Driving Operational Discipline through Quality Written Procedures

1. Driving Operational Discipline through Quality Written Procedures Brian D. Rains Global Process Safety Management Leader DuPont Sustainable Solutions June 13, 2011

2. Today’s Objectives • To share my knowledge and perspectives about Operational Discipline and the essential role that high quality procedures play in strengthening that process • To recommend an 11-step approach to strengthen an organization’s Written Procedures • To share the DuPont passion for developing a safety culture that values adherence to high quality procedures

3. My Background • Chemical engineer by training and an experienced operations leader – 30 years of industry experience • Process Safety Management learnings from operating high-hazard processes and from extensive, global consulting experience • Am the Process Safety Management Practice Leader for DuPont Sustainable Solutions

4. DuPont Today • 208 years of owner-operator experience • Worldwide benchmark for safety • $32 billion revenue in 2010 • Diverse operations in 70 countries, 175 facilities, and with ~60,000 employees • 13 core business units including Sustainable Solutions • A common safety management system across all operations

5. How DuPont Manages Safety and Risk - Step 1 Management Leadership and Commitment - Responsibilities • Establish Policy • Commit Resources • Provide for and Encourage Employee Involvement • Establish Clear Accountability • Verify Compliance • Participate Personally 1. Management Leadership & Commitment

6. How DuPont Manages Safety and Risk - Step 2 2. Build a Safety Culture 1. Management Leadership & Commitment

7. How DuPont Manages Safety and Risk - Step 3 3. Implement PSM Program 2. Build a Safety Culture 1. Management Leadership & Commitment

8. DuPont Process Safety Management Model

9. 4. Operational Discipline How DuPont Manages Safety and Risk - Step 4 Operational Discipline Characteristics • Leadership by Example • Functioning Capability & Sufficient Resources • Employee Involvement • Active Lines of Communication • Strong Teamwork • Common Shared Values • Up to date Documentation • Practice Consistent with Procedures • Absence of Shortcuts • Excellent Housekeeping • Pride in the Organization 3. Implement PSM Program 2. Build a Safety Culture 1. Management Leadership & Commitment

11. The Case for Operational Discipline • Do you experience incidents when failure to have or follow good procedures is an important cause/contributor? • In 2001, DuPont initiated a Six Sigma project to assess causes for significant Process Safety Incidents in 2000 • OD was identified as a dominant factor in 53% of the incidents

12. 8 Step OD Implementation MethodologyStep 1: Be convinced improved OD is neededStep 2: Assess the current stateStep 3: Develop a comprehensive roll-out planStep 4: Focus on the “It,” High Quality ProceduresStep 5: Establish prioritiesStep 6: Strengthen discipline processesStep 7: ImplementStep 8: Audit, audit, audit

13. Most Important Procedures to Improve OD • Management Procedures or Managing Systems • Safety Procedures • Operating Procedures • Maintenance/Repair Procedures • Testing or Quality Procedures • Emergency Response Procedures • Principle of Operating Procedures • Operating procedure provides a clear understanding of and instructions on the detailed operating parameters and limits for safe operation. They also clearly explain the safety, health, and environmental consequences of operation outside process limits and describe the specific steps to be taken to avoid and correct deviations

14. Case for Adherence to High Quality Procedures* • “The April 2010 Deepwater Horizon incident is the most costly and damaging incident in recent history, and possibly the worst of all time” • “The decision making process on the rig was excessively compartmentalized, critical decisions [were made] without fully appreciating just how essential the decisions were… As a result, officials made a series of decisions… without full appreciation of the associated risks.” • “Some complained that the safety manual was ‘unstructured, hard to navigate, and not written with the end user in mind;’ and that there is ‘poor distinction between what is required and how this should be achieved’…Crews were potentially working with a mindset that they believe they were fully aware of all the hazards when it’s highly likely that they were not. “ • “Cement [was prepared] that had repeatedly failed…laboratory tests. Despite those test results, managers let crews continue with the cement job apparently without first ensuring good stability results.” • * Presidential Commission on the Deepwater Horizon Incident

