Safety – The Accidental Career

Interesting survey from the National Safety Council.   The NSC does an annual Job Survey of its magazine subscribers.  One of the key findings is that, for 75% of the respondents, safety was not their first career choice.    Most of them also said they were didn’t know it was a career when they were in college.  One factor may be that the majority of people in the poll are older than 50 and safety wasn’t a widely taught field when they went to school.

It strikes me there are two directions the profession can go with this.

  1. Do a better job of promoting the field to students – The article that accompanies the survey points out that safety is an attractive profession for individuals who are motivated to help others, but still want to pick up a healthy paycheck.   One thing I have observed here in Louisiana is that a lot of college freshman are initially attracted to engineering, but lose interest or get beaten up by the math requirements.  Safety, with its focus on human elements and other softer skills, may be an ideal option for these kids.
  2. Consider whether it is really a bad thing for people to not have safety as their first career choice – Maybe a little outside experience is a good thing in a safety guy.   One of the weaknesses in the field are professionals who apply rigid approaches to safety problems.   Some understanding of why we do things may be a critical skillset.

There is also the concern that safety should not be its own island, separate and apart from other departments.   David Dykes of Chevron made the very good point at a recent conference that there should be no wall of separation between operations and safety. Cross-pollinating staff between safety and other departments helps lower those barriers.

Other interesting findings from the survey – A quarter of the respondents said their companies have added safety staff in the last six months and intend on adding more in the next year.   That is not bad, given the economy and the perception that safety is a cost center.   Also, only 22% of the respondents were female.   That gender gap needs to be addressed.

SEMS Management of Change: Why One Size Doesn’t Fit All

One of the most frequent requests I have been getting from customers is for help with Management of Change policies under SEMS.   It has really been driven home to me that one size doesn’t fit all when it comes to MOCs.   The regulations are somewhat specific about what should be considered, but this is one of those areas of safety management where the solution needs to fit the problem.

First of all, what are we trying to accomplish with MOCs?   When they work, MOC procedures are a common-sense way to make sure you haven’t missed anything.  You considered:

  • Options
  • Impacts
  • Implementation
  • Responsibility

Yes, there are regulatory requirements for what things need to be considered, but the goal here is to make the best decision, not to be a slave to the regulations, right?

So what are we considering?

Personnel MOCs vs. everything else – The MOC concept first emerged as a way to weigh decisions involving equipment,  operating procedures,materials, and operating conditions – tangible, quantifiable things that can be measured and defined.    The idea of using MOCs to address personnel came later and is a bad fit.    Trying to apply a cookie-cutter MOC policy to both equipment changes and personnel changes is a waste of time.

Levels of complexity – Some decisions take a formal process.   SMEs gather around the table.   Pros and cons are debated.   Decisions that have a long half-life should be thoroughly vetted and everyone should understand the stakes.   For others, it takes a mental discipline.   Did I think through the options and consider the ramifications.  If that little alarm of doubt goes off in my head, I know I need to kick it up to another level.

Field vs. HQ decisions – In truth we make hundreds of MOC decisions in the field that do not require a full review.   The CEO doesn’t need to be involved in deciding whether the crew drinks decaf.  On the other hand, some of the most dangerous decisions a company makes are made in the boardroom or on the engineering design table.   We are back to the difference between occupational safety and organizational safety, which is one of the fundamental balancing acts of any safety management approach.   Field MOCs need to be clear, simple and easy to follow.   They are focused on the here and now and they need to give workers a clear path to know when they need to kick it up to management. Management decisions on the other hand need to anticipate the impact of a decision years down the road.    For example, the field crew needs a process to consider a workaround.  The CEO needs to be involved in a decision to reduce the size of a mentoring program that may help train future leaders.

All of this argues for a flexible MOC approach that focuses on the goal – wise decisions – instead of a slavish process.

OSHA’s Enforcement Big Three: Where Does Your Program Stand?

