are found to be and apply consistent color coding. Equipment is designed to mistake-
ineffective at achieving the intended goal. proof processes. During the field trip, our team learned that the super-
visor spent 75% of his/her time on the floor coaching and learning
from employees and 25% of his/her time in his or her office, in meet-
4.4 | Develop usable procedures by integrating ings, or preparing reports.
human factors learnings One other area of commonality between the Nuclear Navy and
McDonald's is the consistency of the “kit,” whereas the inconsistency
To improve consistency in usage of and conformance with proce- of the “kit” in processing industries exacerbates the challenges for
dures, the procedures need to be good. But what is good? That defini- catching up on procedural improvements. Most industry procedures
tion may change from time to time, but effective procedures will have are unique to the process, plant, and equipment involved. Variability
some common characteristics regarding form and format. Better prac- associated with organizational and personnel differences adds another
tices for writing procedures have been gleaned over the years from layer of specificity. These factors create more challenges for industries
human performance social science,9,13 from industries that “do proce- playing catch-up.
dures better,” and from practical field trial-and-error experience. Inter- Although it is a large elephant, the learnings available from other
estingly, industries that “do procedures better” have some similarities industries, academia, and our history provide a toolbox for developing
but also some differences. more usable procedures.
Probably the best known example of an organization that has well- Like risk, human error can never be eliminated. But the frequency
crafted, accurate, and consistently followed procedures is the Nuclear of mistakes can be reduced by creating procedures that apply learn-
Navy. Most operational tasks in the Nuclear Navy are performed using ings on how to optimize human performance of tasks.13 To make
rigorously developed step-by-step procedures. The standards were set these improvements, personnel skilled in developing user-friendly pro-
from the outset by Admiral Rickover. That origin story is in marked con- cedures that minimize the chances of human error need to be part of
trast to the situation within industries such as oil and gas, refining, che- the effort.9,13
micals, and many others where plants were built and started up before This work includes the layout, formatting, and writing of the pro-
industry and regulators recognized the need for complete and well- cedure document. In addition to improvements in layout and style,
maintained written procedures. Some original industry operators can the procedures need to be carefully checked to ensure they do not
recall the date when the company retroactively enlisted procedure include error traps1,13 such as vague or unclear guidance, misleading
writers to document what the operators did and what the operators information, conflicting information, or multiple embedded steps. The
knew. These industries have been playing catch-up since that time. procedures should not require field decisions without providing spe-
The Nuclear Navy benefits from having the imperative and the cific guidance on how to make those decisions. Critical information
funds to provide robust training and to require rigorous qualification must be included directly in the procedure. Specificity helps to drive
standards for new hires. Ironically, another industry known for strong down error rates. Vague or general guidance will drive up error rates.
“procedure processes” requires these practices because of the reverse Newly written or modified procedures then need to be
situation. McDonald's (fast food restaurants) has exemplary processes beta-checked for usability via a field walk-down. A completed but
for writing procedures, communicating procedures, and reinforcing unapproved procedure requires hazard assessment using a procedural
procedures. “Because of high employee turnover and inexperience of process hazard analysis (PHA) method.38,39 The procedural PHA will
new hires, McDonald's procedure and training process must be a very identify how steps could go wrong, the causes that could lead to
robust design.37” By contrast, processing industries tend to have staff errors in completing a step, the consequences from those errors, and
with more baseline skills and knowledge than a McDonald's worker improvements that could prevent the error or lessen the impact of the
but less baseline knowledge than a nuclear worker. Following the hire error. The Human Performance Oil & Gas Walk-Through Talk-
date, however, the McDonald's training and qualification require- Through Guide (WTTT)40 essentially describes elements of a PHA.
ments likely exceed some or many processing industry training stan- Writing by Bridges and Marshall38 and Medrano39 offer guidance and
dards. During a field trip in 2002 to learn about McDonald's practices, methods for conducting a procedural PHA. An effective process haz-
their personnel explained their training, qualification, certification, and ard review is an embedded requirement for conducting a complete
procedure processes to our team. MoC safety review under OSHA PSM.31
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76 OLSEN

