Driving Operational Discipline
through
Quality Written Procedures
Brian D. Rains
Global Process Safety Management Leader
DuPont Sustainable Solutions
June 13, 2011
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
2
Today’s Objectives

To share my knowledge and perspectives
about Operational Discipline and the essential
role that high quality procedures play in
strengthening that process

To recommend an 11-step approach to
strengthen an organization’s Written
Procedures

To share the DuPont passion for developing a
safety culture that values adherence to high
quality procedures
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
3
My Background

Chemical engineer by training and an
experienced operations leader – 30 years of
industry experience

Process Safety Management learnings from
operating high-hazard processes and from
extensive, global consulting experience

Am the Process Safety Management Practice
Leader for DuPont Sustainable Solutions
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
4
DuPont Today

208 years of owner-operator
experience

Worldwide benchmark for safety

$32 billion revenue in 2010

Diverse operations in 70 countries,
175 facilities, and with ~60,000
employees

13 core business units including
Sustainable Solutions

A common safety management
system across all operations
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
5
How DuPont Manages Safety and Risk - Step 1
Management Leadership and Commitment - Responsibilities
•
Establish Policy
• Commit Resources
• Provide for and Encourage
Employee Involvement
• Establish Clear Accountability
• Verify Compliance
• Participate Personally
1. Management Leadership &
Commitment
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
6
How DuPont Manages Safety and Risk - Step 2
2. Build a Safety Culture
1. Management Leadership &
Commitment
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7
How DuPont Manages Safety and Risk - Step 3
3. Implement
PSM Program
2. Build a Safety Culture
1. Management Leadership &
Commitment
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
8
DuPont Process Safety Management Model
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9
How DuPont Manages Safety and Risk - Step 4
Operational Discipline Characteristics
4. Operational
Discipline
•
Leadership by Example
• Functioning Capability &
Sufficient Resources
• Employee Involvement
• Active Lines of Communication
• Strong Teamwork
• Common Shared Values
• Up to date Documentation
• Practice Consistent with
Procedures
• Absence of Shortcuts
• Excellent Housekeeping
• Pride in the Organization
3. Implement
PSM Program
2. Build a Safety Culture
1. Management Leadership &
Commitment
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
10
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
11
The Case for Operational Discipline
Do you experience incidents when failure to have or
follow good procedures is an important
cause/contributor?
•
•
In 2001, DuPont
initiated a Six
Sigma project to
assess causes for
significant
Process Safety
Incidents in 2000
OD Involvement in Year 2000 Incidents
Yes
53%
OD was identified
as a dominant
factor in 53% of
the incidents
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No
47%
12
8 Step OD Implementation Methodology
Step 1: Be convinced improved OD is needed
Step 2: Assess the current state
Step 3: Develop a comprehensive roll-out plan
Step 4: Focus on the “It,” High Quality Procedures
Step 5: Establish priorities
Step 6: Strengthen discipline processes
Step 7: Implement
Step 8: Audit, audit, audit
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13
Most Important Procedures to Improve OD
1. Management Procedures or Managing Systems
2. Safety Procedures
3. Operating Procedures
4. Maintenance/Repair Procedures
5. Testing or Quality Procedures
6. Emergency Response Procedures
Principle of Operating Procedures
Operating procedure provides a clear understanding of and
instructions on the detailed operating parameters and
limits for safe operation. They also clearly explain the
safety, health, and environmental consequences of
operation outside process limits and describe the specific
steps to be taken to avoid and correct deviations
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14
Case for Adherence to High Quality Procedures*
•
“The April 2010 Deepwater Horizon incident is the most costly and
damaging incident in recent history, and possibly the worst of all time”
•
“The decision making process on the rig was excessively
compartmentalized, critical decisions [were made] without fully
appreciating just how essential the decisions were… As a result,
officials made a series of decisions… without full appreciation of the
associated risks.”
•
“Some complained that the safety manual was ‘unstructured, hard to
navigate, and not written with the end user in mind;’ and that there is
‘poor distinction between what is required and how this should be
achieved’…Crews were potentially working with a mindset that they
