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Human Factors Update |
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Contra Costa County, just east of San Francisco, is the home of several oil refineries and chemical plants. The County Board of Supervisors has passed a hazardous materials ordinance that essentially extends Process Safety Management to all parts of 7 larger industrial sites handling hazardous materials. What is unique in the local ordinance is the requirement for a written human factors program that follows a guidance document developed by the County Health Services Department. Guidance Development is Nearly Final That guidance document is in the final stages of development and has included participation by industry, labor, and others with technical expertise in process safety, risk management, and human factors. It draws heavily on previously published guidance documents from the Chemical Manufacturer's Association and the AIChE's Center for Chemical Process Safety. But the inclusion of the guidance documents now makes them statutory requirements. Some Areas will be New to Some Facilities The Human Factors Program will be addressing some areas that may be new to some facilities. These include the consideration of human systems as causal factors in the incident investigation process for major chemical accidents as well as near misses. Another area that many sites will have to formalize is the requirement to conduct a Management of Change prior to staffing changes for changes in permanent staffing levels/reorganization in operations or emergency response. Also, employees and their representatives must be consulted in the Management of Change. The written Human Factors Program must include (at least) issues such as staffing, shift work, and overtime. PHA's for Procedures OSHA has required Process Hazard Analysis (PHA) for facilities and modifications to facilities since 1992. The County guidance document mandates that facilities should consider conducting procedural PHA's for two distinct situations. First, there are certain processes or activities for which a procedural PHA can provide a more thorough and efficient review than a traditional PHA (e.g., unloading/loading, complex valve configurations). Second, there are certain activities or procedures within a process that the source can identify as having "high active failure likelihood and high hazard potential." For these activities, the stationary source should conduct a traditional PHA on the process, but may also elect to conduct procedural PHA's on specific procedures conducted within the process (e.g., sampling). Some New Requirements for Task Analysis Stationary sources must develop a process for procedure development that includes identifying the hazards associated with the tasks and incorporating input from personnel with expertise in the process. One method for developing comprehensive task descriptions and procedures is to conduct task analyses. Task analysis techniques may be applied during the design mode, audit mode, or retrospective mode. Task analysis can help to ensure that the most efficient method is identified and that discrepancies between individuals and shifts are eliminated. Task analysis results may be used as input to the content of operating procedures, training, and operating manuals. Task analysis results may also be used during incident investigations to explicitly identify differences in the prescribed way of performing a task and the actual way it was performed. Several acceptable task analysis techniques exist such as Hierarchical Task Analysis, Tabular Task Analysis, and Timeline Analysis Human Factors considered in Management of Organizational changes The CMA's Management of Safety and Health During Organizational Change is drawn upon heavily in the section that applies to managing organizational changes. It requires that each facility develop criteria or guidance to assist appropriate personnel in determining when an MOC for an organizational change should be initiated.
The CMA publication advocates the use of a team to scrutinize staffing changes and the County guidance advises that this will satisfy the requirement that employees and their representatives be consulted in the Management of Change of organizations. The team should include employees and their representatives, as appropriate, from engineering, maintenance, and operations as well as safety and health. Assessing the impact of the change on safety and health during off-hours or during emergency situations (e.g., spills, fires, explosions, excursions) is of primary importance during this phase of the MOC. For example, the change team may identify that the proposed organizational change will affect operations. In particular, the personnel change will affect the number of operators available to bring the process to a safe state in an emergency situation. The safety and health implications of such a change can then be examined. This is the First in a Series We expect the guidance to be issued shortly. The facilities will have one year to develop a human factors plan. We will continue to report on the status of the guidance and how the facilities are handling the written program development. Expect to see the guidance document posted on our site and available for downloading
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