Evolving Safety Culture: Leading Indicators to Look For

 

Interesting article on growth of safety culture in the Marcellus Shale area in the east.    It was based on a presentation given by Laura Helmrich-Rhodes, an associate professor of safety sciences at Indiana University of Pennsylvania.   Dr. Rhodes looks at seven signs of an emerging safety culture within a company.   She says these indicators are taking hold in the Marcellus.   How does your company match up?

 

  • Is there true top management commitment to safety?
  • Are employees really empowered to stop work if they see an unsafe situation? Are employees involved?
  • Is there an effort to choose contractors that emphasize safety — even vendors for noncore activities like janitorial or catering services?
  • Is there an instant investigation into any near-miss scenarios so that change can be made.
  • Are near-miss and incidents reported not just to management but to all employees so lessons can be learned?
  • Are risk takers terminated and not celebrated?
  • Is safety given its share of the budget?

Two things that make this notable –  First, drilling in the Marcellus only started about five years ago.  There have been growing pains and a steep learning curve for companies and workers.   The second thing is that Dr. Rhodes believes the safety culture that is taking hold in the Marcellus drilling fields could hold important lessons for other industries, like construction.

Better Double Check the Paperwork: Ohio Man Finds Out He is Still Dead

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Done a check of your records lately?  An Ohio man, who disappeared in 1994 and was legally declared dead,  went to court recently to try to have that decision reversed, in as much as he is still very much alive and would like to get a drivers license.  However, the judge said that a three-year time limit for changing a death ruling and, since that had passed, the man is still dead in the eyes of the law.  The judges calls it a “strange, strange situation” and the man says “”It kind of went further than I ever expected it to.”   Read more here.

OK, so this isn’t about  safety management, but it is about making sure you can keep your documents up to date and that is a big part of safety management, so the lesson here is, make sure your records and documentation are in order, or you may have a hard time proving you have a living, breathing safety program.

Skills and Knowledge Under SEMS 2: A Tough Issue for Operators & Contractors

Last week we started a series of blog posts looking at the SEMS requirement for Operators to verify that Contractor personnel have the skills, knowledge and experience to perform their jobs safely and effectively.  Today we continue that series by focusing on the unique challenges this creates for the industry.

The Problem for Operators

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In the old days, oil companies hired Contractors for their ability to do the job.  It was up to the Contractor to figure out what their employees needed to know in order to do the job right.  The proof was in performance; it was right or it wasn’t.  True, you can only judge performance after the fact, so everything was viewed through the rear view mirror.   But it was a pretty simple system to manage; “You mess up, your fired.”

SEMS changed that.  Now, Operators need to look beyond the performance of the companies they bring in on a project and determine whether each worker has the skills and knowledge to do the job before the job starts.  In fact, in one guidance document, BSEE indicates that Operators need to verify the skills and knowledge of each and every contractor employee who is involved in the project.   Wow!  That’s like saying you need to make sure the newspaper delivery boy knows how to ride a bike before you subscribe to the paper.

First, it is an overwhelming task given the thousands of contractor personnel involved in the industry.   Second, the truth is the Operators don’t really know all that much about many of the jobs that are done offshore.   If they wanted to be in the welding business, they wouldn’t need to hire welders.

The Problem for Contractors

The challenge for Contractors is a complex one.   First we need to start with an understanding that, statistically, the offshore world is a pretty safe place to work.   According to the U.S. Bureau of Labor Statistics, in 2011, the offshore injury and illness rate was 0.8 incidents per 100 full-time workers, compared to a rate of 5.0 for the transportation sector and 4.4 for manufacturing.   A lot of that success is because offshore workers are pretty good at what they do.   So the issue is not so much competence, as how we measure competence.  That is where Contractors are having trouble.

For starters, we don’t even have common job titles and descriptions offshore, much less standardized skills and knowledge requirements.   Two completely different jobs may have the same title (try figuring out whether a mechanic  does maintenance or installation of equipment) and two different titles may describe the same job (Does a Field Service Specialist need to know more than a Field Service Technician?).   To give one specific example, the master of a liftboat and the master of an OSV are both captains, but their daily jobs are very different.

The other problem is that, while we may believe our crews are, we don’t have objective criteria to prove it.   If you ask the owner of a small Contractor company how he knows he has the right people on the job, the answer will probably be “because I have been doing this for 25 years.”

Unfortunately SEMS doesn’t care if we have really good intuition that workers are skilled. Verifying skills and knowledge under SEMS involves having a process that backs up “having a good gut feeling that kid will make a good wireline operator” with objective, documented and auditable proof.

That is the challenge that will define this issue for the next year or two.  In a future blog post, we will look at how one industry successfully addressed that problem and the lessons that may hold for the offshore world.