Visual indicators, visual signals, and visual controls41 represent implemented this system. I knew that no matter how long my list
another form of instruction. Lean manufacturing principles, gleaned was, by starting at the top, I was working on what my team mem-
primarily from Japan, highlighted the importance of applying visual bers deemed most important. And they would understand why I was
systems to support reliability and productivity.42 Visual systems can not working on the other 89 items.
be a powerful tool in supporting human performance.41 Data show Prioritization allows people to be focused, productive, and mini-
that >95% of cars stop for red lights and/or stop signs,43 which is sim- mize stress. And the group prioritization effort maximizes the success
ilar to or better than a safeguard having a risk reduction factor of of the organization by targeting work on the most critical needs.
10, or probability of failure on demand of 0.1. Use of labeling, color Note: Part of empowering the workforce includes enabling the
coding, lighted displays, signs, and other visual tools can support com- workforce. A quick way to dampen energy and enthusiasm for making
municating key information at the location where that information is improvements is the failure to follow through. Repeated inaction or
needed. In some cases, procedural steps can be posted in the loca- dismissal of ideas can snuff out sharing of future improvement ideas
tions where they are needed, as is done at McDonald's. and impact retention of the strongest employees.
Understanding how to construct a procedure and recognizing Involving the workforce in the prioritization efforts through
how to avoid introducing error traps into the procedure are essential transparency, an open invitation, and well-publicized priorities can
prerequisites for moving an organization toward more consistent con- help foster consensus on the best use of limited resources. At the
formance and compliance with procedure use. Significant effort and very least, that participation and communication may support under-
resources need to be devoted to starting and progressing on that jour- standing the constraints. Including worker-originated ideas in the
ney. This journey does not have an endpoint. It is a continuous pro- mix of projects will go a long way toward maintaining that
cess of incremental improvement and reassessment. employee engagement and may result in key improvements. When
decisions are ultimately made to reject or indefinitely defer addres-
sing an idea, it is crucial to—at a minimum—respectfully share with
4.5 | Prioritize like a demon (based on defined the individual the rationale for why the decision was made not to
parameters) proceed.

All these ideas sound terrific, but who has time to do these things?
Plus, we are not building a Nuclear Navy from the ground up. We are 4.6 | Conduct failure/cause analysis early
already in operation, and things are happening every day that require and often
our attention.
Working at a typical operating facility is like being on a treadmill Performing failure/cause analysis (a.k.a. RCA) early and often is one of
that never slows down. Finding the time to address systemic deficien- the best tools for improving reliability and mitigating safety risk. Peo-
cies and to make wider improvements is a real challenge given the ple are often more receptive to acknowledging problems they have
steady stream of fires that need fighting in most facilities. seen than problems that may occur in the future, such as described in
So where to begin? … Prioritize like a demon. hazard review scenarios. Connecting the dots between the two, such
In her TED Talk, Emergency Room (ER) doctor, Darria Long Gillespie, as identifying and addressing the causes for failures of critical safe-
speaks of the challenges that many people face of feeling “too busy” and guards in high hazard scenarios, can help to relate those PHA scenar-
the stress that this busy-ness induces. How do ER workers do it? Her mes- ios to real life and make them more credible to employees.
sage is extreme prioritization, or triage, triage, triage in ER vernacular.44 A great mechanism to empower the workforce is to engage all
I have experienced the same when working in plants. After team members in routine failure/cause analyses that support learning
about 5 years of working in a scattershot way and responding to the and improvements. Workers will naturally see problems and have
loudest voice and the squeakiest wheel, our team implemented a ideas to fix them whether trained in RCA or not. Equipping personnel
successful prioritization process that was supported by a centralized with failure analysis tools and building a culture that rewards struc-
tool for managing all incoming small project work requests. The con- tured problem solving will enhance the quality of the solutions. Near-
cept is simple, but it took a significant change in our tools and work hits and process upsets can be analyzed using the same tools that are
processes to bring about that needed improvement. We moved from used for more involved incidents.45,46
a process that allowed anyone to ask the engineer to start working The same learning and cause analysis tools can be applied to
on their need to a centralized weekly review process supported by high-risk work activities that have been incident-free to understand
our local management, supervisors, operations leads, and engineering the causes of success. These learning exercises may identify weak-
to determine the priorities and revisit the highest priorities each nesses in individual layers of protection not previously recognized.36
week. Anyone could attend the meeting and lobby for their project. The weaknesses can then be addressed before an event occurs. The
But the priorities were set by the team and stood until the next process safety operational role discussed above could become a point
week's meeting, absent emergency break-in work that met certain person for supporting the operating staff in working through failure
criteria. My life and probably my blood pressure improved after we and cause analyses.
15475913, 2024, 1, Downloaded from https://aiche.onlinelibrary.wiley.com/doi/10.1002/prs.12505 by SEA ORCHID (Thailand), Wiley Online Library on [27/02/2024]. See the Terms and Conditions (https://onlinelibrary.wiley.com/terms-and-conditions) on Wiley Online Library for rules of use; OA articles are governed by the applicable Creative Commons License
OLSEN 77

