The Best Laid Plans??? (O &T; CAPA)

Note:- It was great catching up after three years, with my Honeywell Boss (2006-12) Anthony Wareham, this week. He has since moved out of Honeywell in 2015 and was on Business visit here. I accompanied him for HSE Legal compliance support across locations in Madras, Chandigarh. (Anthony and I have monthly catch up on happening at Work, #Brexit, Rugby etc etc) 

In my 4 years of support visit to facilities, one of the aspect which amazes me is the lack of clear objectives and targets that are Specific, Measurable, Accountable, Result Oriented and Timely.(SMART) that establishes and measures the safety performance in most of the facilities I visit. What is sad is these facilities are certified for safety, environmental, Quality management systems, thus making me wonder are such certifications a Tick in the box!!! 

So what are the expectations from this program:-

• Integrate HSE objectives and targets (O&T) into business processes, safety succeeds only when it leans on Business and acts as a value enabler! Link O&T to Business metrics.
• Establish a HSE Management Plan to achieve strategic Plans (3-5 years) and Annual Operating Plan (AOP) performance expectations
• Establish, assess and maintain objectives and targets which assure continuous improvement of the HSE Management Systems. A good Management system sustains efforts for better HSE performance.( Note HSEMS is not ISO 14001 or OHSAS 18001, but can be)
• Ensure HSE objectives and targets are established to address and manage the frequency and severity of HSE risk that are identified in through Risk Assessment. The hierarchy of controls for such risk mitigation can be guideline for setting them.
• Ensure proactive and reactive performance measures are integrated into a HSE Management Plan. What gets measured gets done; so start measuring.
• Note that Objectives are broader scope of implementation with Targets narrowing down to precise quantifiable aspect. Plans are measures that involves breaking down the O & T in to manageable, doable steps. 
• Ensure that Senior leaders sign off on O&T and plans. as said, align to business goals as value enabler.

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  So what are areas of setting O & T. (They are both Proactive and Reactive)

  • Accident rates, Near miss, First Aid. (Linked to site census)
  • Behavioural observation, Conditions monitoring.
  • Safety linkage to permits, Preventive maintenance Machine down time! 
  • Risk Assessment in facility, area, process, procedures update
  • Self Assessment, Audits, Inspections.
  • Safety committee meetings, Suggestions
  • EHS design review
  • Corrective Action closure Targets % items close out
  • Training hours, communication handout.
  • Waste, Air Emissions norms,Spills etc 
  • IH Monitoring Work area
  • Employee Safety Perception Survey
  • Sustainability Index linkages as applicable ( Fuel efficiency, Green house gas reduction, Renewables etc)
  • OCP updates!
  • MOC Close out
  • Trend Analysis and setting Objectives from Trend for future.

Establishing and implementing O & T enables organisations and EHS professionals to charter a course over which they can have all the control and do course corrections as required. A good linkage to Facility’s EHS policies, Legal Compliance, Conformance to Corporate Norms besides Risk Assessment outupt shall be a good data points to establish “SMART” O &T. 

It goes without saying displaying O&T at stragegic locations where people can have visual contact would calibrate facility on progress on the same.

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++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++Also another aspect that is missing is the Corrective action closure of actionable items as identified from incident investigation, audits, Inspections, or any other means which trigger an action. Many times issues are open with due past well going months/years beyond original completion date!! This is similar to Smoking Gun situation. Never let the situation get ahead of you or your management! Stay on top on Corrective action closure. This helps when incidents like major spill, leaks, fatality happens and authorities drill deep in to your past record keeping to find items open for years and years!! (DuPont has issued open for 20+ yrs in Belle, WV Fatality)!! (This is an example and intention is not to name & Shame a company) 

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One of the practical way to stay on top is to classify corrective actions that are due in to 1) Items that can be closed within 30 days, 2) Items that can be closed within 90 days and 3) Items that can be closed with 180 days. Corrective actions which require >180 days to close should be taken out of Facility responsibility as it would require resources that are beyond facilities budgets, capability.

Once closed use validation process through check by a III party or III person not involved in the process so that there are no Bias, skewed interpretation of closure. 

Corrective actions at end of pipe and O &T beginning of the pipe if done well can let the Safety system flow smooth! Some times in great organisations, the best laid plans /Schemes do go smooth like oiled machine.

Good Luck, God Bless

Karthik.

29/4/17, 1305 Hrs.

Author: Karthik B; Orion Transcenders. Bangalore.

Lives in Bangalore. HESS Professional of 30+ yrs experience. Global Exposure in 4 continents of over 22 years in implementation of Health, Environment, Safety, Sustainability. First batch of Environmental Engineers from 1985 Batch. Qualified for implementing Lean, 6Sigma, HR best practices integrating them in to HESS as value add to business. View all posts by Karthik B; Orion Transcenders. Bangalore.