If you want to know what enforcement officials at OSHA are concerned about, you don’t have to read their minds.  The agency uses a number of public meetings and conferences to lay out its priorities.     One of those opportunities came last month at an American Bar Association conference when Tom Galassi, OSHA’s Director of Enforcement Programs (DEP) spoke.   He spelled out the three key areas that his group is focusing on (as reported in the Seafarth and Shaw Law Firm’s Environmental Newsletter):

Heat:  Always a biggie with the oil and gas industry, especially with summer coming.   According to the presentation, OSHA did 266 inspections last year on heat-related issues, including 34 following fatalities.

Ergonomics:  The top area for inspections here are nursing homes and other health care facilities.   All told, OSHA did 240 inspections involving ergonomics last year, about average for the agency.

Workplace Violence:   Mr. Galassi says the agency has 29 open workplace violence investigations right now and has issued three citations this year.  He urged  night retail businesses, health care facilities, and social services to make sure they are protecting their workers adequately.

What do heat, ergonomics and workplace violence have in common?  There are no regulations directly covering any of those hazards.  In each case, OSHA has invoked the General Duty Clause Section (5(a)(1) of the OSH Act)  to say that employers have a legal obligation to provide a workplace free of “recognized” hazards that are likely to cause death or serious physical harm.

What does this mean to companies?   First, the top enforcer from OSHA just told you his agency is focused on heat, ergonomics and workplace violence.   You would be well advised to make sure your safety system addresses these areas.   Second, don’t assume that the only hazards you need to address are spelled out in regulations.  The General Duty Clause has turned into one of, if not the, chief enforcement tool employed by OSHA.

Buddy-to-Boss Supervisor Workshop In Lafayette, May 22

Think back to when you got your first promotion to manager.   Suddenly having to manage co-workers was probably the toughest transition of your career.

Are you giving your supervisors the tools they need to be leaders? 

I will be premiering a brand new workshop for supervisors on May 22 in Lafayette, LA.  The purpose of this workshop is  to help supervisors  make that difficult first step from being just another guy on the crew to managing the crew.

Learn more and register here.

This highly-interactive, fast-paced workshop uses exercises and video to help supervisors adjust to their new responsibilities.   The topics covered in this workshop include:

  • Dealing with co-workers who may be resentful or expect special treatment
  • Coaching workers
  • Leading by example
  • Managing in the “fishbowl”
  • Why “leaders eat last”

 Because this is a new class, we are offering a special introductory rate for participants who sign up by May 8th.

Register here.  For more information, contact Ken Wells, Lifeline Strategies  (985) 789-0577 or KenWells@LifelineStrategies.com.

New Macondo Study Coming – Helpful or Too Little Too Late?

The anniversary of the Macondo accident brought an announcement from the Chemical Safety Board (CSB) that it plans to hold a public meeting in Houston on June 5 and release a report on the incident.   According to a statement from the CSB chair, “first two volumes of our four-volume investigation report, covering technical, regulatory, and organizational issues.”

The incident has already been studied by several groups and the findings were consistent enough that it is worth asking what one more study will accomplish.   CSB says it will look at areas that were not adequately covered in other studies:

  1. The publication of new findings concerning the failures of a key piece of safety equipment—the blowout preventer—that was, and continues to be, relied upon as a final barrier to loss of well control
  2. A comprehensive examination and comparison of the attributes of regulatory regimes in other parts of the world to that of the existing framework and the safety regulations established in the US offshore since Macondo.  
  3. In-depth analysis and discussion of needed safety improvements on a number of organizational factors, such as the industry’s approach to risk management and  corporate governance of safety management for major accident prevention, and  workforce involvement through the lifecycle of hazardous operations.

What does all that mean?   CSB has already tipped its hand a little on a couple of those points.   First, on the blowout preventer – Most of the studies of Macondo have focused on what might have gone wrong with the upkeep or use of the BOP, particularly test results that indicated that high pressure fluids rising up from the  well pushed the drill pipe off center.     For some time there have been rumblings that the CSB’s investigation was  pointing it in a different direction.   It is not known whether CSB is still pursuing an alternate theory of why the BOP failed but, if so, it would open new areas of study.