believe they were fully aware of all the hazards when it’s highly likely
that they were not. “
•
“Cement [was prepared] that had repeatedly failed…laboratory tests.
Despite those test results, managers let crews continue with the
cement job apparently without first ensuring good stability results.”
* Presidential Commission on the Deepwater Horizon Incident
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15
U.S. Navy’s SUBSAFE System
•
Between 1915 and 1963, the U.S. Navy lost about one
submarine every 3 years to noncombat causes
•
In 1963, when the nuclear-powered USS Thresher was lost,
112 naval personnel and 17 civilians perished
•
The Navy investigation ‘found deficient specifications,
shipbuilding practices, and maintenance practices, along
with inadequate documentation of construction and
maintenance actions and deficient operational procedures
•
Admiral Rickover, then head of the nuclear Navy, told his
staff to establish a system to ensure that such an accident
would never recur
•
The new SUBSAFE system was established within 54 days
and no SUBSAFE-certified submarine has since been lost
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16
Principles of the U.S. Navy SUBSAFE System
•
•
•
•
•
•
•
•
•
•
•
•
Top management commitment to safety
Clear and written safety requirements
Education, not just training
Regular rewriting of requirements
Separation of powers and assignment of responsibilities
Emphasis on rigor, technical compliance, and work
discipline
Documentation, capturing what is done and why it is done
Participatory audit approach, and requirements for
objective quality evidence
Program based on written procedures, not personalitydriven
Continual certification of a facility
Accountability and accompanying responsibility
Special efforts to be vigilant against complacency
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17
Principles of the U.S. Navy SUBSAFE System
•
•
•
•
•
•
•
•
•
•
•
•
Top management commitment to safety
Clear and written safety requirements
Education, not just training
Regular rewriting of requirements
Separation of powers and assignment of responsibilities
Emphasis on rigor, technical compliance, and work
discipline
Documentation, capturing what is done and why it is done
Participatory audit approach, and requirements for
objective quality evidence
Program based on written procedures, not personalitydriven
Continual certification of a facility
Accountability and accompanying responsibility
Special efforts to be vigilant against complacency
As important as procedures, SUBSAFE establishes a mindset,
a questioning attitude and what the officers call chronic
uneasiness, summarized in the saying, ‘Trust, but verify’
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18
Performance: Function of Managing Systems & Execution
Safety
Management
Standards
Operational
Effectiveness
Operational
Discipline
70%
x
40%
=
28%
State of
Standards
and
Procedures
State of
Implementation
and
Adherence
State of
Operational
Effectiveness
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19
11 Procedures Best Practices
1.
A procedures “Standard” describes what is expected and by
whom
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20
OPERATING PROCEDURES AND SAFE WORK PRACTICES
PSM-OPSP-001
Plant
Page 1 of 1
PSM Manual
Date Revised: 6/23/2010
Revision No: 2
PSM Element Procedure for Operating Procedures and Safe Work Practices
1. Purpose
2. Scope
3. Responsibilities
3.1 Site PSM Operating Procedures & Safe Work Practices Leader
3.2 Area Managers and Unit Operations Leaders
3.3 Technical Personnel
3.4 Qualified Operator
4. Definitions
5. Procedure
5.1 Operating Procedure Requirements
5.2 Safe Work Practice Requirements
5.3 Control of Procedures and Practices
5.4 Procedure for Procedures
6. References
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21
11 Procedures Best Practices
1.
2.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
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22
11 Procedures Best Practices
1.
2.
3.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and
other technology tools are employed
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23
11 Procedures Best Practices
3.
Procedures are well written and easily followed. Visuals and
other technology tools are employed
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24
11 Procedures Best Practices
1.
2.
3.
4.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is
used universally with appropriate procedure headers
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
25
11 Procedures Best Practices
1.
2.
3.
4.
5.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
Every procedure is classified as to importance and risk
mitigation
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26
Increasing Likelihood
Likelihood Category
Overall Risk Classification
6
III
II
I
I
I
I
5
III
III
II
I
I
I
4
IV
III
III
II
I
I
3
IV
IV
III
III
II
I
2
IV
IV
IV
III
