Learning by Training

By Arend van Campen

THE LIMITS OF PGS 29

In the Netherlands, the so-called PGS 29 is used as a standard reference to prevent risk in tank storage terminals. It uses the ‘bow tie’ methodology, scenario description or goal-based requirements. I have been to presentations at StocExpo about this approach and wanted to write something about before Christmas and the hopeful beginnings of 2019.

When I wrote the book Safety Of Ethics some years ago, based on my Master’s thesis, I researched and found that despite the evergrowing number and volume of guidelines and regulations, they only cover ‘linear’ cause and effect relationships. Linear means the direct correlation between an error and its direct consequence. Such a mistake is also known as an error of commission.

PGS 29, in my view, is written along this well-trodden path and, therefore, I don’t see how it can prevent ‘non-linear’ accidents or risks. My ongoing research is about my observation and scientific findings that our industrial creations are just too complex to regulate from the outside with yet another set of recommendations or prohibitions. Nature shows and proves to us that our non-linear earth, planet, environment, as well as us, you and me, people, do not abide to linear regulation. No amount of rules, regulations or laws written down or imposed with force from the outside will be able to prevent non-linear risks or accidents.

So, what is this phenomenon we call non-linearity, you may ask? In short: two understandings and explanations. Linear systems usually are predictable and more or less controllable by instruction; non-linearity may be steered by information called feedback, but needs constant adjustment and adaptivity (learning); it does not allow instruction - we speak about a closed-loop approach.

A good example is to watch cigarette smoke: In a windless room, the first smoke seems to rise up in one line. But after a little while, the smoke starts to twirl, and becomes unpredictable: it shifts from linear to non-linear behaviour.

We base guides like the PGS 29 on reductionistic analysis but fail to accept the limitations of scientific determinism. Such approach only reaches the borders, or limitations, of linearity and cannot explain or control what can happen in the realm of non-linearity (environment, behaviour, society). More is needed to understand this ‘complexity’.

But there is a workable answer to this dilemma. We can use the exciting new science of steering and control named ‘Systems Theory’, which deals with complex systems such as our industries, social environment or politics. I believe - and actually know - that we have come to the limit of functionality of man’s created preventive tools such as the PGS 29 and need to move forward to understand complexity and related definitions like disturbance, perturbations, equilibrium and balance of living systems. Industries we have built are alive. To predict their longevity and sustainability in our nonlinear complex society, we must not make an error of omission: not doing what we should do.

Let’s do that during 2019! Happy New Year!

This is the latest in a series of articles by Arend van Campen, founder of TankTerminalTraining. More information on the company’s activities can be found at www.tankterminaltraining.com. Those interested in responding personally can contact him directly at arendvc@tankterminaltraining.com.