F I G U R E 3 Real drift showing


how workers continually adapt
resulting in work-as-done versus
work-as-imagined. Deviations from
procedures have the potential to
result in positive or negative
outcomes.13

4.7 | Reward proactive continuous improvement opportunity. If “work-as-done” involves “taking a short-cut” from the
efforts written procedure steps, this situation requires technical/process
safety review to determine whether the short-cut is a defect or an
Many companies tend to reward the heroes that come in to save the improvement (Figure 3). If the alternative steps are safe and stream-
day during upset or emergency situations. But rewarding the smaller line the procedure, it is better to institutionalize this change through
proactive continuous improvement efforts by workforce members is updating the procedure. If found to be unsafe, the hazards and risks
equally and probably more important. need to be communicated so that the practice is changed.
Continuous improvement means finding and addressing defects We must expect that defects exist,26,27 that humans make
of any type that are in the system.26,27 Addressing defects includes mistakes,1,2,14 and that normalization of deviation is everywhere.15 In
45,46
identifying mitigations to prevent small failures or upsets as well short, we must realize that our processes are not perfect. The goal is
as implementing changes to address broader systems issues that con- to find the defects and implement individual and systemic corrections
tribute initiating causes or cripple safeguards. Defects include wherever possible and as often as possible. There are too many
defects in the system to make a dent if the entire workforce is not
• procedure steps that cannot be followed or should not be engaged in and rewarded for being part of that solution.
followed;
• work that is progressing without a procedure;
• permitted work that is proceeding without a completed quality 5 | CONC LU SIONS
safety review;
• prescribed field walk-downs that are not occurring before issuing The term “operational discipline” and the definitions given imply that
permits; lack of discipline is a causal factor for human error. Through failure
• MoCs involving process changes that are signed off without a com- analysis, experience, and social science, we know that is not the case.
30,31
plete hazard review ; Initiative titles or slogans are not the most important driver, but a poor
• MoCs that are signed off without all required technical disciplines slogan can contribute to derailing an improvement effort. We do not
participating in the technical reviews29; want to frustrate or talk down to workers who we need to engage in
• PSSRs that are signed off without field walk-downs47; and finding solutions. It is incumbent on managers and industry leaders
• many other procedural and process defects and deviations. who have adopted the term “operational discipline” to make the shift
away from it.
Identifying those day-to-day defects and taking steps to prevent When we seek to improve organizations' reliability and safety
their recurrence are key continuous improvement efforts. Identifying performance, management must acknowledge the realities of how
these work process defects does not need to wait for a 3-year audit humans behave and the barriers to aligning that behavior with perfect
to occur. Changing the language and creating mechanisms that conformance. We cannot address those barriers if we do not name
encourage the workforce to continuously look for defects in all them specifically. We must recognize that our organizations and pro-
aspects of their work will drive more systemic improve- cesses are laden with defects. It is our job to continually find those
26,27,32–34
ments. defects and correct them.26,27
Note: Part of assessing a defect can include determining if a per- Healthy culture requires a positive, inclusive, and curious
ceived “defect” (i.e., deviation) is actually an improvement environment that seeks to continuously learn and improve
15475913, 2024, 1, Downloaded from https://aiche.onlinelibrary.wiley.com/doi/10.1002/prs.12505 by SEA ORCHID (Thailand), Wiley Online Library on [27/02/2024]. See the Terms and Conditions (https://onlinelibrary.wiley.com/terms-and-conditions) on Wiley Online Library for rules of use; OA articles are governed by the applicable Creative Commons License
78 OLSEN

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The author declares no conflicts of interest.
18 other elements of Rickover's approach to process Safety. Tap-
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DATA AVAI LAB ILITY S TATEMENT ary 23, 2022. https://www.taproot.com/normalization-of-excellence-
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