III
II
1
IV
IV
IV
IV
III
III
C1
C2
C5
C6
C3
C4
Consequence Category
Increasing Consequence
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27
Consequence Guidelines
Social
Economic
Projects
Environmental
Social
Impact
Minimal
Immaterial
Important
Serious
Pervasive
Extraordinary
Low
Low
Medium
Medium
High
High
Health & Safety
(Public and
Employees)
Incident - no
treatment
First aid/ minor
illness
Medical aid, injury or Temporary disability/ Permanent disability Fatality
illness/ restricted
lost time
work/ Nuisance
public impact
Environmental
Release to on-site
environment,
contained
immediately
Small uncontained
release below legal
limit or with minor
impacts / possible
cumulative impact
on-site
Minor environmental
impact, but result in
permit violation or
administrative
penalties
Significant adverse
impact, significant
long-term liability,
enforcement action
Catastrophic impact,
material (corporate)
long-term liability
cost/schedule
1% - 3% Project
cost/schedule
3% - 5% Project
cost/schedule
5% - 7% Project
cost/schedule
7% - 9% Project
cost/schedule
Financial /
Damage
(Equipment +
Business
Interruption)
C < $100k
$100k =< C < $1M
$1M =< C < $10M
$10M =< C < $100M $100M =< C <
$500M
Reputation
(Political/
Regulatory)
Individual concern/
local media
attention/ no impact
on Suncor's
reputation
Community concern/
regional news/
adverse impact on
Suncor's reputation
at regional level
Provincial news/
adverse impact on
Suncor's reputation
at provincial/ state
level
National news/
Recurring national
public outrage/ short- attention/ punitive
term drop in market action by
share and share
government against
price
company/ long-term
major impact on
market share and
share price
Cost/ Schedule <1% Project
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>9% project
cost/schedule
C > $500M
28
Lifesaving Rules
The following standards are inviolable; if followed, they are known to help reduce
employee exposure, serious injuries and/or death. Thorough job planning will help
ensure that these standards are met. These standards apply equally to both
employees and contractors.
 CONDONING THE VIOLATION OF SITE STANDARDS
 ENERGY CONTROL (formerly LOCK, TAG AND TRY)
 CONFINED SPACE ENTRY
 LINE BREAK (formerly FIRST BREAK)
 HOT WORK
 FALL PROTECTION
 ELECTRICAL WORK PERMIT
 INTERLOCK BYPASS
 RELEASE OF HAZARDOUS MATERIALS TO THE ENVIRONMENT
 RECKLESS ENDANGERMENT
Willful violations of or serious disregard for any of these Inviolable Safety Standards
will subject the involved individual(s) to immediate disciplinary action, which could
result in termination.
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29
11 Procedures Best Practices
1.
2.
3.
4.
5.
6.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
Every procedure is classified as to importance and risk mitigation
All procedures are routinely reviewed, consistent with #5 and
by an appropriate cross section of the organization
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30
11 Procedures Best Practices
6.
All procedures are routinely reviewed, consistent with #5
and by an appropriate cross section of the organization
Periodic Reauthorization of Operating Procedures
All sections and associated content of operating procedures
and safe work practices shall be reviewed and reauthorized at
intervals not to exceed three years.
Qualified operators shall be included in the review process to
verify that sound and accurate practices are reflected in each
operating procedure, and to solicit suggestions for modifications
and improvements, including changes to procedures in order to
minimize the potential for human error.
Operator participation in the review process shall be
documented.
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31
11 Procedures Best Practices
1.
2.
3.
4.
5.
6.
7.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
Every procedure is classified as to importance and risk mitigation
All procedures are routinely reviewed, consistent with #5 and by
an appropriate cross section of the organization
A verification strategy is applied to all procedures, consistent
with #5
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
Confidential
32
“Trust but Verify” – A Continuum
Training
without
Testing
Checklists
without
Auditing
Concurrent
Verification
100% Trust
100% Trust
0% Verify
100% Verify
Peer
Checking
Training
with
Testing
Checklists
with
Auditing
Copyright © 2009 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
Independent
or
Supervisory
Verification
33
11 Procedures Best Practices
1.
2.
3.
4.
5.
6.
7.
8.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
Every procedure is classified as to importance and risk mitigation
All procedures are routinely reviewed, consistent with #5 and by
an appropriate cross section of the organization
A verification strategy is applied to all procedures, consistent with
#5
Content is maintained up-to-date via robust MOC processes
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
34