Second, Safety Case – This approach is used in the North Sea, but has largely been pushed to the side in the U.S.   CSB has sponsored a number of studies on the use of safety cases.  Chances are great that CSB will recommend the adoption of that approach.

How much impact will this report have?   Hard to say.  the CSB is a new government agency that is still trying to establish its role.   On the technical side, industry is likely to argue that CSB is a latecomer to the design and use of BOPs.  On the safety case side, other agencies like BSEE and the Coast Guard are already moving forward with their regulations to address Macondo.  As one expert said at a joint agency listening session on performance-based standards, “Since we still haven’t fully implemented our own safety management approach, how can we say it doesn’t work and that we should abandon it for the safety case approach?”

CSB said the results would be released at the June 5 meeting, but it has not announced the time or place.

GHS Update to HazCom: Several Thousand Reasons to Train

We are still waiting for OSHA to move into an  enforcement mode on companies that failed to train their workers on the new Global Harmonization System updates to HazCom.  However, we may have some indication of how hard the agency will throw the book at companies that don’t provide the required training.

The GHS updates went into effect last year and companies had until December to train everyone on staff.    OSHA is said to preparing to release its directive to the field on enforcement.

However, according to the website EHS Today, OSHA recently charged an Ohio company for failing to teach HazCom to employees prior to the GHS updates and the fines were expensive.   Globus Printing & Packaging Co. Inc. was reportedly cited by OSHA for 24 alleged safety and health violations last summer, including a charge of not providing proper training.   The fine?  A proposed $91,800.

No telling what OSHA will do to companies that failed to train on the new standard by the deadline, but this case may be an indication that it won’t be cheap.

Walking The Walk: The Dangers of Walking and Texting

We’ve heard plenty about the dangers of texting while driving, but how often have you watched a pedestrian stumble through a crosswalk because he was trying to text while crossing the street.

The University of Queensland in Australia put volunteers through an experiment where researchers studied people walking normally, reading texts while walking and typing texts while watching.   The results are ugly.

textorThe study used terms like “in-phase motion of the thorax” and “virtual pedestrian environment experience,” but thankfully the excellent website Safety News Alert translated it all into English.   Apparently, the researchers had volunteers walk in a straight line for about 30 feet.   Then the volunteers were asked to walk again while writing or reading texts.   Suffice it to say, texters seemed to wander a bit. It didn’t really make much whether the volunteer was writing or reading texts, they still wanders, causign the report to refer to them as “texting zombies.”

Of more importance to the researchers was the finding that people tended to walk with a stiff-legged gait when texting, making them more prone to trips or falls (or not noticing that the light has changed in an intersection).  Safety News Alert quotes the lead author, Dr. Siobhan Schabrun, as saying, “People walk like robots. They try to keep their head straight so their eyes can stay on the phone. They lock their arms, their trunk and their head together.”

The authors say this is a first of its kind study.  Now science may need to turn its attention to the implications of playing Farmville while walking.

SEMS Warning Signs: Paper-Thin Plans Won’t Cut It.

The Center For Offshore Safety held a very successful conference last week.  Generally speakers were upbeat, with a lot of focus on safety culture.   But there were warnings that SEMS plans that look good may just be paper thin.  Based on who was giving the warnings, industry can’t afford to ignore them.

With any safety management system, there will be differences between what is put down on paper (where it looks great) and what is actually going on in the field (where it tends to get messy).   I call that difference the reality gap.   Sometimes the gap is so narrow you can’t see daylight between the plan and the field execution.

However, based on some of the speakers at the COS conference, the SEMS reality gap for some operators is enormous.   Perhaps the most important warning came from the Director of BSEE, Brian Salerno.    His written remarks are here, including this warning:

One of the major disconnects is between operators and contractors. Many contractors are simply not familiar with safety procedures on a facility, nor is the operator making much of an effort to ensure safety consistency. This has had some horrifying results, and remains an area of concern for us as we consider the future of  the SEMS program.