The Five Stages of SEMS

I was talking with Katherine Warren of the Boxley Group, who works with works with oil and gas clients on information management and process improvement, and she jokingly referred to contractors wrestling with SEMS going through the five stages of grief.  It struck me as pretty apt.   So here is my take on the “Five Stages of SEMS:”

  1. Denial“SEMS doesn’t apply to us.  That’s something the oil companies have to do.”    (or “We hardly ever go offshore”  and “We don’t work in deepwater.”)
  2. Anger – “What do you mean, I have to fill out a training matrix?”   (Or “ Why should I send you my Safe Work Practices?  My company has been working for you for 15 years!”)
  3. Bargaining“Just let us finish this job and we will have the records straightened out the next time you need us.”
  4. Depression “Not another audit!”
  5. Acceptance “So we hired someone to just fill out the online questionnaire, we’ve uploaded all our RAVs, we met all the training requirements….what?  The project got delayed?”   

So where is your company on the Five Stages of SEMS?

The Hot Issue on SEMS Right Now: Skills and Knowledge

The SEMS issue that you hear the most about right now is probably the requirement that Operators verify the skills and knowledge of Contractor personnel.  We are going to devote the next few blog posts to exploring the issue, where companies are today and some of the solutions that are starting to emerge.

welding2

This is certainly one of the toughest parts for both Operators and Contractors to get their arms around.   The SEMS and SEMS II regulations have something like 11 references on the need for Operators  to verify skills, knowledge or experience of personnel,  such as:

  • You are responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and  are conducting these activities in accordance with the requirements in your  SEMS program.” (30 CFR 250.1914 (b) (2))
  • “Periodic training to …verify  adequate retention of the required knowledge and skills.” (30 CFR 250.1915 (b))

The requirement doesn’t just involve personnel who go offshore either.  Shoreside activities like maintenance and design work may also fall under the regulations.

For industry it has been a huge shift in focus, from hiring companies and then expecting them to do the job safely and correctly to making sure that each worker knows how to do his or her individual job before they start work, at least under a strict reading of the SEMS rules.

So how has industry addressed this?  For the first year or two of SEMS, the focus has been on collecting pieces of paper – certificates, diplomas, class rosters, resumes – anything that shows evidence that a worker was at least  taught required aspects of the job.

The concern is that that is not enough.   Sitting through a class doesn’t prove you know how to do something or that you know the right way to do it.  After all. how many of us really want to go back and try to pass that geometry test we took back in Junior High?   Besides that,  a lot of the most skilled workers in the industry learned through on the job training.   How do we track that?

Over the last few months Operators are increasingly looking at worker skills evaluations as a way to drill down to whether the individual has the specific skills to do the job right now.   Apache (whose shelf assets have now been sold to Fieldwood Energy) led the way on this by requiring Contractors to provide evaluations of their personnel every year.  Apache/Fieldwood doesn’t tell Contractors how to do that, just that it needs to be documented and auditable.

As more and more Operators adopt that model, the focus is turning towards and effective and standardized model for the evaluations.  More on that in a future blog.  If you are looking for help complying with this area, feel free to contact us.

 

GHS Training Deadline: Seven Weeks And Counting

OSHA says that more than 40 million workers must be trained on the new  Globally Harmonized System (GHS) updates to the HazCom Standard by December 1st.
No word yet on whether OSHA will be out in force in December, checking to see if the training has been done, but it will certainly be a part of enforcement efforts if chemicals are involved in a violation.

GHS Pictogram

Companies that work in offshore oil and gas may take come comfort in knowing they are many, many miles from the nearest OSHA inspector, but many forget that there is a HazCom connection through SEMS.  The Operating Procedures element of SEMS says Operators need to have procedures for the “properties of, and hazards presented by, the chemicals used in the operation” and “Control of hazardous chemical inventory.” (30 CFR 250.1913)

That raises the potential that BSEE inspectors, who have a formal agreement with OSHA to enforce regulations, and SEMS auditors may come looking for proof that personnel have been trained in the new GHS updates.

If your company needs help training personnel before the December deadline, contact us.

As The First Round of SEMS Audits Winds Up, Questions About What The Next Round Brings

Offshore operators have, by and large, finished their first round of SEMS audits.   There will be lessons learned and adjustments to be made but the big question is:  What will BSEE expect from the next round of audits?  This round tended to focus on audits of operator management systems, rather than compliance or performance (meaning whether the operator’s SEMS was in place, rather than whether every piece of the plan was being met).

However, that may change.   Some months ago, Chuck Simpson, owner of WorkSafe International and one of the more respected auditors in the Gulf, pointed out to me that the new SEMS II revision adds some new language on the audit requirements.  It says audits “must also identify safety and environmental performance deficiencies.”

From an audit standpoint that could be a huge change, potentially requiring extensive on-scene physical audits and evaluations of contractor records.    While no one argues that the goal of SEMS is to control the potential for safety and environmental incidents, audits of safety management systems tend to focus on the systems level.   How a company addresses incidents and near misses is usually viewed as a process at the systems level.  In other words, if something goes wrong, does the company adapt its system to prevent the problem from happening again?

The Center for Offshore Safety’s (COS) Program Manager for Audit Accreditation, Om Chawla, spoke at the Offshore Safety and Workforce Capability Assurance Conference this week and I had a chance to ask him about the change.   He said COS is very aware of it, is concerned that it changes the focus of the audit process and is in dialogue with BSEE to see what the agency really intends.

Wait and see.

 

Want A Good Safety Program? Steal It!

