Page 129 - Serious Incident Prevention How to Achieve and Sustain Accident-Free Operations in Your Plant or Company

CH10pp103-110 4/10/02 12:50 PM Page 107

Establishing Performance Standards 107

facturing managers to develop and implement action plans and procedures
specific to each operating unit. To ensure that process equipment inspec-
tions accomplish their intended purpose, inspections must be executed in
conformance with appropriate performance standards. In conducting a pre-
startup inspection, for example, guidelines should be developed to assign
responsibility and document how the inspections will be conducted.
Expectations should be established for both target levels of perform-
ance and for specific methods of performance. As one moves down the or-
ganization chart, standards need to become more specific and detailed. At
the point-of-control level, operating and maintenance procedures, together
with work authorization permits, are examples of the documentation needed
to provide detailed guidance for the execution of critical work. Such docu-
mentation helps ensure that the numerous actions and special techniques
necessary to sustain long-term success are properly performed.
Reducing the frequency of accidental spills and releases is a common
safety and environmental-related objective for chemical facilities and re-
fineries. Performance standards in the form of action plans and procedures
are essential in documenting critical actions needed to achieve the desired
reductions. An effective action plan for reducing spills and releases should
include steps to evaluate causes of past incidents, prioritize opportunities
for improvement, and initiate improvement actions. Examples of operating
and maintenance practices with potential for reducing hazardous material
spills include: double checking the alignment and position of valves prior to
starting flow, corrosion inspections, and the testing of high-level alarms on
tanks. Such practices are a part of the critical work for spill reduction, and
documented standards are needed to ensure expectations in performing
these tasks are clearly understood.
People will eventually make mistakes, and equipment will eventually
malfunction. When errors or malfunctions have the potential for cata-
strophic consequences, standards must include redundant safeguards block-
ing the pathway to a serious incident. The consequences of inadequate
performance standards can be devastating.
1
In its investigative report of an overfilled underground hydrocarbon
storage cavern, the National Transportation Safety Board concluded that in-
adequate performance standards were a contributing cause of the incident
that resulted in three deaths. In recommending that the facility’s operating
permit be revoked, a Texas State Board of Examiners concluded the cavern
inventory process was inaccurate, measurement procedures unreliable,
safety devices not fully operable, and employees insufficiently trained.
Facilities with inadequate standards of performance are in effect dependent
upon good luck for sustaining safe operations. When the consequences of
failure include the release of flammable or toxic materials, performance
standards dependent upon luck are clearly not sufficient.