15. U.S. Navy’s SUBSAFE System • Between 1915 and 1963, the U.S. Navy lost about one submarine every 3 years to noncombat causes • In 1963, when the nuclear-powered USS Thresher was lost, 112 naval personnel and 17 civilians perished • The Navy investigation ‘found deficient specifications, shipbuilding practices, and maintenance practices, along with inadequate documentation of construction and maintenance actions and deficient operational procedures • Admiral Rickover, then head of the nuclear Navy, told his staff to establish a system to ensure that such an accident would never recur • The new SUBSAFE system was established within 54 days and no SUBSAFE-certified submarine has since been lost

16. Principles of the U.S. Navy SUBSAFE System • Top management commitment to safety • Clear and written safety requirements • Education, not just training • Regular rewriting of requirements • Separation of powers and assignment of responsibilities • Emphasis on rigor, technical compliance, and work discipline • Documentation, capturing what is done and why it is done • Participatory audit approach, and requirements for objective quality evidence • Program based on written procedures, not personality- driven • Continual certification of a facility • Accountability and accompanying responsibility • Special efforts to be vigilant against complacency

17. Principles of the U.S. Navy SUBSAFE System • Top management commitment to safety • Clear and written safety requirements • Education, not just training • Regular rewriting of requirements • Separation of powers and assignment of responsibilities • Emphasis on rigor, technical compliance, and work discipline • Documentation, capturing what is done and why it is done • Participatory audit approach, and requirements for objective quality evidence • Program based on written procedures, not personality- driven • Continual certification of a facility • Accountability and accompanying responsibility • Special efforts to be vigilant against complacency As important as procedures, SUBSAFE establishes a mindset, a questioning attitude and what the officers call chronic uneasiness, summarized in the saying, ‘Trust, but verify’

18. Performance: Function of Managing Systems & Execution Safety Management Standards Operational Effectiveness Operational Discipline 70% x = 40% 28% State of Implementation and Adherence State of Standards and Procedures State of Operational Effectiveness

19. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom

20. OPERATING PROCEDURES AND SAFE WORK PRACTICES • PSM-OPSP-001 Plant Page 1 of 1 • PSM Manual Date Revised: 6/23/2010 Revision No: 2 • PSM Element Procedure for Operating Procedures and Safe Work Practices • 1. Purpose • 2. Scope • 3. Responsibilities • 3.1 Site PSM Operating Procedures & Safe Work Practices Leader • 3.2 Area Managers and Unit Operations Leaders • 3.3 Technical Personnel • 3.4 Qualified Operator • 4. Definitions • 5. Procedure • 5.1 Operating Procedure Requirements • 5.2 Safe Work Practice Requirements • 5.3 Control of Procedures and Practices • 5.4 Procedure for Procedures • 6. References

21. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner

22. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed

23. 11 Procedures Best Practices • Procedures are well written and easily followed. Visuals and other technology tools are employed

24. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers

25. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation

26. Overall Risk Classification

27. Consequence Guidelines

28. Lifesaving Rules The following standards are inviolable; if followed, they are known to help reduce employee exposure, serious injuries and/or death. Thorough job planning will help ensure that these standards are met. These standards apply equally to both employees and contractors. • CONDONING THE VIOLATION OF SITE STANDARDS • ENERGY CONTROL (formerly LOCK, TAG AND TRY) • CONFINED SPACE ENTRY • LINE BREAK (formerly FIRST BREAK) • HOT WORK • FALL PROTECTION • ELECTRICAL WORK PERMIT • INTERLOCK BYPASS • RELEASE OF HAZARDOUS MATERIALS TO THE ENVIRONMENT • RECKLESS ENDANGERMENT Willful violations of or serious disregard for any of these Inviolable Safety Standards will subject the involved individual(s) to immediate disciplinary action, which could result in termination.

29. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization

30. 11 Procedures Best Practices • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • Periodic Reauthorization of Operating Procedures • All sections and associated content of operating procedures and safe work practices shall be reviewed and reauthorized at intervals not to exceed three years. • Qualified operators shall be included in the review process to verify that sound and accurate practices are reflected in each operating procedure, and to solicit suggestions for modifications and improvements, including changes to procedures in order to minimize the potential for human error. • Operator participation in the review process shall be documented.

31. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • A verification strategy is applied to all procedures, consistent with #5

32. Confidential “Trust but Verify” – A Continuum Checklists without Auditing Training without Testing Concurrent Verification 100% Trust 100% Verify 100% Trust 0% Verify Peer Checking Training with Testing Independent or Supervisory Verification Checklists with Auditing

33. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • A verification strategy is applied to all procedures, consistent with #5 • Content is maintained up-to-date via robust MOC processes

34. 11 Procedures Best Practices • Content is maintained up-to-date via robust MOC processes Control of Procedures and Practices Requirements Sites shall develop and implement a procedures management program that addresses the preparation, control, accessibility, approval, authorization, and review of operating procedures. Changes to the documented technology or facilities must be authorized in conjunction with the MOC-T authorization document. Operating procedures shall be updated and approved prior to implementing any changes. Changes that involve subtle changes to facilities must be authorized in conjunction with the MOC-Facilities change authorization document.

35. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • A verification strategy is applied to all procedures, consistent with #5 • Content is maintained up-to-date via robust MOC processes • Initial and refresher training is provided at a frequency consistent with #5. Written, field and supervisory assessments are performed

36. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • A verification strategy is applied to all procedures, consistent with #5 • Content is maintained up-to-date via robust MOC processes • Initial and refresher training is provided at a frequency consistent with #5. Written, field and supervisory assessments are performed • Procedure revisions (documents) are controlled without impacting broad access to the procedures

37. 11 Procedures Best Practices • A procedures “Standard” describes what is expected and by whom • Every procedure has a single person owner • Procedures are well written and easily followed. Visuals and other technology tools are employed • Content is consistent with core documents and balances comprehensiveness with user needs. A consistent format is used universally with appropriate procedure headers • Every procedure is classified as to importance and risk mitigation • All procedures are routinely reviewed, consistent with #5 and by an appropriate cross section of the organization • A verification strategy is applied to all procedures, consistent with #5 • Content is maintained up-to-date via robust MOC processes • Initial and refresher training is provided at a frequency consistent with #5. Written, field and supervisory assessments are performed • Procedure revisions (documents) are controlled without impacting broad access to the procedures • Continuous improvement is driven by metrics and audits

38. 11 Procedures Best Practices • Continuous improvement is driven by metrics and audits • Metrics are designed to monitor/insure compliance • Number of Overdue operating procedure reviews • Reported corporately every quarter; Goal is Zero • Additional metrics are maintained locally • Number of near misses (e.g., an excursion above safe operating conditions • Number of significant non-conformances involving safe work practices • Audits insure quality of procedures and their execution • Are in addition to routine authorization reviews • Tiered, standards setting audits • Job Cycle Checks

39. 11 Procedures Best Practices • Procedures “Standard” • Single Person Owners • Well written, easily followed and visual • Consistent, comprehensive and user friendly Content • Importance and Risk Classified • Routine Reviews • Appropriate Verification • Change Management Process • Initial & Refresher Training plus Assessment • Revisions Controls while Accessible • Metrics and Audits

40. Summary • Operational Discipline is a deeply rooted commitment by everyone to carry out every task the right way every time. • The greater the operational risks, the greater the need for a strong Operational Discipline Culture. • Quality Written Procedures must be a cornerstone for any attempt to strengthen the Operational Discipline Culture of an organization • This 11-Step Approach is recommended. It will strengthen the quality of an organization’s Written Procedures

41. For more information:brian.d.rains@usa.dupont.com