11 Procedures Best Practices
8.
Content is maintained up-to-date via robust MOC processes
Control of Procedures and Practices Requirements
Sites shall develop and implement a procedures
management program that addresses the preparation, control,
accessibility, approval, authorization, and review of operating
procedures.
Changes to the documented technology or facilities must
be authorized in conjunction with the MOC-T authorization
document. Operating procedures shall be updated and
approved prior to implementing any changes.
Changes that involve subtle changes to facilities must be
authorized in conjunction with the MOC-Facilities change
authorization document.
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
35
11 Procedures Best Practices
1.
2.
3.
4.
5.
6.
7.
8.
9.
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
Every procedure is classified as to importance and risk mitigation
All procedures are routinely reviewed, consistent with #5 and by
an appropriate cross section of the organization
A verification strategy is applied to all procedures, consistent with
#5
Content is maintained up-to-date via robust MOC processes
Initial and refresher training is provided at a frequency
consistent with #5. Written, field and supervisory
assessments are performed
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
36
11 Procedures Best Practices
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
4. Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
5. Every procedure is classified as to importance and risk mitigation
6. All procedures are routinely reviewed, consistent with #5 and by
an appropriate cross section of the organization
7. A verification strategy is applied to all procedures, consistent with
#5
8. Content is maintained up-to-date via robust MOC processes
9. Initial and refresher training is provided at a frequency consistent
with #5. Written, field and supervisory assessments are performed
10. Procedure revisions (documents) are controlled without
impacting broad access to the procedures
1.
2.
3.
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
37
11 Procedures Best Practices
A procedures “Standard” describes what is expected and by whom
Every procedure has a single person owner
Procedures are well written and easily followed. Visuals and other
technology tools are employed
4. Content is consistent with core documents and balances
comprehensiveness with user needs. A consistent format is used
universally with appropriate procedure headers
5. Every procedure is classified as to importance and risk mitigation
6. All procedures are routinely reviewed, consistent with #5 and by
an appropriate cross section of the organization
7. A verification strategy is applied to all procedures, consistent with
#5
8. Content is maintained up-to-date via robust MOC processes
9. Initial and refresher training is provided at a frequency consistent
with #5. Written, field and supervisory assessments are performed
10. Procedure revisions (documents) are controlled without impacting
broad access to the procedures
11. Continuous improvement is driven by metrics and audits
1.
2.
3.
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38
11 Procedures Best Practices
11. Continuous improvement is driven by metrics and audits
Metrics are designed to monitor/insure compliance
•
Number of Overdue operating procedure reviews
 Reported corporately every quarter; Goal is Zero
•
Additional metrics are maintained locally
 Number of near misses (e.g., an excursion above safe
operating conditions
 Number of significant non-conformances involving safe
work practices
Audits insure quality of procedures and their execution
•
•
•
Are in addition to routine authorization reviews
Tiered, standards setting audits
Job Cycle Checks
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39
11 Procedures Best Practices
Procedures “Standard”
Single Person Owners
Well written, easily followed and visual
Consistent, comprehensive and user friendly
Content
5. Importance and Risk Classified
6. Routine Reviews
7. Appropriate Verification
8. Change Management Process
9. Initial & Refresher Training plus Assessment
10. Revisions Controls while Accessible
11. Metrics and Audits
1.
2.
3.
4.
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40
Summary

Operational Discipline is a deeply rooted commitment
by everyone to carry out every task the right way every
time.

The greater the operational risks, the greater the need
for a strong Operational Discipline Culture.

Quality Written Procedures must be a cornerstone for
any attempt to strengthen the Operational Discipline
Culture of an organization

This 11-Step Approach is recommended. It will
strengthen the quality of an organization’s Written
Procedures
Copyright © 2011 DuPont. All rights reserved. The DuPont Oval Logo, DuPont™, and The miracles of science™ are registered trademarks or trademarks of DuPont or its affiliates.
For more information:
brian.d.rains@usa.dupont.com