In the Q&A section of the session, Salerno was even stronger saying BSEE would not allow the SEMS audits to be come a “rogue process…prone to being gamed” by industry.

For anyone who might not follow Washington speak, when the head of the agency that oversees offshore oil and gas says many contractors don’t even know what the safety practices are on the facility and operators aren’t trying very hard to inform them, you take the message seriously.   When a regulator used the words “horrifying results” and that they are looking at them as they “consider the future of” a regulation,  that translates as “get your act together before we do it for you.”

Next up was Coast Guard Rear Admiral Joseph Servido who gave industry a spanking over the state of inspection readiness on vessels in the Gulf.   He talked in particular about a vessel company that called the Coast Guard to do a routine inspection of three vessels that already had International Safety Management Code plans in place.   What did the Coast Guard find? Fire-detection systems that had been bypassed and inoperable rescue boats.  Remember, this wasn’t a surprise inspection.  The company had called the Coast Guard to schedule the inspection.    Why is this a concern for SEMS?  Because the Coast Guard is making the case for requiring OSVs and MODUs to have SEMS plans.  These kinds of nonconformities are just ammunition in that debate.

Finally, when a panel of auditors discussed lessons learned form the SEMS audits, one speaker said that they found too many cases where documents they were shown for their review had never made it out to the people working on the facility.

That is a reality gap.   It indicates a battle plan that not only doesn’t stand up in the heat of battle, but has never even been shared with the troops on the front lines.

Five humble suggestions to avoid what may be a regulatory hammer:

  1. Bridging documents and MSAs need to reflect an operator’s real expectations under SEMS.
  2. These documents need to be shared with operations and HSE departments and not be stuck in the sales departments files.
  3. Bridging documents need to stop being templates and start becoming actually dialogues about whose safety practices are going to be followed and why.
  4. Operators need to beef up their orientations so that they actually explain how SEMS is implemented on a facility, how documents are to be shared and kept.
  5. Now that SEMS  plans are in place and established, focus on how those plans are communicated so that the people in the field can understand them and follow them.

Clearly not every one of these problems apply to every operator SEMS plan and it is not right to paint the industry with the same brush.    However,  if these problems are extensive enough to cause regulators need to step in and fix them, won’t everyone in industry have to live with the results?

Kicking Over The Ant Pile: USCG Tackles Non-crew Training on MODUs & OSVs.

One of the lessons from the Macondo disaster was that the jobs people do on vessels  in offshore oil and gas are out of sync with the regulations.    Whether it is a MODU involved in drilling or an offshore workboat  performing sophisticated well control operations, Coast Guard oversight is generally limited to seafarers.  That ignores a lot of workers who are lumped into the general category of “persons other than crew.”

The Coast Guard just opened up the whole can of worms by releasing an Advance Notice Of Proposed Rulemaking (ANPRM) that tackles the issue head-0n,  The ANPRM, titled Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities seeks public comments by July 14th on a range of concerns that reflect the Coast Guard’s view that there are too many questions about non-seafarers on oilfield vessels.

What training do they require?  What are the lines of authority?   Who is responsible if things start blowing up?   It is a hugely complex problem and every technological advance we make to the work vessels do in offshore oil and gas just adds more moving parts to the problem.   We know that the vessel master and other seafarers need training on safety and other emergency response practices, but what about all the workers who are involved with anchor handling, ROVs, company representatives and other specialty workers who may find themselves on vessels?  (I think here about a paleontologist I once meet who spends his days on a drill ship looking at microscope slides…not exactly Popeye, the sailor man).

These questions of chain of command, decisionmaking authority and training for non-seafarers played such a prominent role in the  investigation of the Macondo disaster that the agency committed to address them through a rulemaking.

