The problem with desk-bound OSHA rule-makers
Oilfield safety culture has come a long way since the ground breaking recommendations of the 1990 Cullin Report that followed the Piper Alpha disaster. But safety today is bogged down in a top-down dictatorial mentality which is not keeping up with how increasing systems automation and complexity is affecting the needs of our workers.
1. Nanny State And Blame Culture
Social critic Herbert Spencer famously wrote over a century ago that "The ultimate result of shielding men from the effects of folly, is to fill the world with fools."
The nanny state's blame culture is a root cause of safety over-regulation. Countries need laws that make citizens responsible for their own actions. If while at work you have been to ladder safety school, and you used a certified ladder and you fell off, then you must share some of the blame.
2. Over-Regulation As A Cause Of Fatigue And Distraction
Some regulations require operators to follow so many mind-numbingly dull procedures that people eventually lose concentration and make a mistake anyway. Safety regulators need to find a certain happy medium between personal initiative and rigid adherence to procedures.
The need to continually find such a medium is worse than not understood, it is too often totally ignored. Rig roughnecks and roustabouts repeat the same procedure over again for 12 hours straight without mistake, partly because the type of work has enough mix of eye, hand, foot and body movement to keep their mind occupied.
But cheap sensors brought with them today's modern systems, which are hard wired back to a central control room, where systems operators no longer have a chance to patrol the plant; they must sit still in one spot, staring into computer screens for hours at a time. Physical movement has become a forbidden luxury. Lack of exercise and movement causes the body's lymph fluids to stagnate; little understood toxins back up into the liver and then into the mind.
Dull repetition causes the chair bound operator's attention to wander off. Fatigue and boredom sets in. Regulatory bodies and control room designers show few signs of awareness that they should be taking these second order human effects into account.
3. Narrow Minded Safety Rules Overlook Human Needs
A certified safety officer is a person with authority to influence how work is performed. To qualify, he must demonstrate an extensive knowledge of the safety-related rules, regulations and job assessment procedures required by the likes of OSHA in the U.S. or NEBOSH in the UK.
While some parts of the syllabus contain useful information about how to assess risk, too much of the safety curriculum concentrates on showing knowledge of the exact names and section numbers of various workplace safety rules and laws. Without expressly saying so, safety certificate exams reward those who demonstrate a narrow legalistic knowledge of the rules, a mentality which is sadly reflected in the outlook of too many safety officers on today's jobsites.
Safety officers who think like leaders personally engage participants in reviews of workplace rules and procedures. Leaders know that people want a sense of control of their work environment.
Workers don't want top-down edicts telling them how they MUST conduct their work, to be announced by a memo stuck on a notice board. Work procedures should be constantly questioned, reviewed and modified. Because nobody is more familiar with a procedure than the person who performs it every day, we should harness the knowledge of our workplace participants when we design the flow of work.
The following ten human workplace needs can serve as a work procedure checklist:
- empathy with the operation,
- a sense of self-efficacy with the procedure
- communication with team members
- optimism about the outcome of the job
- self-motivation to do better
- self-esteem that the job is worthwhile
- self-monitoring of the value of his contribution
- a sense of belonging to the team
- a sense of cohesiveness with the group
- self-awareness of the participant's status and position.
System operators who lack a sense of control over their work task environment easily get bored and lose interest in their duties (even mission critical ones).
4. Ergonomics and Too-Complicated Systems
In November 2010 an Airbus A380, Qantas flight 32, upon takeoff from Singapore Changi Airport, suffered a violent engine turbine disk disintegration that ruptured fuel tanks, hydraulic controls and data cableways. Instead of the normal flight deck crew of three, QF32 had 5 senior pilots on board that day and even so, it took this team of experienced aviators over an hour to decode the flood of alarms coming from busted systems, before they could reach a point that they had enough data to decide to attempt an emergency overweight landing. Systems complexity nearly got the better of one of commercial aviation's most experienced flight crews.
Here is a dilemma faced by those who draft safety rules which tend to reward dumb, docile obedience. At what point do safety rules no longer "shield men from folly"? Should there be a limit on the size of safety manuals? No more than 5kg, or maybe no thicker than 4.5 inches?
Twenty six years before that flood of unexpected concurrent events came close to overwhelming QH32's flight crew, Yale sociologist Charles Perrow had argued in his 1984 book, "Normal Accidents: Living with High-Risk Technologies" that high tech systems are now so complex that every possible failure cannot be anticipated. Perrow's Normal Accident Theory argues that occasional catastrophic failures are inevitable, saying that complexity tends to require complex systems be managed in such an authoritarian top-down way, that systems engineers tend to write too-rigid procedures.
When operators are busy managing an unforeseen event, rigid rules get in the way. In other words, NEBOSH and OSHA certification has produced a generation of safety rule-makers unable to address Perrow's observations. Too many OSHA-inspired safety rules do little more than crudely imply that when something goes wrong, somebody has to be blamed.
5. People Need Some Room To Think For Themselves
Big corporations like to send their employees to outward bound-type incentive weekends, where soft office workers are put into positions of perceived danger, where they must draw on their own physical resources to avoid hurting themselves; e.g. walking on a high rope obstacle course or paddling kayaks in choppy seas. People nearly always survive these adventures without injury because we know that humans inherently look after their own survival. Ordinary people perform seemingly hazardous tasks quite consistently, but only so long as they are fresh, attentive, NOT tired or distracted and focused on performing only one task at a time. A goal of such adventure training is to let participants gain confidence in themselves.
We still today train fairly soft oil and gas process operators in some pretty wild fire-fighting skills, based on the known fact that the best chance of defeating a petrochemical plant fire happens within five minutes and the only people available that fast are the operators. So they get to do fire-fighting school, where they enter totally dark confined spaces on fire, using a fire hose spray nozzle to push back a thousand degree flame front and sometimes even practice rescuing victims in smoke blackened darkness.
The training is dangerous. But by carefully controlling the external factors, inexperienced people can learn to perform extraordinary tasks in ways that ensures that nobody gets hurt.
In short, well-rested alert humans can manage risky situations, so long as a third event doesn't distract them. There are many dynamic work situations not covered by the rule book: derrickmen hooking up heavy choke and kills hoses to the marine riser of a floating drill rig in high seas; fishermen handling nets in rough weather; crane operators on floating drill rigs loading pipe from wildly heaving boats in high seas. All face dynamic situations where skill, experience and judgement call for actions on a second by second basis.
Safety rules need to recognize this and not distract the man from focusing on doing his job because his work is governed by fear of becoming the object of a flood of blame emails.
We need to design work so that people on the job feel they have the authority and confidence to quickly adjust work to handle sudden concurrent events in the same way as the QF32 crew managed major distractions while keeping their focus on the main task at hand.
It would also be helpful if the job description of safety officers made them available as a resource to assist when an unexpected concurrent incidents do suddenly occur. Sadly, what we too often observe during an unfolding incident is a safety officer not jumping in to lend a hand, but standing off to one side, with his digital camera ready to photograph any digression from the rule book.
The problem starts with the too narrow focus of desk-bound NEBOSH and OSHA rule-writers, who need to get out their chairs into the real world of work where they can start applying their rule making theories to situations such as helping the AD hook up a 600 kilogram, five-inch kill hose to the riser of a heaving drillship on a stormy night.
Source: Evan Jones, posted on OilPro http://oilpro.com
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