Bay of Biscay, Bery Very RISK aay!

My Merchant Navy friends always fear “Bay of Biscay” as one of the very high risk area in their sea faring experience!!! call it Bay of Biscay-Bery Bery Riskaay! (Accent!!) 

This slideshow requires JavaScript.

I did not want to get in to TECHNICAL Safety topic in my BLOG! I wanted to keep this to generic ESH aspects as well as people focus. But can’t help! 

Over the past 5 years, in my ESH consultancy, in the 10s of sites I have visited for Assessments, Training, consultations, I repeat not one person, yes not one person at those facilities, (Including 90% of EHS professionals) have managed to answer my following Question? 
1) “What is Hazard? What is Risk” What is the Difference” !!!!And 90% are OHSAS 18001 certified facilities on paper, to add insult to Injury!!!  

This slideshow requires JavaScript.

2) I am also puzzled  to see Inconsistencies in Severity ratings!! For example falls and Electric Shock would always lead to a Fatal Situations as maximum potential scenario in severity!! People rate them as fatal in severity and while other situations they rate such harm as a First Aid Injury.  

1467059070089

3) Risk Rankings never done to identify top 10 issues or potentials and establishing Site Risk Portfolios and acting on them.

Risk Likelihood Table

3) Heirarchy of controls to mitigate risk not applied. Always folks resort to Procedure or PPE! Engineering options not even considered as a possibility. 

HierarchyTriangle4) There is no tie up /connect of Risk assessment to established Operational control Procedure! 95% of folks have no clue to the linkage that procedures are output to Risk Assessment. Procedures as one of the tool in Heirarchy of controls! The procedure reference is also never mentioned in Risk Registers as to how the risk was mitigated.

5) Risk Register is a live document, it is updated as and when changes happen to activity or change in legislations. At a minimum a review is done annually to bring the register up to speed and through calibration once in Three years to make it current.  (Courtesy Riskscorecard.net) maxresdefault

6) Many sites still sticking to 2 by 2 Matrix!! (Probability, Severity) this clogs the risk spectrum! The best practice these days are Probability*Severity* Frequency*% people exposed*Level of legal compliance. ( all rated from 1 to 5) so that max risk is 5*5*5*5*5=3125 thus you can focus on your risk mitigation efforts. 

13bc2be06b6edca3fe29b5fe3148ac47

7) Whenever I ask folks how many of Shopfloor employees / workmen participated in working the risk assessment, the answer is practically next to Zero. Risk assessment are mainly done to keep people in the action safe!! We dont seek their inputs???? 

cala-group.jpg

8) Risk assessment not tied to establishing Objectives, Targets, Management plans more so with focus now on ISO 9001, 14001 and upcoming 45001 all focused on risk based approach to Business. 

This slideshow requires JavaScript.

Hope folks can learn and take risk assessment to next level!! I recollect Doing Risk portfolio in 1992 for my facility, good Seven years before OHSAS 18001 even introduced! That helped us to have peace and focus on key issues knowing the expect the unexpected is just 1% probability.

Good Luck and God Bless!
Karthik.

20/4/17 1610 Hrs.

 

 

ARK——>Acts Of Random Kindness!!!!!

What can be the Acts of  Random Kindness (ARK) that Safety (ESH) Professionals can do at workplace!!! I would try to list!! please feel free to add!! While Random can be seen as an unplanned act, I would work here in a planned context.

