As COVID-19 continues to spread across the world so do the impacts on personnel as well as operational safety. There are a number of resources available containing steps that companies as well as individuals can take to help prevent infection and slow down transmission, such as: washing hands, social distancing, staying home if sick, and so on.
However, what could or should organizations do to maintain safe operations of their facility or plant if there is a loss of safety-critical personnel resulting from self-isolation or policy changes such as travel bans, meeting cancellations, and remote work. What if safety-critical tasks could not be completed? What if critical maintenance was delayed? What if active process changes (MOCs) could not be completed in a timely manner?
Preliminary Risk / Readiness Assessment
To help work through these risks the following questions and steps will help prepare your organization for a possible disruption of safety-critical functions. These have come from my work helping organizations during reorganizations and transitioning safety-critical roles over the last decade. They are not in any order or comprehensive and are provided as a springboard for further analysis:
What would constitute a breakdown in managed safety that would require shutting down a facility, plant or process? How measures would help you know this in advance?
Who is responsible for each element of process, pipeline, or occupational safety program? Do emergency plans exist to cover each area of accountability?
What positions / roles if not available would significantly impact safety effectiveness? Do you have backup personnel assigned for these roles? Are they trained to take on safety-critical roles if required?
What systems / processes if not available would negatively impact safety performance (lockout / tagout, hot work, confined space entry, critical defeats, MOC, emergency shutdown, emergency response, control room processes, etc.)
What safety-critical maintenance could be delayed if necessary, how would you decide which ones?
Which open management of change (MOCs) if not completed could threaten safe operations?
What leading indicators would let you know that you might not be able to operate safety?
If approvals of safety-critical MOCs were delayed what process could be used to escalate or override approvals?
How would disruption or change in contractor availability impact safe operations?
How should risks be communicated and escalated preceding, during, and after a crisis situation (e.g. breakdown in safety)?
What scheduled safety-training if not completed would disrupt production and negatively impact safe operations?
What can be done now to mitigate disruptions to the safety program?
What regulatory obligations might be impacted if key personal were not available? Steam Chief, Incident Commander, emergency response personnel, health and safety personnel, environmental resources, line supervision, maintenance, technical and engineering support, etc.
What training could be conducted now to provide backup of safety-critical positions?
How will the level of risk be measured and monitored during a crisis?
What risk assessments could be conducted to ensure that changes to policies do not negatively impact the safety of people and operation (e.g. travel bans, social distancing, staffing levels, operating budgets, remote meetings, training, use of contractors, etc.)
What resources / materials if not available would negatively impact safety performance (contractors, spare parts, maintenance crews, technical staff, trainers, SME, engineers, safety personnel, etc)
What measures could be strengthened or added to better monitor and respond to operational risk (disruption in production, failure to operate safely, failure to meet regulatory obligations, etc.)?
What additional precautions can be taken to ensure contractor safety?
Are appropriate staff trained in executing an emergency shutdown of the facility, plant, or process if and when required?
Steps to take when transitioning accountability and authorities of safety-critical roles
Should any safety-critical positions or roles require transitioning the following check-list will help to mitigate risk exposure resulting from the change in personnel:
Reassignment of existing tasks
Reassignment of compliance program assignments
Contacting chairs of committees, working groups, or project teams
Documenting critical knowledge
Training new person assigned to previous position
Coverage of previous accountability and authorities until another person fills the position
Update of training, procedures, emergency call lists, or work instructions
Notification of regulatory authorities of change to personnel
Update of any systems, databases, security privileges, etc.
Other steps
Additional risks during the transition or after the change has been implemented
Transitions can themselves create additional threats to safe operations that will need to be addressed. These include:
Critical work may not get done in a timely manner
Critical skills or certifications may be lost or reduced
Increase in workload may occur due to covering previous duties and responsibilities
Preparation of regulatory reports might be impacted
Potential impacts to the health and safety of people, process, or the environment because of personnel changes
And others
Organizational Management of Change (OMOC)
Companies that have implemented an Organizational Management of Change (OMOC) as required by OSHA, CER, CSA Z662, API RP 1173, along with other safety regulations and standards, will be better prepared to address risks associated with changes to their workforce. An effective OMOC program will include:
Identification of positions and roles in the organization that are safety-critical
Establishing a process to trigger an OMOC when these positions or roles require change
Developing of a risk screening tool to assess the level of risk associated with changing these positions or roles, along with changes to policies and procedures
Developing transition plans to maintain continuity for safety critical roles and positions when these are changed according to the level of risk
Establishing a process to monitor changes during each transition and communicate any changes to risk to management
Ensuring that all safety-critical positions and roles are fully implemented (transitioned) by following up after the position or role has been changed (this includes reinstatement of roles if the change was temporary)
Next Steps
The COVID-19 pandemic will place additional strain on a company's safety management system. Those without a safety management system may find that they will need more work to prepare themselves for what may happen.
In either case, conducting a risk / readiness assessment will help organizations improve their ability to maintain safe operations. In addition, companies that have not implemented an OMOC process will benefit from doing so to help reduce risk exposure due to personnel changes.
Be safe, Act safe.
Should you need any assistance during the COVID-19 pandemic we can help to formulate and conduct risk assessments, identify safety-critical positions and roles, implement an interim organizational change process, or support you in transitioning safety-critical roles as needed. Please contact us to find out more on how we can help you keep your personnel and operations safe.
