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WHAT ABOUT THE WORKERS PROCESS SAFETY • THOSE ON THE SHOP FLOOR OFTEN HAVE THE BEST IDEA OF THE RISKS THEY DEAL WITH AND, CSB SAYS, SHOULD BE INCLUDED IN ANY CONVERSATION ABOUT SAFETY US FEDERAL REGULATIONS require worker participation in matters of process safety and industry standards similarly call for worker participation. Nevertheless, according to the Chemical Safety and Hazard Investigation Board (CSB), recent incident investigations have identified numerous cases where opportunities were missed to include workers in discussions around process safety. “A lack of effective worker participation can lead to an increase in the risk of injury to workers and, in the event of a serious safety incident, can impact the company and members of the public who live near these industrial facilities,” CSB says in a recent Safety Digest on the topic. CSB quotes the Center for Chemical Process Safety (CCPS) which, in its Guidelines for RiskBased Process Safety, says:
“Those workers directly involved in operating and maintaining the process are most exposed to the process. The workforce involvement element provides and equitable mechanism for workers to be directly involved in protecting their own welfare. Furthermore, these workers are potentially the most knowledgeable people with respect to the day-to-day details of operating the process and maintaining the equipment and facilities and may be the sole source for some types of knowledge gained through their unique experiences. Workforce involvement provides management a mechanism for tapping into this valuable expertise.” A ROLE NOT PLAYED CSB notes that, in several investigations, it has identified ineffective worker participation as
causal to the incident and has pointed out that workers and their representatives “play a critical role” in hazard identification, risk reduction and an overall increase in an organisation’s ability to prevent chemical incidents. It has also issued a number of recommendations to companies, individual facilities, labour unions, industry groups, state governments and federal agencies that aim to improve worker participation. These have included: • Creating or improving opportunities for workers to participate directly in matters relating to process safety management and major incident prevention • Empowering workers to provide input on how work is performed, through safety committees, special projects, inspections and audits, hazard analyses or other specific measures • Providing opportunities for workers to be trained and share information on the nature of the hazards present in the workplace, lessons learned from other sites, incident investigation outcomes, industry best practice and the like, and • Strengthening requirements for worker participation in industry standards and state and federal regulations. BACK TO THE BEGINNING CSB has been alert to the issue for more than 20 years, as evidenced by the first of four cases referred to in its Safety Digest. This was, indeed, CSB’s first investigation and report, and concerned an incident at the Sierra Chemical Company explosives manufacturing plant in Mustang, Nevada in January 1998. Two massive explosions occurred seconds apart, killing four workers and injuring six more. CSB’s investigation found that the absence of worker participation in process safety activities at the Sierra Chemical Company was a “major cause” of the incident: workers lacked sufficient understanding of the process hazards at the site and the controls that were in place. While there was a worker participation programme in place, it made no provision for employees to be involved in the development of safety policies. Further, workers did not use and were not aware of written operating procedures and safety information. They knew only that they were handling explosives and
HCB MONTHLY | DECEMBER 2019