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Safety Moment #59: In-Kind / Not In-Kind Change

Defining change in the context of Management of Change

Two recent Safety Moments have discussed the difficult, yet important, topic of defining “Change”. Change is a constant in all industrial facilities; so some means is needed for determining which of those changes need to be handled within the Management of Change system. The first two Safety Moments were:

In this Safety Moment — the third in the series — we review the distinction between “In-Kind” and “Not In-Kind” changes.

PowerPoint logo used for Safety Moment PresentationsIf you would are leading a discussion or meeting to do with the change in the context of Management of Change please note that we offer a PowerPoint presentation on the topic. This presentation can help you structure and organize the discussion.

Safety Moment #58: From “change” to “Change”

Safety Moment #58: From “change” to “Change”

Conditions on process and energy facilities are constantly changing. Criteria are needed for deciding when a proposed should be handled through the Management of Change system. This Safety Moment discusses potential criteria. It also reviews the issue of critical and non-critical changes. 

Details are available at:
https://iansutton.com/safety-moments/safety-moment-58-change-change

Safety Moment Presentations

Safety Moment Presentations

About six months ago we started publishing a weekly Safety Moment. As time permits, we will continue to do so.

The Safety Moments have been well received, so we decided to make PowerPoint versions of them. They provide a structure and framework for you to initiate and organize discussions with your colleagues. 

The following are features of these Presentations. 

  • They are supplied in .pptx format (you will need a current version of PowerPoint to open the files). This open structure allows you to edit what we have provided, and to add your own material. (This approach is in line with the Process Safety Management philosophy of having a program that is performance-based and non-prescriptive. There are no universally correct answers — each organization must develop its own system.)
  • Each slide includes notes that provide background information for the person making the presentation.
  • They are priced at $9.50.

The first two of these Safety Moment Presentations are: 

  1. Operating Procedures — Defining Terms
  2. Management of Change — Defining Change

To learn more please visit https://iansutton.com/#Safety-Moment-Presentations.

Thank you.

Safety Moment #56: Sinking Standards

Great Eastern / Titanic comparison

Great Eastern

This month is the 30 year anniversary of the Piper Alpha disaster. And, as to be expected, there have been many articles, blogs and web pages to do with that event, and the lessons that it continues to teach us. But there is an earlier maritime event which probably had a greater impact in its day than did Piper Alpha in ours. And that event was the sinking of the Titanic.

That event has given rise to many stories, movies and even some proverbs.

  • Rearranging the deck chairs on the Titanic.
  • Until the moment she actually sinks, the Titanic is unsinkable. (Julia Hughes).
  • Seize the moment. Remember all those women on the ‘Titanic’ who waved off the dessert cart. (Erma Bombeck).

One of the most important lessons to do with this famous event concerns the gradual erosion of safety standards that took place from the time of the building of the Great Eastern in 1858 to the sinking of the Titanic, 54 years later (which is why the picture at the head of the post is of the Great Eastern, not the Titanic).

For more discussion to do with the Great Eastern / Titanic comparison, and what it can teach us today, please visit Safety Moment #56: Sinking Standards.

Thank you.

Process Safety Assessments

Process Safety Assessments

We are working on a new series of ebooks. The series is called Process Safety Assessments.

All process safety programs require that formal audits be performed — typically every three years. These audits are a vital part of the program because, as they say, “There is always news about safety, and some of that news will be bad”. Audits are a crucial part of the process of identifying the bad news. However, formal audits do not always provide the insights that experts in a field can provide. That is where Assessments come in. They allow for subjectivity and opinions that would not normally be found in an audit.

To learn more, please visit our Process Safety Assessments page.

Safety Moment #55: A Few More Process Safety Basics

Process Safety Management Basics

The topic page Process Safety Management at the Sutton Technical Books site noted that the term ‘Process Safety Management’ can become somewhat diluted to the point where it can carry such a variety of meanings that it begins to lose any meaning. In response to this concern we suggested that we go back to basics, and that we should consider just those three words: Process, Safety and Management, and use them to frame the definition.

The post generated a considerable volume of thoughtful and useful responses, so we continue the theme of tightening down on the meaning of the phrase ‘Process Safety Management’ in Safety Moment #55: A Few More Process Safety Basics.

  1. PSM programs typically are constructed around a set of management elements. (OSHA has 14, CCPS has 20.) They are dialects of the same language. But of them all, unequivocally, the most important element is Employee Participation. And it’s not called ‘Communication’, and it’s not called ‘Culture’. It’s called Participation.If employees and contract workers at all levels (ranging from the short-term contractor or the temporary receptionist, up to the CEO) are engaged in the program, then its goals will be achieved. Hence, a ragged operating manual with coffee stains all over it is better than a pristine document that sits on a shelf.
  2. Next we have Management of Change. If a facility is properly designed and constructed, then all incidents occur because someone, somewhere made a change that took the system outside its safe limits (for which numbers are required). Some changes, such as corrosion under insulation, are covert — they are the trickiest to manage. 
  3. Finally, we have Hazards Analysis. If you don’t know what the hazards are then you can’t fix them. And hazards analysis is not just to do with people sitting in a room talking to one another. It’s a way of thinking (back to Employee Participation). So, if, before opening a valve, a technician “Takes Two” and thinks through the potential for “Reverse Flow” or “Wrong Materials” then the hazards analysis program is working well.

Safety Moment #54: The Process Safety Carousel

The Process Safety Carousel

This post is taken from the corresponding post at the Sutton Technical Books site


One of the challenges to do with process safety management (PSM) is circular reasoning or logic. Many of the PSM elements tend to become self-referential. Process hazards analyses can illustrate this conundrum with discussions on the following lines.

  1. Could high temperature in this vessel lead to a serious incident?
  2. What is high temperature?
  3. It’s that temperature that could cause a serious incident.

Similar difficulties can be seen when deciding on how to manage a proposed change to the facility. This time the question/answer sequence can go as follows.

  1. Does this proposed change require implementation of the Management of Change (MOC) program?
  2. We don’t know — we will have to run it through the MOC system to find out.

The use of risk-based analysis tools can create a related set of problems. For example, many facilities use the concept of ALARP (As Low As Reasonably Practical Risk), say when deciding on whether to use a new material of construction.

But the use of the word “reasonable” in the definition of ALARP requires its own definition, otherwise, once more, a circular discussion is created.

In situations such as these a fundamental problem is that the values being used are qualitative, and often quite subjective — a level of risk that is acceptable to one person may be totally unacceptable to another. There is no right or wrong in situations such as these — merely different opinions.

The only way of breaking the circular logic is to use to use numbers — to move toward quantification. So, for example, it may be decided that “high temperature” is 250C. This means that, if the temperature in the vessel reaches that value, then it action must be taken to reduce the temperature — otherwise there could be a release of flammable or toxic materials from it.

With regard to risk it is much difficult to assign numerical values due to the inherent subjectivity of the topic, as just discussed. Moreover, there is a public relationships aspect to think about. If a manager states that the target value for fatalities is say one in a thousand years, then that manager has said that fatalities, even at a very low level, are acceptable. This is something that he or she probably wishes to avoid doing.

There is no definitive answer to the difficulties just raised. Risk is fundamentally a subjective matter. All that can be said is that, wherever possible, quantitative limits and goals need to be defined.