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Employee Participation and Culture

March 11, 2014
Thinker-1

Rodin’s Thinker

The topic of “Safety Culture” is one that has received much attention in recent years. Yet “culture” is very similar to “Employee Participation” — a topic that has been part of the OSHA Process Safety standard for a generation and that is now being incorporated into BSEE’s SEMS rule. Therefore it is useful to review what has been learned about Employee Participation. The following material is extracted from the book Process Risk and Reliability Management.

Employee participation lies at the heart of any process safety management program. It is probably for this reason that OSHA placed the topic of Employee Participation, also known as Workforce Involvement, as the first of its fourteen Process Safety Management elements.

All employees (including contract workers) must be involved in the program. Although PSM programs are often conceived of primarily in technical topics such as hazards analysis, risk quantification and fire and explosion modeling, the involvement of all employees at every level is fundamental to the success of such programs. When employees feel involved they are much more likely to make suggestions for improvement, participate in new initiatives and “walk the extra mile”. Moreover, the effective involvement of the workforce provides a sanity check for new ideas, projects and analyses. Anything new or unusual should be reviewed by the employees; they will immediately identify any common sense problems because they are the ones who know the facility best.

It is important to note that this element is called Employee Participation, not Employee Communication. The intent is that employees fully engage in the spirit of the process safety program. For example, a process hazards analysis (PHA) offers an opportunity for participation in two ways.

First, all employees should be encouraged to participate in the PHA meetings themselves. They should have a chance to contribute their knowledge, experience and ideas. Second, and maybe more important, carrying out PHAs creates state of mind for all employees; they will start to look at everything they do in terms of its risk impact. The insights generated will then suggest ideas for reducing that risk. In other words, the purpose of a PHA is not just to identify hazards, but also to encourage a particular way of thinking among all employees. So, an operator working by himself at one o’clock in the morning may be about to open a valve on a line that connects two tanks. If, before doing so, he spends a few moments going through some of the PHA guidewords such as “reverse flow” or “contamination” he may identify a possible accident situation, and decide not to open the valve until he has talked over the proposed action with his supervisor or colleagues. When the operator acts in this manner both the participation and the PHA elements of the process safety program are working perfectly. Employee participation is not a stand-alone activity; instead it should be woven into the fabric of all the elements of a risk management program.

Additional examples of workforce involvement occur when a pipefitter learns that a new chemical is about to be used in the process. He may question whether the current gaskets are safe in the new service. Or an outside contractor may feel that he or she has not been given sufficient instructions as to what to do and where to go in an emergency, and makes that concern known to the host company.

Although there are many benefits to do with participation, management has to recognize that, by asking employees to get involved in decision making they are also asking those employees to take more risk with regards to their career and reputation. It is much easier for an employee merely to follow orders — even if he or she knows that those orders are not sensible — than to take initiative. Moreover, increased employee participation may run into road blocks with unions and other organizations that represent those employees. Consequently, employees must feel that they are sufficiently rewarded for participating in management programs. One way of achieving this is to provide employees with long-term rewards if the company does well, for example by giving them stock rather than cash bonuses.

Developing Employee Participation

Management and the employees should develop a written plan showing how they plan to implement Workforce Involvement. An example of one of these is shown below.

  • The PSM program will involve all employees and contract workers, as appropriate to their job function and experience level.
  • The program will involve the full participation of “employee representatives” – where such duly elected representatives exist.
  • “Employees” includes not only full-time workers, but also temporary, part-time and contract workers.
  • Decisions as to which kinds or classes of employees should be consulted regarding specific PSM matters will take into account factors such as job functions, experience, and their degree of involvement with PSM and the company’s general background.

Safety Committees

Safety committees provide a formal channel through which management and the employees can communicate with regard to process safety issues and overall company culture. There are many references to the involvement of employee representatives in the OSHA standard. These would usually be on the safety committee. If the facility is non-union, it is essential that the employees’ representative is selected by the employees, not appointed by management. But it is important to ensure that the committee is not isolated; the effective implementation of this element requires that everyone participate in the process safety program.