  1. Be visible, show empathy, reach out to employees.
  2. Involve Employees at decision-making. Lower the level, the better. Make things happen where action is. 
  3. Spend time at shop floor, understand issues from their perspective. Listen. Always see what is in for them, why they should do it?? What will be the benefits to them?
  4. Speak AT them not Speak to them.  Hear what is not being said. Read Body language.
  5. Listen to Employees,Ask “What is your Opinion”? “I don’t know, what do you think?”
  6. Get to know people, try to know more about “the PERSON” (without being intrusive)
  7. Establish Trust. A key ingredient to relationship building. 
  8. Encourage employees to report situations when reported, work out resolution one way or the other.
  9. Seek inputs from them on Policy, Program, Procedures, PPE etc. Give feedback post decision on their inputs one way or the other.
  10. Get to know people better, their dear/near. Julius Cesar knew every soldier by name.
  11. Incident investigations are never done to blame employees!! Such Investigations are stupid! Only a terrorists do acts intentionally to kill themselves and others. Every Incident is fault of management at a base level. 
  12. If you can say good things about them spread / propagate the word. If nothing to be said, keep quiet. Never bad mouth people! If to be criticized, point to the behaviour and give feedback to the individual.
  13. Catch people doing right things, nothing works like a praise! There are many people who would like to be praised than getting truck load of money! Different people, different needs!! Find out what people want!! 
  14. Look out / Scout for female employee issues, Especially Sexual Harassment nature. Be the person to escalate,  even if, every one at work, keeps mum and mind their own business.
  15. Make sure people are well fed,the army moves on its stomach, many times (especially end of month times) folks may not have money, so may choose to go hungry /  starve. Look out! 
  16. Work people development as part of your goal, Inspire, Motivate, Engage. Make people feel good. 
  17. Communicate Communicate Communicate—-> NO News is bad news. Have courage to inform folks of information they wont agree with. Never hide.
  18. Dont be a Safety policemen to find faults, people don’t come to work to commit mistakes. So Go easy.

Safety (ESH) is all about to the people, by the people, for the people, so go about just doing it with Technical excellence as hardware and people skills as software.

 

This slideshow requires JavaScript.


GOOD LUCK! GOD BLESS
Karthik.

17/4/17 1500 Hrs. 

 

If I should Stumble, Catch my Fall !!!!

This is not about Billy Idol 1984 number!!

This slideshow requires JavaScript.

15th April!!

  1. Titanic the unsinkable ship sank on the morning of 15th April 1912.
  2. Hillsborough Football Stadium disaster 1989 which Killed 96 Children, Men, Women who were Liverpool fans. 15th April 1989.

Accidents, Industrial deaths are not new; they were happening before, happening as I type now and would happen in future. Where great institutions excel is they learn from such incidents and make sure such incidents never ever occur again. 28 years on Football stadium safety moved leaps and bounds and Passenger ship sinking not heard in my life time so far. They put in great systems, infrastructure, skill based training, Emergency response to Catch the fall, again. (Or perhaps never fall) 

So what were Root Cause in a broader sense that lead to these events:-

  1. Complacency:- Both cases absence of previous incidents made leadership to believe situations are all safe. I am think of organisations which have foolishly assumed that No Incidents means all good and great, only to see a major incident wipe business clean. What also happens is in their complacency mode an arrogance creeps in, which isolates /insulates such organisations and the fall is high and mighty.
  2. Error in Judgement:– Authorities didn’t read the situation developing (Crowd Swelling at gate, High speed Ship) that can cause lead to a potential incident situation due to lack of judgement or lack of information, data. This is where a good pre planning (Pre Mortem as Dan PINK calls it would help) to foresee things that could go wrong and put corrective actions. Previous crowd incidents in 1980s UK football matches were never taken note to correct situations. 
  3. Inadequate Infrastructure:– The lack of adequate life boats at the super ship, Locked stands which prevented fans from moving around thus leading to virtual stampede. I can quote numerous instances where lack of emergency exits, Exit locked from outside or lack of support system makes organisations sitting duck should things go wrong. Effective safety always comes with world-class Engineering and infrastructure. Nothing more, Nothing less. Everything else is secondary. Great organisations which value human lives, work an infrastructure focus to prevent Loss of lives and property damage in an adverse situation.
  4. Lack of Emergency response:- In Hillsborough, precious time was lost in even declaring and communicating emergency. When done and support systems arrived only 14 of the 96 died in the hospital or were on the way when they breathed their last. 

I am not listing everything that went wrong! My thoughts are how organisations can learn lessons from such incidents and work a plan to ensure incidents that affect people do not happen in their work place. As I keep saying, No one but terrorist comes to work with an intention to get kill or lose a limb! Still we blame people for things that go wrong??

