Conduct of Operations – You Need a Management System
September 19, 2018
If your company is within the United States and is governed by Process Safety Management (PSM), you are required by OSHA to have PSM Systems such as Mechanical Integrity, Management of Change (MOC), Incident Investigation, and Pre-Startup Safety Review (PSSR) – just to name a few. These management systems include standards, procedures, and practices that describe both what's required and how to do it.
The question you need to ask is, "Are the tasks we are performing to comply with these requirements being executed correctly, every time?"
The requirements of your PSM Systems are only effective if you properly address reliable, consistent, and correct execution of these standards, procedures, and practices. Conduct of Operations (CoO) is the set of management systems that define and ensure the execution of operational and management tasks in a deliberate and structured manner.
CoO is sometimes called "Operational Discipline" and is closely tied to an organization's culture. The overall objective of CoO is structuring operational tasks in a manner consistent with the organization's risk tolerance to ensure that every task is performed deliberately and correctly, minimizing variations in performance. By "correctly" I mean, "Everyone doing the right thing, at the right time, every time."
Minimizing variations in performance reduces risk and enhances operational integrity. So, what does a Conduct of Operations Management System look like? There are seven main areas, most with sub-areas of focus within them.
Management Leadership and Commitment
Ownership and Accountability
Performance Goals and Objectives
HSE Governance Structure
Enforcement and Standards of Conduct
Monitor Organizational Performance
Equipment/Asset Ownership and Control
Work Control Systems
Control Access and Occupancy
Control of Maintenance Work
Control Capability of Safety Systems
Equipment Status and Condition Verification
Control of Alarms
Portable Instruments and Tools
Safe Operating Limits and Integrity Operating Windows
Competent and Capable Resources
Recruitment and Selection
Fitness for Duty
Employee Participation and Engagement
Safe Work Practices
Compliance and Verification
Operator Shift Logs
The next question you may be asking is, "If I need it, and I don't have it, how do I get it"?
Here's what we suggest:
Step 1 – Develop standards and procedure that define what each of these CoO Management Systems require and how to do them
Step 2 – Determine what standards and procedures are already is in place, how well are they being adhered to, and what's not in place
Step 3 – Begin closing the gaps by improving what's in place and implementing what's not in place
Step 4 – Audit and continually improve
If you're interested in implementing a CoO Management System or improving your Conduct of Operations, Operational Sustainability, LLC can help.
We've developed a Conduct of Operations Standard that defines and describes the overall requirements as well as the supporting standards and procedures for the individual management systems identified above that are needed to accomplish Step 1
We can survey your employees and managers, follow-up with an assessment to identify what's already in place, what needs improvement, and what's not in place, to accomplish Step 2
As part of the assessment recommend specific actions needed to implement CoO and help with the implementation to accomplish Step 3
Work with you on continuous improvements and follow-up with periodic surveys/assessments