3d-Steal-Like-an-Artist-NYTOK, let’s see how many people hate this concept:  If you want to implement a good safety program, STEAL IT!    But don’t steal from just one company, steal from everyone you can.

I stumbled on a book called “Steal Like An Artist” by Austin Kleon the other day.   His point is that nothing is completely original, it all builds from the things that came before it.

I realized that this applies to safety as well.  A lot of people have come up with their own version of some safety advancement and the natural thing is to try to “protect the brand,”  but in reality, every step forward we take in safety builds on some advance that someone else did somewhere else.   So maybe we need to admit that and, if we are stealing, let’s steal from the best.

Just a few concepts from the book that may apply to this process of taking the best of what is around us to develop our own programs:

  • Don’t think for a minute that you are coming up with some great program that no one has ever thought of before.
    • “There’s nothing new under the sun” (Ecclesiastes 1:9)
  • Don’t worry about what safety initiatives are good or bad; the test is whether you would want to use it.  Or as Kleon says “there’s only stuff worth stealing, and stuff that’s not worth stealing.”
  • A great idea isn’t worth much if it isn’t being used and you might as well be the one to use it.
    • “Everything that needs to be said has already been said.  but since no one was listening, everything must be said again.” (Andre Gide)
    • “It is better to take what does not belong to you than to let it lie around neglected.”  (Mark Twain)

There is another way to look at all this.   If company A has a better lockout/tagout policy than company B, doesn’t company B have a duty to its workers to adopt the better program?    Is that stealing or being responsible?

That is not to say safety professionals shouldn’t get paid for their work and the programs they develop, but it is saying we should not ignore other safety initiatives just because we didn’t think of them first.   We often hear that safety shouldn’t be a secret.  This concept moves it one step forward.   Safety needs to be stolen.

 

What’s Behind The Coast Guard Drive to Make Vessels Have SEMS Plans?

Should vessels have Safety and Environmental Management Systems (SEMS) plans that align with their offshore oil customers’ SEMS plans?  On September 10th, the Coast Guard published an Advanced Notice of Proposed Rulemaking (ANPRM) which would require SEMS plans for certain vessels working on the Outer Continental Shelf.

This may be one of the most significant regulatory changes facing the vessels that work in the oil and gas world.  the Coast Guard says it “intends for this SEMS to be developed and implemented by the vessel’s owner or operator and compatible with a designated lease operator’s SEMS required under Bureau of Safety and Environmental Enforcement (BSEE) regulations. The Coast Guard seeks comments on whether a SEMS that incorporates the management program and principles of API RP 75 is appropriate for vessels engaged in OCS activities, would reduce risk and casualties, and improve safety on the OCS.”

The rule could  affect 2200 vessels:

  • 1,800 Offshore Supply Vessels (OSVs),
  • 150 liftboats,
  • 125 MODUs,
  • 125 other vessels.

What’s behind the proposal?

Probably a lot of things, starting with the need to align MODUs with SEMS.   SEMS is centered around managing safety and environmental requirements on facilities.    On drilling projects, the operator has to have the SEMs plan but the facility is a MODU, and much of the facility-specific information is under the control of the drilling company.  Both BSEE and the USCG want to make sure there is no disconnect between the operator’s SEMS and the driller’s safety program.   By taking the lead in requiring MODUs to have SEMS plans, the Coast Guard may be sidestepping an inter-agency squabble over whether which agency controls safety on the vessels.

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But there is more at stake with this rulemaking because it affects more than just MODUs.  The reasoning for the Coast Guard is that the ISM code is not specific to offshore energy sectors, “this Code assumes a vessel’s mission is international transportation of cargo, not OCS activities.”  Translation: ISM fits some but not all of the safety framework of offshore operations.   For example, many crew members on an offshore construction vessel are not “seafarers” under STCW.    The Coast Guard wants to close those gaps.

Finally, there is a deeper reason for this proposal.    The Coast Guard regulations have not kept up with technology.   The last revision to the Subchapter N regulations governing OCS safety came out before the first deepwater facility was even in production.   Today, a lot of well activities are done on the ocean floor by workboats using ROVs.   These boats fall into a regulatory shadow, largely outside the direct authority of BSEE and beyond the expertise of most Coast Guard personnel.    The proposal would be one way to oversee those operations and provide the regulatory muscle to make sure operator SEMS and vessel safety programs are in line with each other.

An ANPRM is the first step towards a new regulation.  It is when the agency asks industry and the public what the future regulations need to look like.     In this case, the public comment period is open until December 9, 2013.    Industry needs to take advantage of this opportunity to have its say.

Decommissioning in the Gulf

Apache_UK_Beryl_BravoNew report on Decommissioning in the Gulf of Mexico – $1.3bn and $1.7bn  spent on P&A work last year.   An eye-popping figure.    Apache leads the pack in money spent to remove structures.    The report comes from Prof. Mark Kaiser of LSU, who has become one of the top experts on the impact of decommissioning work.   Here is a story about the study.

SEMS came in  response to a drilling accident, but this is a reminder that so much of the work in the Gulf is decommissioning (and with a lot of work comes a lot of risk).