What can companies do?

  1. Leadership walk the talk, committment to change things, Visible felt leadership.
  2. Risk Assessment for Planning with Normal, Abnormal, Emergency situation, Use guidelines like ISO 31000. Establish action plans for risk mitigation with timely tracking.
  3. Link risks to objectives, Targets and measure. What gets measured gets done. Review.
  4. Establish sound Emergency procedures, practice practice, practice… 
  5. Train Train Train, Communicate Communicate Communicate.
  6. Work Corrective actions when things dont appear right? Encourage people to come forward and report situations.

Good luck!! As a Liverpool fan in my teens the incident touched me personally!!! (Now EPL what’s that!!)
Take care, god bless

Karthik.

15/4/17. 1800 Hrs. 

Trading Places !!! ESH Folks, Can you??

This is not about Eddie Murphy Blockbuster movie!! MV5BYTEzMjBiMzktMjQyMS00YzBhLTgzNWQtNzA0NmEwMTNmMDQ2XkEyXkFqcGdeQXVyNDk3NzU2MTQ@._V1_UY1200_CR90,0,630,1200_AL_

Phil La Duke has written an awesome post (as usual)  two days back, I can’t wonder as to how much Phil and my thoughts align to ESH implementation. His post is about Compromise is a big part of Safety.

Seeing it from local situation, I always wonder? Do ESH folks are there just to say NO /My way or the Highway? Not establishing relationship, influence over peers at work. Unfortunately, my assessment of EHS folks is a sad yes. Of course, such folks are very few in a larger context of Indian scenario of about 3500 Professionals, ( MY guesstimate) but like one bad apple in a basket which can make others rot, bad traits can spread fast. 

So what can ESH folks do to not to get in to complacency Mode:-

  1. Human being get in to error mode, be aware of it, Work mitigation considering error is bound to happen. Put in sensible policy (Never to be violated) Guidelines, Rules (Flexible to change). Never put your ego before cause. You are not know all.(Courtesy Hearts & Minds)slide_18
  2. Dont push it hard to make them accept. As Phil says, If you push, they will find a way to beat around and would carry out task when you are not around! Remember, hidden risk more dangerous than unknown Risk.
  3. Visible, Visible, Visible and Communicate, Communicate, More communicate. As saying goes, even if you are there on shop floor 4 hrs/day people wd perceive never seen you before. (Like how we find a new model of car on road after good 6 months and then find 3 in 4 hours or you communicate a message 6 times, people would say they heard once)!!! Communication is what listener perceives. All paperwork, desk work, reports can wait. Keeping people safe is Task#1. 

    This slideshow requires JavaScript.

  4. As Phil says, “Show Must Go ON” I keep saying in my site visits in a more blunt term any Donkey can stop work, it doesn’t require common sense! Good safety professional work a plan to keep business going. Find a way to make sure show keeps going of course, keeping people, property safe is a must. Work Risk assessment, Ask folks, what is the right /safe way to go about it? (They know 90% time, but won’t tell you, Why should they?). As I keep saying” I don’t know What do you Think, or What is your Opinion” Some way ahead would sure be found. Obiviously, for that Safety folks need to keep the saw sharpened on Technical excellence. leader-as-a-communicator-16-728

Safety profession is all about Trading Places and seeing everything from other’s perspectives as a Worker, As a Plant Manager, As a CXO, as a colleague and help them make see what they can’t visualise !! It is not easy, but then who ever said Safety profession is easy??? 

Good Luck and God bless.

Regards

Karthik

13/4/17 1900 hrs.

PS: 1) I reproduce Phil’s Blog for those who dont have web access.

 

Compromise Is A Big Part of Safety

by Phil La Duke

Two weeks ago I spoke to a fine group of safety professionals at an ASSE PDC on the dangers of complacency and in two days I will speak at the Michigan Safety Conference about shifting the focus away from body counts in favor of the things that cause safety. In preparing for both of these topics something that had always bothered me became clear: Safety is a series of trade-offs and compromises.  I can already hear my detractors, “That’s La Duke endangering the workplace with more his safety  heresy.”

