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at any time, not just on day-shift: Backshifts, weekends, holidays, etc. there’s no time immune to a possible incident. You may also find indications of incidents occurring in walk-through logs, communications logs, ITPMRs, work orders, etc. Here’s some II related questions you might ask to help you determine if your staffing is adequate: • Are incidents being reported, conducted, and documented? If not, is this a culture issue or a staffing issue? • Are incidents and incident report findings & recommendations being addressed, communicated, and followed to their conclusion? Are there incidents that could have avoided with proper staffing? Are there incidents that would have their severity reduced with proper staffing? Are there incident investigations with recommendations that could be addressed with proper staffing? Management of Change / Pre-Startup Safety Review: Properly implementing the MOC and PSSR elements takes a lot of time! We often find that these two elements are amongst the first to “fall behind” in suboptimal staffing situations. Here’s some MOC/PSSR related questions you might ask to help you determine if your staffing is adequate: • Have MOCs / PSSRs been conducted when they were supposed to be? • • • Were the MOCs / PSSRs conducted adequately to properly manage the hazards related to the change and the new systems? Is the documentation of MOCs / PSSRs complete? Are there any open items or recommendations from MOCs, PSSRs, or project punch lists? Process Hazard Analysis: The PHA and open PHA recommendations can also help us understand if our staffing levels are appropriate. There may also be indications in the PHA itself. There’s a portion of the • • •

PHA that deals with staffing directly, but we’ll deal with that in the Building a defensible case on staffing section of this article. Here’s some PHA related questions you might ask to help you determine if your staffing is adequate: • Are the PHA recommendations being addressed, communicated, and followed to their conclusion? Is the facility provided with modern controls, alarm systems and equipment? (Newer, modern facilities often have significantly lower staffing needs than older ones) Has the PHA been updated / validated as required by MOC activities and the 5yr schedule? Emergency Action and Response Plans: Whether we’re looking at the plan(s) themselves, or analyzing an after-action report, there can be a lot to learn here concerning proper staffing levels. Obviously, the required staffing levels for Emergency Response facilities is going to be higher, but that doesn’t mean there is no staffing requirement for Emergency Action plans. Here’s some EAP/ERP related questions you might ask to help you determine if your staffing is adequate: • In the event of an incidental release of • • ammonia, do you have adequate staffing to investigate and respond? In the event of an emergency response, even if you are not a “responding” facility, do you have adequate staffing to ensure that the equipment is properly shut down? If you are a “responding” facility, do you have enough adequately trained personnel to staff your response team including an Incident Commander, safety officer, decontamination personnel, two entry teams, etc. If you bring key staff back on-site to deal with emergencies, are they close enough to respond in a timely manner, or do you need to increase the size of your trained response team? • • •

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Are we addressing MI recommendations in a timely manner?

• Are there indications that maintenance of the facility and system are being conducted properly and required repairs aren’t being delayed? Are there no indications in the written MI records, or in your observations, that the system is running outside the written operating limits? Incident Investigations: A review of incident investigation history can tell us a lot, if the facility has a good process safety culture. But if they don’t have the right culture, and /or they don’t have any documented incidents, you’re going to have to do a little detective work and interview plant employees to find out if incidents are occurring that aren’t being recorded. Remember to spread your net wide here because incidents can happen •

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