Involvement in PSM Elements

Employees can participate in the PSM program by taking leadership of some of the elements of process safety. This type of involvement does not have to be universal; employees will be selected based on their understanding and knowledge of the topic in question. Nevertheless, it is a good idea to involve employees with lower levels of experience wherever possible in order to train them in the details of the process safety program.

Difficulties with Workforce Involvement

Although effective workforce involvement and employee participation bring many benefits, there are costs and drawbacks, as discussed below.

Inefficiencies

Increased participation of employees in the PSM program can lead to short term inefficiencies brought about by spreading work among a large number of people, rather than assigning it to a small number of full-time specialists. For example, rotating operators through a Hazard and Operability Study means that the analysis will be slowed down because the newcomers will have to get up to speed on what has already been covered by the previous team members.

Another example of this type of problem (and opportunity) occurs when the operators are each asked to check the P&IDs for a small section of the plant. It would be much quicker to have one designer go out and do the whole job — but doing so would lose the important benefits that would be gained when the operators check their own unit line by line and valve by valve. Furthermore, the operators may be able to identify problems with the P&IDs because they know how “things really are”. Ultimately, the short term inefficiencies consequent on using all the operators to perform such tasks will be more than compensated for by the gains in the overall knowledge and understanding of the operational integrity system.

Unwillingness to Accept Change

Implementation of workforce involvement can create anxiety — particularly among managers — because they are likely to hear facts about their organization that are critical of their efforts. Moreover many workers prefer to work in a “command and control” management system because they can thereby avoid the responsibility for mistakes that are made and because thinking is such hard work.

Labor / Management Relations

It has to be recognized that the ideal workforce involvement situation depends heavily on good labor/management relations. If there is a good deal of strife and disagreement between the two parties, then, realistically, progress in this area is likely to be difficult. For this reason, it is important to set realistic goals, and not to over-commit as to how much progress can be made in this area.

OSHA Standard

The OSHA standard and guidance to do with Employee Participation are shown below.

(1)  Employers shall develop a written plan of action regarding the implementation of the Employee Participation required by this paragraph.

(2)  Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.

(3)  Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.

Guidance

Employers are to consult with their employees and their representatives regarding the employers efforts in the development and implementation of the process safety management program elements and hazard assessments. [ Employers must ] train and educate their employees and to inform affected employees of the findings from incident investigations required by the process safety management program. Many employers, under their safety and health programs, have already established means and methods to keep employees and their representatives informed about relevant safety and health issues and employers may be able to adapt these practices and procedures to meet their obligations under this standard. Employers who have not implemented an occupational safety and health program may wish to form a safety and health committee of employees and management representatives to help the employer meet the obligations specified by this standard. These committees can become a significant ally in helping the employer to implement and maintain an effective process safety management program for all employees.

Written Plan of Action

OSHA requires that the Employee Participation program be written down. This can be difficult to do well because Employee Participation is involved in so many areas of process safety and because participation represents a state of mind rather than a specific program.

The plan of action should identify who is responsible for the management of the PSM program, how employees can learn about it, and how suggestions for improvement can be implemented.

Consultation

As already discussed, employees must be involved in all aspects of PSM, not merely informed about decisions that have been made by other people.  Their opinions matter, and should always be acted on. Even when an idea is rejected, management should always communicate with the employee as to why that decision was made.

On union plants, the employee representatives will be appointed by the union. On non-union plants, the employees may choose someone to represent their interests. The appointment must be made by the employees, not management.

Access to Information

In addition to consulting with employees, it is important that management makes sure that employees know that they have a right to access to information to do with process safety. The fact that Process Hazards Analyses (PHAs) are specifically identified within this element has prompted many companies to make sure that operators participate in the PHAs, often on a rotating basis.

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