But think about it, “safe” is a relative term. Is it safe shooting a movie at the Packard Plant?  No when compared to shooting in a sound studio, yes compared to Detroit Animal Control capturing a scared and agitated tiger in the abandoned and unsafe labyrinth of tunnels below the plant (it had escaped during a German video shoot).

This weekend I saw a “health tip” on avoiding the flue: “get the flu vaccine, wash your hands often, and don’t touch handrails.” Now I know of at least four workplaces where an employee can get written up for NOT touching the handrails while traversing steps.  When I worked and Trinity Health (by people who really KNOW about the subject) we were a) required to get a flu shot, b) had ample dispensers of hand sanitizer conveniently located and c) were told not to touch the handrails, rather to hold our hands slightly above the rail so that should we begin to slip and fall we would be able to catch ourselves.  For the record this is how handrails are intended to be used.  The idea is less about eliminating the risk of falling, and more about the mitigation of the risk of injury; to reduce the consequences of slipping on the steps.

Tradeoffs are part of our job we want people to be alert and vigilant and to focus on the tasks at hand, and yet we know that remaining hyper-focused tends to lead to attention fatigue, where are minds can no longer focus at such a high level and errors become exponentially more common. So by pushing awareness and focus we at some point actually create hazards.

Complacency is another area where we have to pick our battles. On one hand we want workers to be confident and competent in the tasks they do, but on the other hand we don’t want them to get TOO confident either; it’s an on-going battle.

Just Say No Doesn’t Work

Too many safety professionals see themselves as guardians of all their flock. These safety professionals tend to discount the life experience and decision making abilities of their people and think they know better in all cases. And when safety professionals develop this attitude they get in the business of saying “no, that’s too dangerous”. I have occasion to be the Production Safety Consultant on a big budget action film. Action films, despite the extreme precautions to reduce the risk of undesirable outcomes (it’s not just injuries, but destruction of property, damage to equipment, etc.) action films remain a fairly high risk endeavor (as compared to shooting at an outdoor Paris café) but safety people need to recognize that the old adage, “the show must go on doesn’t just apply to Hollywood or Broadway but to oil fields, and auto manufacturing, or logistics, or bio tech, or well… you get the picture (no pun intended).  Everywhere the work has to get done, ideally safely, but if you tell them “no” they will just wait until you aren’t around to do it.  And hidden risk is deadly risk. Our jobs in safety has to be about helping people make informed decisions about the risks they take, not making global rules and procedures because one person made a bad decision. We have to be better than that, but being better than that is a lot more work.  Safety is not a profession for the lazy, and point of fact I haven’t met that many lazy safety practitioners (the problem is the ones who are stick out in my memory).  I’ve met plenty of crusaders who have an exaggerated sense of their own importance to the organization, and I’ve seen my fair share of bellyachers (you have to remember that through my writing, blogging, speaking, and consulting I meet a LOT of safety professionals that traverse geographies, cultures, industries) but mostly I’ve met good safety who are earnestly trying to do the best job they can. Most are respectful, thoughtful, and intelligent, and most would agree that safety, and the steps we are forced to take are often compromises that keep us up at night.

A-ha?? Take on me, Hunting High& low!

This post is not about the Guys from Norway who took the music world by storm and set world on fire in English Pop music industry during 1980s!

This question came in Whatsapp Group! “What are Industries’ ESH Needs Tomorrow and how professionals can be different from one another to make a difference? -” by a gentleman! What makes ESH and Companies  get that “A-Ha moment” to Take them on and go hunt High and low to be a winner!! 

I thought of sharing my views, so this post!! I assume tomorrow indicates a 2-5 year window!

