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David E. Cummings
E.I. DuPont de Nemours & Co.,Inc.
Prepared for Presentation at American Institute of Chemical Engineers 2013 Spring Meeting 9th Global Congress on Process Safety San Antonio, Texas April 28 May 1, 2013 UNPUBLISHED
AIChE shall not be responsible for statements or opinions contained in papers or printed in its publications
GCPS 2013 __________________________________________________________________________ Key Strategies for Implementing a Corporate Fatigue Risk Management System
David E. Cummings
E.I. DuPont de Nemours & Co.,Inc.
1007 Market Street, Wilmington DE 19898 david.e.cummings-1@dupont.com Keywords: fatigue, fatigue management, ANSI/API 755, human factors
Abstract
The First Edition of ANSI/API Recommended Practice 755 Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries was published in April 2010 as a result of the BP Texas City catastrophe of March 2005. In the last two years, many companies in the petroleum and chemical processing sectors have been working to implement the basic tenants of this new practice. An effective fatigue management program involves a multi-disciplined team approach to engage various functions of an organization, including PSM/EHS, HR, Medical, and Operations. This paper will explore the process, associated elements, and key issues integral to the design, development, and implementation of a formal fatigue management system across DuPont as a global manufacturing organization with a diversity of high hazard processes. This includes internal policies, training and development, standardized procedures and tools, and internal collaboration strategies.
1. Introduction
ANSI/API Recommended Practice 755 was issued in 2011 based on a recommendation issued to the American Petroleum Institute by the U.S. Chemical Safety Board as an outcome of the BP Texas City 2005 incident investigation report. Prior to that time, there was little industry guidance or standards on the subject of fatigue management (FM). There is and has been substantial literature published and technical resources developed on the general issues and concerns with fatigue management in terms of circadian rhythms and the effects on human performance variables, and many industries such as aviation and commercial transportation have adopted specific standards with accompanying regulatory requirements. E.I. du Pont de Nemours & Co. is a global science-based products and services company with over 200 manufacturing units across 70 countries involving nine business segments. It is engaged in technology solutions and innovation across a range of disciplines, including agriculture and industrial biotechnology, chemistry, biology, materials science and manufacturing, offering a wide range of products and services for markets including agriculture and food, building and construction, electronics and communications, general industrial, and transportation. Manufacturing technologies and site operations involves a myriad of process hazards, including flammable liquids and gases, highly toxic materials, reactives, combustible dusts, corrosives, asphyxiants, and thermal/mechanical energies. DuPonts philosophy and current practice is to apply process safety management systems and requirements to all manufacturing operations and locations using one global set of internal elements and technical requirements. Based on the companys current risk profile, process safety systems that help maintain a high degree of operational discipline and reduce the potential for human error, including those that could be related to employee fatigue, are key elements of an integrated risk approach.
GCPS 2013 __________________________________________________________________________ DuPonts process safety management model and system has included a long standing element and requirements for Training and Performance where the performance portion of the element requires a specific focus on physical capabilities (fitness for duty) as well as diminished capacity (mental and psychological capabilities for process safety sensitive jobs, including the effects of fatigue) for operating and maintenance personnel working at all manufacturing locations. DuPont updated the Training and Performance element to specifically include an internal fatigue management policy as an integral part of the global process safety management program in January 2011. Initial implementation of the new technical requirements has been progressing since that time. The program embraces the following key elements of fatigue management as described in ANSI/API 755: Maximum hours of service Training for employees and line management Staff workload balance Work environment evaluations Medical Evaluations (personal risk factors)
Implementing a fatigue management system was integrated into corporate process safety management systems; however, active involvement of other key functions within the organization is important in this area. Within DuPont, the process safety competency serves as the corporate owner on FM, while other key functions such as Human Relations (HR), Integrated Health Services, and Occupational Health (EHS) all have played a meaningful and contributing role in developing and implementing portions of the FM process in the initial design stages, during implementation, and in an ongoing role as part of the run and maintain phase of this work. This collaboration has contributed greatly to the overall results.
Once the site survey was completed, the data was collated and utilized as inputs for the development of corporate policies, timing and implementation plans, management training, and development of internal FM training and guidance documents. The survey was collected and analyzed in a simple excel tool similar to that depicted in Figure 1.
This definition does not cover all situations where an extended work set and shift schedules may be applicable and necessary to minimize fatigue, including commissioning new plants or substantive MOC projects where construction, PSSRs, start-ups, and lining out the process may be necessary involving
GCPS 2013 __________________________________________________________________________ operations, technical and R&D resources, response to natural disasters (e.g., hurricanes, earthquakes, etc.), mothballing or dismantlement activities, new product trials in pilot plants, etc. Each company should define when and how these types of situations should be managed in terms of unique conditions and the application of extended work hours and shift schedules with potential fatigue factors. DuPont adopted an internal policy at the site level to develop a formal exception process for situations where the Hours of Service Limits (ANSI/API Table 1) may not be met due to specific circumstances. An exception process is discussed in the standard in Section 4.8.5 with general criteria, however; the specific procedures and details should be developed by each company. For DuPont, the exception approval process has been designed to be executed at the local level for a case-by-case exception by site or unit management. For longer term, permanent, or standing exceptions, off-site leadership approvals are required. In both cases, exceptions will document the situation, the rationale, and any relevant alternative controls or methods to be taken to mitigate the potential effects of fatigue. This includes use of a standardized form and line management approvals for each exception situation.
