The problem with "correctly" is that, by itself, it is subjective. If we want things done "correctly," we have to make the requirements objective. "Correctly" is typically situational.
In general, I divide practices into guidelines, policies, standards, and procedures. Others may have different divisions or specifications.
Guidelines may apply to any of the other three. They typically exist to save time or money and are not required to be safe, to be environmentally sound, or to avoid damage. Application of guidelines is up to the operator. There's nothing specifically "correct."
Policies are broad statements of organization objectives. For example, we will comply with all published environmental regulations. There is obviously a "correct" response, but objectivity is lacking because the statement is too broad to measure.
Standards provide steps required to comply with the policy. For example, placing equipment in service requires that all instrumentation is operable and all vents and drains are closed and capped. This appears measurable, but it does not necessarily provide enough guidance to ensure "correctness." Holding an operator accountable for meeting this standard would probably be unfair and unjust.
A procedure describes exactly what must be done to comply with the policy. For example, Instruments A, B, and C must be placed in service and, if necessary, here are the specific actions required to ensure that happens "correctly." Likewise, drains 1d, 2d, and 3d and vents 1v, 2v, and 3v must be closed and capped "correctly." This may appear burdensome, but how can an operator be held accountable if we do not specify exactly what we need and expect?
If leadership is unwilling to do the work -- and I can testify that fully-developed procedures are a LOT of work -- to identify what is "correct," they cannot justifiably hold operators accountable.
I have found that fully developed procedures uncover many potential Abnormal Conditions. When I write a procedure, I ask myself at each step what happens if flow, pressure, temperature,
etc. deviates from the expected. The responses may most often be guidelines rather than procedures, but that's OK. We cannot anticipate all Abnormal Conditions, no matter how smart or experienced we are. We cannot hold operators accountable for "correct" action unless we can define fully what "correct" action is. That probably doesn't satisfy regulators (corporate or government), but it ensures justice.
Being "correct" is not always appropriate. Operators must understand their processes (and themselves) well enough to be able to address complex problems when they arise. I know the urge to second guess is sometimes overwhelming, but it has to be resisted. There is a difference between second-guessing and working toward a root cause. If we do not make that clear to our organizations, we are not "correct."
I've rambled enough. That's probably "incorrect."
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Steven Osborne
Luling LA
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Original Message:
Sent: 08-16-2019 00:24
From: Steve Cutchen
Subject: Operational Discipline
Here's my concern with "the performance of all tasks correctly every time:"
The term "correctly" is judged after the fact. The seeds of this are here in the comments. Sometimes it means "by the procedure" but sometimes it doesn't. Sometimes there is room. That minefield is up to the operator to navigate in real time.
Judging occurs after the fact, and leads to Outcome Bias (see below), assigning hero versus failure. If it worked out, it was done correctly.
Hindsight bias (see below) can then be used to place blame.
At GCPS, I've heard Operational Discipline commonly defined as "Always follow the procedure" and Discipline come to mean "a punishment inflicted to correct disobedience, poor behavior, or poor performance." Operational Discipline becomes Discipline of Operators.
Leadership can fall from enablement to enforcement. A search through the binders and we can find a violated procedure.
What happens in Abnormal Operations situations; unplanned, where there are no procedures or which cannot even be proceduralized? These Abnormal Operations are the initiating event for most incidents.
if Operational Discipline is a keystone for assuring process safety, and if it is limited to 'Always Follow The Procedure,' how does it help in the majority of process safety incidents that are not or cannot be proceduralized?
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Outcome Bias: the tendency to evaluate prior decisions according to whether the outcome was good or bad. A common belief is that bad events can only arise as the result of bad decisions, and conversely. But history teaches us otherwise: good decisions can still have bad outcomes
Hindsight Bias: the tendency to view past events as somehow more foreseeable to the people on the spot than they actually were. This is one of the reasons why what seem to us to be obvious warning signs are often ignored. But such warnings are only effective if the participants know what kind of bad event they are headed for, and this is rarely the case. You do what makes sense at the time. So do other people.
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Steve Cutchen
Investigator
US Chemical Safety Board
Houston TX
Original Message:
Sent: 08-15-2019 11:50
From: Steven Osborne
Subject: Operational Discipline
I like Gary's wording. Where something is absolutely mandatory, procedures should make that clear and "correctly" would require that the action be performed exactly as prescribed. In most cases, room should be left for improvisation to match the circumstances, and "correctly" means the task is completed in a timely manner, cost effectively, and with little or no risk to people, the environment, or the facility. To achieve optimal performance, "correctly" has to be determined situationally. Regulators, in my experience, don't always like that answer.
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Steven Osborne
Luling LA
Original Message:
Sent: 08-15-2019 09:35
From: Gary Hilberg
Subject: Operational Discipline
Steve - very broad question but a good one. I Agree with Anh on performance to standards but we all know that there are various level of standards and the level of absolute compliance should vary. It is imperative that management identify high risk operations where any deviation is not acceptable while, in the interest of efficiency and effectiveness low risk procedures may allow more variation. The submarine force we did this with the nuclear work/operations - many areas around reactor safety required two person check offs and more reviews while the low pressure steam systems had lower levels of controls - but these were identified by the procedure type and the actual steps in the procedure. If we tried to apply the nuclear standards to all work, the time and personnel would not be available. In summary if management does not take the time to properly train and provide the documents/standards that are appropriate the worker will be forced to make decisions on compliance that can be hazardous for them.
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Gary Hilberg PE
President
Continuum Energy
Cypress TX
Original Message:
Sent: 08-14-2019 17:08
From: Steve Cutchen
Subject: Operational Discipline
In the CCPS definition of Operational Discipline:
The performance of all tasks correctly every time.
what does "correctly" mean to you?
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Steve Cutchen
Investigator
US Chemical Safety Board
Houston TX
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