  1. Leadership Engagement:- With the new Standard of ISO 9001, 14001 out and new 45001 expected to come later this year, the Industry needs to align its leadership participation to the needs. No Longer “MR” the Scapegoat, Smooth operator or can be the fall guy. The new standards place a lot of emphasis on Leadership participation to align to policy, set vision, set objectives, targets review as well as lead the company beyond now to engage in new frontiers of business expansion. h-and-m-image
  2. Strategic Planning:- One of the key differentiator of excellence is to predict the future as well as foresee it. The enabler for executing this is through a good strategic planning covering 3-5 year window. Analyse SWOT PEST model and identify issues. Work the resources required. Even if a hit rate of 0.5 is achieved, you are ahead of the curve. EHS professionals need to go beyond Tech aspects to master Fin, HR, Ops aspects and that’s where basic management knowledge would go a long way. Integrate this as a way of doing business with linkage to Facility/Business/Operations/ Country/Region Risk Portfolio. 
    Word Cloud Strategic Planning
    Strategy is key

    strategic-planning-swot-map
    SWOT with 5 forces
  3. Legal and other requirements:- The legal requirements which are the law of the land is not expected to change much given the low priority government always gives to such sectors. At the same time, the stakeholder outreach, joint venture participation, foreign investments in the Industry would set out expectations to implement some standards, codes, fundamental requirements etc which the interested parties may insist be complied as condition of business. Companies who want to surge ahead and ESH professionals who want to be different need to know these and work a plan to implement them so that due diligence occurs with less acrimony or suspicion. Also remember ESH is a dynamic target to shoot when you are on the move on tread mill, so watch out on the horizon for requirements that can impact your business besides ever-expanding scope of EHS. ( Business Continuity, Product Stewardship, Ergonomics, SARS, Furlough, Work Place Violence, Vulnerability assessment, Dept of Homeland Security, were unknown terms good 20 years back!!) Compliance-Requirements_Cover_Yourstory
  4. Embrace Technology:- The internet of things is here, work to spruce up your enablers. Excel is long dead and buried, Apps are new norms, Data is divine to slice, dice and form an opinion with justification. Views of new generations born after 1990, matter to maintain sanity in workplace, so seek them through tech devices. Work audio-visual aids as evidence and to strengthen your training and communication programs. Knowledge sharing thro portals is minimum expected like wearing shit/trouser. collaboration for inputs in developing programs, procedures, process, protocols is minimum expectations through Cloud based infrastructure. Of course, nothing can be achieved without fine tuning self in terms of relationship, engagement, emotional awareness. Work appropriate methods to calibrate them in a frequent manner. (Courtesy Beecham Research) bor01
  5. Finally as an individual what would you do to keep yourself different, spotted in the crowd? Ultimately, that’s what matters!
    1. Growth and Customer focus is key to everything you do. Be it home, work, environment. You are out to sell yourself. Work Personal Brand, know yourself your strength, weakness! Convert weakness as a strength to work.
    2.  Get Results:- You are measured by what you delivered. Salary,  # kids, Fulfilling committment, Tasks completed, % Incentives, all linked to results. Moral victory of nearly achieving  and just missed counts to nothing!! No one remembers who was #3 or #4 in any event. It is always top 2 at most. So work to get results through planning, execution and go beyond! download (2)
    3. Make people better:- You being professional has a duty to fulfill and your actions would have an impact one way or the other in people whom you influence. Work the best out of them, make them better in areas you can help them learn and grow through interactions, communications etc. As saying goes, “People join the organisation, but leave the manager”!!!! images

Hope this helps folks to prepare themselves and their organisation for the tomorrow.
Good Luck and God bless.

Karthik.

8/4/17

0945am

In the Land of Snake Charmers, Snake oil salesmen rule?????

One of the biggest fad I am seeing and asked to participate is implementing the Behaviour Based Safety (BBS) Sham!! I can’t quote of 10s of instances over the last 5 years, where I was called to implement BBS as a consultant “I read the Miranda warning first too”. 3597538_orig Few weeks down the line everything goes quiet and program falls through the rails or we find clients totally not ready. Why??