Figure 4: Sample Site Analysis Time and Attendance Schedules A significant part of DuPonts initial evaluation of existing shift schedules and site data survey questions focused on the types of tracking and software (scheduling) tools that were either already in use or could require development to track work hours, including scheduled and unscheduled overtime call-ins. In most cases, site systems tracking overtime rates for work groups but not specific employees other than annual salary statistics. Site level tracking systems which were cataloged that could be modified and used to monitor maximum hours of service and off site recuperation times included the use of an HR work hours and pay status, web based tools, security gate electronic logs, and access data bases. None of these existing systems as structured were deemed an acceptable and reliable means to proactively schedule, manage, and track individual employee work hours. A six sigma black belt resource and project was initiated in order to review each of the work hour and overtime tracking system attributes, and develop a standardized solution that could be used at all sites to help line management ensure that the maximum hours of work in ANSI/API 755 Table 1 maximum hours of work. As part of the six sigma project, the main attributes of an overtime tracking system were captured as illustrated in figure 5.
Figure 5 : Site Survey Data Desirable Attributes for Electronic Scheduling and Tracking
4. Training
DuPont developed a standardized and leveraged training package which could be applied at each site in order to provide initial and refresher training on fatigue management. Two packages were developed ; one to target employees who were subject of FM (operators and mechanics), and one for line managers who supervise these employees. The guidance and criteria in ANSI/API 755 was used to create the technical content of each package. Initial training was designed to be one hour of information and cover the following topics: Basics of sleep and fatigue including causes, symptoms, and prevention strategies Understanding risk of on the job fatigue and impacts on safety Overview of the site fatigue management system including maximum hours of service criteria
DuPont occupational health resources have also previously partnered with external groups such as the Porcupine Health Unit and the Sudbury & District Health Unit in Canada to develop additional sources of fatigue management training such as the Shiftwork like Clockwork (SWLCW) training modules illustrated in Figures 6 and 7 . These materials provide significant details over nineteen (19) modules that can be used for both initial training of new employees and refresher training for existing employees. DuPont has adopted an internal FM refresher training frequency of three years.
6. Work Environment
DuPont has utilized a series of PHA related tools and checklists to conduct baseline, cyclical and MOC related evaluations for over the past twenty years. A human factors checklist has been one of these historical tools. DuPonts strategy to address FM work environmental factors involved adding content to these existing tools in order to help ensure that fatigue management workplace factors were considered and evaluated during all cyclic and project related PHAs. Integrating this review into existing PHA processes has proven to be a more sustainable and effective practice rather than creating a stand alone fatigue management work environment assessment process.
8. Contractors
DuPont has also adopted internal process safety requirements for a fatigue management program applied to selective contractors who work in higher hazard process areas which typically is limited to resident maintenance service providers, test and inspection consultants, and specialized services resources who may be on-site only during major turnarounds. Contractors are required to develop their own internal programs with the basic elements of fatigue management as described in ANSI/API 755. DuPont will typically audit their systems and performance at the site level on a periodic basis to verify the program is adequately implemented. Many major contractors have embraced an enhanced focus to manage fatigue risks. In one example, a resident maintenance contractor developed a modified approach for their employee work scheduling during an annual shutdown with a DuPont site in Protection Technologies in order to improve fatigue management practices. The shutdown typically lasts 15 days involving 12 hour shifts and the contractor reduced the shift duration to 11 hours and inserted a day off for each employee during the process. Feedback from the employees was very positive, and this modifications were managed so that there were no additional costs or delays in the shutdown schedule. This unique approach serves as a good example where the owner/operator (DuPont) worked in collaboration with contactor partners to achieve a common objective which also supported the business and operations.
10. Conclusion
Based on the lessons learned from the BP Texas City incident in 2005 and the new ANSI/API 755 Recommended Practice, internal company initiatives to integrate fatigue management into existing risk management systems is a prudent and necessary step to help minimize the potential for human error and the associated episodic incidents in high hazard process operations. The process safety function should be the logical process owner, however, the initial systems design and implementation activities involving fatigue management necessitate a collaborative effort between other key company and site level resources and functions, including operations, human relations, health services and occupational health, in order to develop an integrated system and achieve maximum risk management benefits. Since the ANSI/API RP 755 standard includes primarily performance based content, implementation also may involve a substantial number of internal corporate or local policy decisions, and potential issues which require focused discussions and interpretations to promote consistency with internal applications at each site. The initial FM implementation process may span two to three years in order to plan, educate, develop, implement and monitor site level organizations and accompanying results. Organizations that include
GCPS 2013 __________________________________________________________________________ fatigue management requirements in existing PSM policies should recognize that implementation progress may vary at each site depending on size, complexity, shift schedules, the existence of labor unions with collective bargaining agreements, and other factors. These potential variations on the rate of progress require a simplified process to track implementation across all applicable operating sites (see figure for an example of tracking based on the six main program elements). Integration of fatigue management evaluation criteria into existing PSM audit protocols and systems is typically the last step in a long term FM implementation and performance measurement process.
11. References
(1) American National Standards Institute (ANSI)/American Petroleum Institute (API) Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries - RP 755 (First Edition, April 2010)