Society is becoming more intolerant of negligent behaviour on the part of industries and corporations. Since the actions of maintenance professionals have a profound effect in this area, they carry a …
Society is becoming more intolerant of negligent behaviour on the part of industries and corporations. Since the actions of maintenance professionals have a profound effect in this area, they carry a great portion of the responsibilities for the safe operations of installations on a continual basis. Legal precedents are beginning to hold those in charge of maintenance responsible for failures in their maintenance regimes. This has put new light on the actions of maintenance managers, as well as the consequences of the actions.
Mostly as a response to the Westray Mine explosion in Nova Scotia in 1992, which killed 26 workers, Canada has introduced proposed changes that would add health and safety obligations to the Criminal Code. The proposal emphasizes that the provincial regulatory role (OHS acts and regulations) “will continue to serve as the first line of defense against death and injury in the workplace”.
In a letter to the United Steelworkers of America (USWA), Federal Justice Minister Martin Cauchon stated that the proposals placed “in the Criminal Code an explicit duty for all persons employing workers or directing their work to take reasonable measures to avoid foreseeable harm to the person or the public. Wanton or reckless disregard of this duty leading to the death or bodily harm would form the basis of a charge of criminal negligence.”
Ottawa proposes enshrining that duty in a new section 217.1 of the Criminal Code.
Close examination of this section suggests that employers, directors and supervisors, who are already under a legal duty (as spelled out by various provincial and federal OHS acts) to do “everything reasonable under the circumstances”, could be found guilty of criminal negligence if their failure to comply with the provincial OHS acts and regulations leads to a workplace death or serious bodily harm.
In Canada, this should lead to greater positive emphasis by employers on respecting the intent of regulatory laws such as the provincial OHS acts which focus on the measures identified as being able to prevent accidents such as training, hazard identification and control, and, of course, preventive and predictive maintenance.
There have also been dramatic changes in the regulatory environment of Australia, the United States and Great Britain. This trend is set to continue and it has profound consequences for those who administer maintenance in these companies.
Regardless of regulatory or legal pressures, there is an underlying responsibility as corporate citizens and human beings.
The maintenance responsibility for safety management is in two principal areas:
Doing the correct job
Doing the job correctly.
Doing the Correct Job:
Maintenance professionals have a responsibility to ensure that the assets under their control are managed in a manner that ensures continued safe operation. Unfortunately, in many cases, this function is not clarified. To understand exactly what “continued safe operation of the assets” means, it is necessary to understand:
The function of the assets
The consequences of failures of these functions
When these functions are fully understood, it is easier to determine what maintenance policies should be applied. There are a host of methodologies and approaches purporting to fulfil these requirements. Some have demonstrated limited effectiveness, while others tend to create absolute bureaucracies.
Reliability-centred maintenance (RCM) can be defined as “a process used to determine what must be done to ensure that any physical asset continues to do whatever its users want it to do in its present operating context”1. It is the opinion of the author that only a rigorous implementation of RCM is able to adequately determine the minimum safe levels of maintenance to ensure the continued safe operation of physical assets to the level required by their users.
In the course of such RCM analyses there is often an alarming amount of new information uncovered regarding the function of the assets. This leads to both greater awareness of the role of maintenance in the safe management of the assets and improved safe operation of assets.
Doing the Job Correctly:
This is the focus of this article and is intended to dispel some of the myths and current practices regarding the role of maintenance in the safe execution of tasks. The assumption in this section is that the correct job is now being done.
Many of the industrial accidents that occur happen due to poor task execution. Incidents may be attributed to a variety of reasons, but principal among these are the following:
Use of inadequate tools
Lack of knowledge regarding permitting or isolation (lockout/tagout) procedures, or the lack of their effective use
Lack of understanding of the correct procedure(s) for doing the work
Lack of adequate skills to carry out the job
Unfamiliarity with the equipment being worked on
Lack of understanding by those executing the work, of other tasks or events happening around them
The risks of incidents due to these reasons are multiplied by regular events in the maintenance environment such as a maintenance shutdown. Another factor that can greatly increase the risks of incidents is the use of inadequately-trained operators for the performance of maintenance work2.
Generic Checks
A popular method to reduce risks is to create/use a pre-work checklist. There are several problems with this approach. The principal problem is that the checklist may not be relevant, in its entirety, to every situation to which it is applied. Problems may develop.
Firstly, it becomes part of the judgement of the person doing the job to determine what on the checklist does and does not apply to the current situation. This can lead to incorrect assumptions.
Secondly, as the checklist is always the same, it can easily become part of a “lunchroom” task and either ignored or not taken seriously.
Thirdly, related to the first, as the checklist is generic, it may not take into account either the specific risks and hazards associated with the current task or the changes due to new and /or different ambient conditions.
Inductions
Another of the processes used to try and lower the incidence of risks is the inclusion of various safety procedures and site-specific regulations in the site induction. This is especially prevalent during shutdowns. While this is a positive step, few people take in all new information in an adequate manner.