As I keep saying in my training sessions to make it clear to FOLKS, Implementing BBS is not a consumable like eating Noodles. You boil water, pour noodles and taste maker and after 3 minutes your hunger is gone and purpose of quenching hunger is served. Rather, BBS is all about shedding your extra weight from your body through discipline, exercise and routine regime that requires plan, doing, checking, acting up on review. Unfortunately, in an Indian context many companies fall victim to what we term as “SNAKE OIL Salesman” who hypnotize top leadership, (even 8/10 ESH professionals are guilty by association who havent understood the concept) that behaviour control would solve all the safety problems at facilities and pull wool over their eyes. And top management in their greed to save investments in other  capital expenses or other form, fall victim. Also BBS is not copy/paste……. 

So what is the right way to work the BBS if at all organisations are serious about injury reduction intent !! 

  1. Establish baseline —> First check where you are in EHS journey implementation. The following curve would be a good example. As clearly indicated in the curve, Behaviour change is the last mile connectivity to quote current language. Unless the other elements are mostly in place,  which are determined by analysis of baseline planning, working at people behaviour change etc working without addressing this is an insane way would only deliver insane results. BBS is a journey.Untitled.png
  2.  Pitfalls to effective BBS implementation:- Even after setting up a sound infrastructure, Management systems, Indicators, 0 Fatality program things can fail!! Why? because no two human being is alike. There are barriers in terms of people, systems, infrastructure etc. Untitled.png
  3. The other reason BBS is a failure is Rifle vs Shot Gun approach. BBS needs Rifle approach of Aim->Fire. Shot gun approach is more a spread target!! So in Rifle approach folks needs to clearly know the behaviours that needs to be tackled head on called KEY FOCUS Behaviours. For that, one needs to have past history of incidents,accidents that are investigated and root causes linked to behaviour pattern are determined. The repeated behavioural patterns that cause most incidents (Say top 5-6) needs to be focused for a rifle approach. Many companies miss this or lacks sound incident investigation plan, metrics, history. They lose focus in to mix up behaviour and conditions monitoring. 
  4. If you want BBS to succeed,identify the key barriers that can cause the process to derail even after you identify key focused behaviours. Screen Shot 2017-04-06 at 11.31.13 AM

    So what are the barriers that can derail effective BBS implementation.

  • Lack of Hazard Recognition and Inadequate, ineffective Response to Hazards.
  • Business Systems, Process inadequate to handle safety /behaviour issues.
  • Infrastructural inadequacies to address behavioural issues.(Non Enabling behaviour)
  • Hygiene factors Rewards, Recognition aligned to individuals, lack of safety perception.
  • Personal Factors, Culture, Personal Choice.
  • Disagreements on what are the right safety practices.
  • Inadequate resolutions of issues brought out in BBS observations by Steering team.

To keep post short, I don’t want to go in to details on 10s of issues on Barriers that impede BBS implementation that I have seen in Facilities and no wonder programs fall apart when corrective actions don’t happen. 

So what else companies need to do sustain BBS long-term (say beyond 18 months when steam can fizzle out). 

  1. Fix new targeted behaviours to focus as BBS evolves.
  2. Crop new observers, familiarity can bring contempt, complacency.
  3. Support the observers with resources, embrace technology, go digital, show visible changes.
  4. Target Barrier removal % and move the needle, display progress to all.
  5. BBS expanded to all areas over time, all personnel including guests, contractors, visitors fully in scope.
  6. Leadership Engagement/Involvement. No program thrives without this element.
  7. Steering committee rotation, insight, knowledge.
  8.  Ownership spread to all level, ultimately every one becomes an observer.

As I keep saying, nothing I post here in new or not known to folks, the question is the gap in knowing/doing. Great organisations through effective leadership, risk based approach, empowerment to employees bridge the gap and execute every program flawlessly.

Karthik.

6/4/17

1315 Hrs. 

Act of God? Is it? Be an Atheist at WORK!

I wake up this morning to hear a Fox news summary podcast (every hour, 24*7) of a boiler explosion in St.Louis, MO which killed 3 and serious injury to 4. Such incidents happen whichever part of the world leaves you a bit demoralised for a while! I also read  John Newquist FB post on this at 530am! It appears that an exploded boiler piece flew 500 Feet and landed on roof adjacent building killed 2 persons there! It also appears that this incident affected few folks who were on their first day on job (Monday 8am filing papers)!!