And here comes that rulemaking. It is bound to be controversial because the questions the Coast Guard is trying to address do not have easy answers.   Or cheap answers.   The Coast Guard indicates it may want everyone on the vessel to go through some level of basic training. Right now STCW Basic Training is a five-day course.

It could also require a clear and unambiguous document that explains the lines of authority on the vessel.   That opens up a whole liability/insurance risk area that has been glossed over in the past.

Finally, it could put the Coast Guard on a collision course with BSEE over the question of who is in charge.  Coast Guard regulations say it is always the Master of the vessel and this rulemaking may put the responsibility on the vessel to define lines of authority after that.    BSEE puts the responsibility on the oil and gas leaseholder to determine the “Ultimate Work Authority,” specific to each type of operations (drilling, production, P&A, etc.).   It is going to take some coordination between agencies to work that out and then if will take coordination between vessel owners and oil companies to put it into practice.

 

Announcing SEMSReady – One Stop Solution For Contractor Skills and Knowledge Evaluations.

Explaining SEMSReady Certification at the COS Safety Forum in Houston
Explaining SEMSReady Certification at the COS Safety Forum in Houston

This week at the Center for Offshore Safety (COS) Annual Forum, we announced a new service for oil and gas contractors – SEMSReady Certification of Skills and Knowledge Management Systems.   As background, most offshore operators now require their contractors to evaluate their personnel to make sure they know how to work safely offshore.  The COS has issued guidelines for acceptable skills and knowledge management systems and more operators want their contractors to meet those guidelines.

My company has partnered with OQSG, a Lafayette firm with extensive experience in evaluating workers under DOT pipeline OQ rules and in offering a training tracker database built specific for skills and knowledge evaluations. Together, we offer SEMSReady which teaches companies how to meet SEMS evaluations.

Now we are expanding SEMSReady to help companies meet the COS guidelines and then to certify their programs.  The information below explains the program.

Incidentally,  our next SEMReady class in Lafayette is sold out, but we do have openings in the Houston class to be held on Thursday, April 17.

For more information on classes or certification, contact me at KenWells@LifelineStrategies.com or call at 985-789-0577.

___________________________________________________

New SEMSReady logo

SEMSReady™ Certification takes the guesswork out of meeting Operator requirements for Contractors to develop a SEMS Skills and Knowledge Management System (SKMS).  It follows the basic principles and good practices outlined by the Center for Offshore Safety Skills and Knowledge Management System Guidelines.[1]

The SEMSReady™ SKMS

SEMSReady’s™ unique approach helps companies:

  • Determine specific skills and knowledge requirements needed to perform offshore jobs
  • Create and conduct objective and consistent skills and knowledge evaluations
  • Train evaluators to perform accurate evaluations
  • Create an auditable program to verify system integrity
  • Manage documentation and records to meet regulatory requirements

Advantages of SEMSReady™ Certification

A number of Operators require Contractors to meet complex training matrices and to verify the skills and knowledge of their workforce under SEMS.   In the future, many will expect contractors to develop a skills and knowledge management system that follows the Center for Offshore Safety’s model.

A SEMSReady™ Certification supports the accuracy of a Contractor’s SKMS through a standardized development process and third-party review. SEMSReady Certification increases the validity of the program and decreases the auditing burden for Operators.

Five step process to achieve SEMSReadyTM Certification:

Step 1 One-on-one assistance for creating a Skills and Knowledge Management System or enhancing your existing system to meet industry practices.
Step 2 Train SKMS administrators and evaluators on the SEMSReady™ approach and validate their credentials.
Step 3 Utilize SEMSReady’s™ standardized process to create and document the path to competence
Step 4 Manage documentation and records to meet regulatory requirements using Pinion CoursewareTM or ensure that your existing data management system meets the SKMS guidelines.
Step 5 Program review by SEMSReady™ representatives to validate and determine certification

 

 


[1] SEMSReady™ has not sought or received the endorsement of the Center for Offshore Safety.   The program is based on a commonsense interpretation of industry practice.