While complying with specific regulatory requirements, site induction falls short of correcting the problem: the high level of inherent risk in the performance of a maintenance task. This needs to be the ultimate goal in this area and not merely regulatory compliance.
Planning and Scheduling
It is in the processes of planning and scheduling that the beginnings of risk mitigation can be found. This, along with an adequate means of managing such information (computerized maintenance management systems), can greatly lower the risks involved in maintenance task execution.
The process needs to begin with the pre-planning stage of the maintenance work. For those new to maintenance management, planning is ensuring that a task is ready for execution (what to do, how to do it). However, different interpretations can mean such things as:
Ensuring materials are ready for job execution
Ensuring that adequate safety information is included in the maintenance instruction (proper tools, hazards, etc.)
Ensuring that the procedure is up to date, approved and adequate for the task at hand
Ensuring resources have been planned and estimates included
Ensuring that specialized equipment has been taken into account
Pre-Planning
The pre-task planning stages of maintenance tasks are fundamental to risk mitigation. It is recommended that this be done using a Safe Work Procedure Template similar to the one in Fig.1 below.
The specific advantages of using a pre-planning format such as this safe working procedure is that it forces a detailed, time-critical review and understanding of th
e task(s) to be executed and of the hazards that each step presents. It provides current, up-to the-minute, time of task execution, task-specific hazard information, hazard mitigation information, permit information and pre-check information.
There is also the inclusion of tools and procedures for each sub-task involved in the execution of the work. While the first part of the document is directed at task-specific hazard identification, the procedure itself is directed at “bottling experience”. That is, ensuring that people have the information required to execute the work to an adequate standard. Care needs to be taken here not to try to teach mechanics basic procedures with which they are already familiar as this will not be well received.
The use of this type of format implies several things. Firstly, it implies that there is a need for a strong analysis of the risks and hazards involved with each task just prior to its planning and as close to the moment of execution as possible. Secondly, it implies that there is a need to plan, and by implication pre-plan, every maintenance task, including those carried out by third parties during shutdowns.
Much work needs to be done in the pre-planning stages, as well as in the management of such procedures, to ensure they are both current and correct. However, the benefits, in terms of mitigation of risk, safe execution practices and ultimate time-saving, are worth these efforts.
As a second part to the document in Fig.1 there is a need to not only detail what is required, but also to be able to monitor compliance and, more importantly, obtain feedback. One of the under-used functions of maintenance procedures is as a tool for continuous improvement. In fact, a well-managed maintenance procedure system can be one of the centres for managing continuous improvement. Each procedure becomes a live document in which those executing the work can contribute their comments as to the procedure tools required and any other part of the document. It can then become a repository for tips and general comments regarding how best to do work.
These two documents then need to be included in the computerized maintenance management system, either integrally or as attached documents, and controlled via strict document control procedures. At this time there is the opportunity to add other planning information such as equipment references, etc. Part of the control procedure should include a way to integrate the comments of those doing the work.
One of the focuses of Fig.2 also determines any changes in the conditions surrounding the task to be done. Even changes in the weather may have an impact.
With advance planning, many of the risks in the execution of work are mitigated. The amount of new information to be absorbed is reduced.
The next part that needs to be examined is maintenance scheduling (the who and the when).
This is the organization of all of the logistical factors required to execute the work. While the planning portion of execution focuses on how, why, where and with what, the scheduling function addresses the who and the when of execution.
It is standard practice in maintenance scheduling to look at who will do what, when — in other words, scheduling as a measure of time available. This is one of the basic tenets of capacity scheduling. However, there is also a need to look at the geophysical aspect of maintenance scheduling. That is to say, where the task will take place and what are the other activities and events taking place at the same time in the area. As always, this needs to be revised anytime a change is made to the maintenance schedule.
There are very few software packages that schedule with a geophysical aspect in the marketplace at the present time. However, software is client-focussed and, as more and more clients begin to demand this type of functionality, it will begin to appear. At the present time, it falls to maintenance planners/schedulers to do this as a judgement call, possibly in conjunction with maintenance supervisors. Armed with the awareness that this is required, risk will be reduced.
Conclusion
As can be seen, there are alternatives to industry-accepted practices at controlling maintenance-related risks. These are not only effective but at times, more effective than procedures currently in place. It can be seen from the changing industrial environments that this focus is not only important, but should be accepted as standard practice among maintenance professionals.
Do not be influenced by standard thinking on this subject. The approach that will achieve the lowest level of risk is that which is specific to the equipment/tasks and that which is the most practical.
The Author:
Daryl Mather is a management consultant, conference speaker and author in the areas of maintenance and reliability. He currently works for a management-consulting firm in Great Britain. Contact him at: darylm@klaron.net
The article was adapted for PPC by John E. Little, risk management consultant specializing in optimizing safety management systems. Contact him at: jelittle@oricom.ca
1 John Moubray, Aladon
2 Professional Safety magazine, March 2003, Assessing a fatal HAZRIN#text2#
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