Such incidents, an Act of God, as we call it can happen to any entity! I recollect with Horror a Major accident 30 years back in an upcoming Paint Intermediate Manufacturing facility at project stage at Ankleshwar, which killed 5(?) people including to be married soon Engineer.Screen Shot 2017-04-04 at 9.09.14 AM It was due to a pin hole through which steam seeped in and causing explosion of the RM storage tank which was getting heated. The global project contractor has installed Ten such installations all over the world, until then, without even a PIN PRICK to an employee! 

Act of God or not, there is a legal obligation for statutory authorities now to investigate incidents and put corrective actions in place. There would be some consequences for the affected entities with fine, penalties as well as possible case for man slaughter. Ofcourse, the positive side is great companies would learn from even the Act of God incidents to put in programs in place to prevent recurrence. I recollect our efforts to put in a Lightning Protection program to field employees when one of our colleague was killed while working in open, stuck by Lightning in Latin America dozen of years back. This included prevention, protection, forewarned aspects covering preventive, reactive, proactive measures. Thankfully, over next 15+ years not one life was lost despite increase in exposure.

So such incidents would continue to happen, court summons would come, exposure to image, liability, public outrage/sympathy would be the norm. So what can ESH folks do from their perspective to protect the first and foremost responsibility, which is to protect companies interest at all costs and add to bottom line? (Nothing more, nothing less, Safety First, is all an EMPTY SLOGAN, thankfully I never believed one minute even 30 years back, may be the Gujju water I drank, in me !!) 

  1. Comply with Legal Requirements !! Cross the “T”, Dot the “i” make sure that requirements are up to date. Tests, inspections, calibration, monitoring are not passed over due for any items. The scrutiny of such government agencies investigation can go back years. (As was case when records were searched as far as 28 years back) 
  2. Ensure that Risk assessment are done. It shouldnt come as a surprise shock and dismay to authorities that such act of god incident is thought off only after the accident. Learn from others and cover in risk assessment even such Black Swan scenarios! While you can’t do much to mitigate, when such happens, to be “Forewarned is ForeArmed” as saying goes! 
  3. Ensure Asset Integrity are all current. A good preventive maintenance program usually helps to prevent such accidents. (As saying goes, God also helps only those who help themselves so be an Atheist,never leave thing to God to help
  4. Carry out routine assessment, inspection, Audits of areas /facilities as a whole, with planned approach and tracking mechanism. Keep such documents up to date. Work out corrective actions as required without undue delay. Never leave smoking gun. Work deadlines that are practical, meaningful and doable.
  5. Work out training to all employees that are affected by area,actions, training and communication, helps to remove ignorance and creates awareness. Everything done to make people protection a key aspect helps to salvage some positive points in the eyes of Jury.
  6. Establish the dialogue process with employees through Safety committee(ESH Committee meetings) to bring in their concern, suggestion, opportunity for improvement. Work on such requests with priority, close the issues one way or the other ! This also helps morale at workplace and makes employee give positive feedback about company’s efforts in the eyes of investigator when company culture would come in scrutiny.
  7. Of course, Legal aspects are left to legal experts, take their guidance at every stage and work a plan. Never shoot yourself in the foot. I recollect a Senior executive, a good friend of mine of an Indian Pharma Major losing his coveted job when some uncontrolled documents in his possession (Kept folded in his work diary) lead to incriminating evidence against the company during the “FDA Inspection” meeting at conference room !!! Truth is stranger than fiction as I keep saying!! 

So such incidents of ACT OF GOD over which we have no control can happen and we can’t decide the outcome. (near-miss or Fatality based on luck, chance)! Best in class business work everything that would try to swing a positive opinion in the eyes of judiciary, public etc so that consequences to the business interest, reputation, damages are as minimal as possible through their actions. So be a WORK Atheist working only on logic, rationale, risk assessment and common sense in to play and never leave things to GOD!! ( I always say GOD= Good Only Deeds)!!! 
Good LUCK and GOD BLESS
Karthik.

4/4/17. 0900 Hrs.