intelligent scada systems - iceweb safety/compliance.pdf · properly established compliance...

Session Five: Properly Established Compliance Applications Provide Valuable Learning Platforms

2013 Electrical Arc Flash Conference – IDC Technologies 1

Session Five:

Properly Established Compliance Applications Provide Valuable Learning Platforms

Dr Donald Glass

Engineering Consultant & Executive Director, St James Software

Abstract

Regulatory compliance in many countries and many industries is mandatory and the reporting requirements can be quite complex and onerousi. Compliance standards such as NERC (North America) have over 1000 regulations that need to be regularly analyzed and considered.

A number of facilities in North America have configured their Compliance Management applications together with other Operations Management applications (such as operations logbook, handover logbook, incident manager, hazard & root cause analysis) to provide a platform for continuous learning about the facility, the operations and the risk areas.

An example of this approach can be observed in the linking a permit-to-work application with an operations management operation. The resultant, automatic escalation of high risk situations, combined with relevant information, allows the permit to work application to not only set a high standard – supporting the drive for high safety standards - but simultaneously help employees improve their skills while performing their duties.

We examine how managers can use compliance programs to help with the training of new staff as well as with the streamlining of maintenance, safety and environmental programmes.

Introduction

Accidents simply happen – or do they? The truth behind each accident is that something, someone or a series of situations, things and people have acted, or more frequently not-acted, in such a way that an accident is almost bound to happen. Something causes accidents. The cause, more often than not, is a series of events, mostly unnoticed, that build up over a period of time.



Plenty of statistics from Power stations across the world have built up a clear picture on the build-up to incidents, injuries, lost-time injuries and worst case scenariosii.

The culprits – causes – can be grouped into three categories, namely equipment, the process or people. This paper talks to these culprits!

Accidents don’t just happen

Accidents are Incidents with more serious consequences. Incidents are near-misses that actually happened. Near-misses are incidents that nearly occurred.

All incidents can be traced back to one or more of the causes linked to equipment failure, process problems or human error.

(Process problems are usually result of equipment or people, so for the remainder of this paper we will focus only on equipment and people)

In order to reduce all levels of incidents on a facility, it is necessary to reduce – and aim to

eliminate – unsafe equipment conditions and unsafe human behavior. The two key words in this section are People and Equipment

Shift Handover

Gartner Researchiii has revealed that most accidents or serious incidents occur within 30 minutes of a shift change or as a direct result of something important not being handed over clearly.

Why is this?

The key element in the handing over of responsibility for a running plant is in context, relevance. The simple facts of what is taking place on site can be easily deduced or discovered from the data & control systems. The relevance – the why – of past decisions is often an unknown. It is this unknown that may result in the incoming operator making an incorrect decision, leading towards an incident with negative consequences. The key words here are Relevance and Plant Information.

The remainder of this paper will focus on these four key words: People, Equipment, Plant Information and Relevance



How does a Responsible Manager ensure Compliance and reduce Accidents?

Plant managers are responsible for ensuring that their facilities are fully compliant with all relevant legislation – including staff and facility safety. Plant equipment may be old or aging and staff may be inadequately trained with experienced staff having retired. How does a plant manager survive?

In short, he needs to find Qualified, Experienced, Trained and Compliant staff. Not easily achievable through the employment of additional – or new – staff, so the best alternative is to develop and train internally. The next question to be addressed is that of the nature of the training.

Another key element to accident reduction is continuous learningiv in plant knowledge and regulatory compliance.

It’s interesting to note that plant knowledge, regulatory compliance, training, equipment, people and relevance are all interlinked.

We now look at how a plant manager can use a suitable Management Information system linked to a Compliance management system to provide continuous (real-time) training for staff working on site.

Plant Data, Information, Knowledge, Education & Trainingv

PLANT DATA to INFORMATION

Every plant is full of data. Distributed control systems and historians have been collecting data since the 1980’s. Data (applied measurements) has been stored at plant level and aggregated to group and network level and is available for analysis and report generation.

Conditions, events and parameters on the plant are available to be measured. Data is applied measurement, meaning that various measurements collected over a period of time and collated into relevant groups yields data.

Applied measurement = data

INFORMATION to KNOWLEDGE

In a similar manner it can be shown that applied data yields Information and applied Information yields Knowledge.

How is Information applied in order to obtain knowledge? Quite simply, it is important to determine relevance of the data and information, and to obtain the context in which that information is collected. One can define Knowledge as Information + Relevance.



Again, it can be shown that applied knowledge yields wisdom. Our objective in adapting a Compliance Management system is to enable staff to learn the difference between Information, Knowledge and Wisdom.

An example in the power industry: Information is knowing how many Arc Flash incidents have occurred on the facility. Knowledge is knowing all about Arc Flash occurrences, what can cause them or prevent them. Wisdom is knowing how to avoid an unplanned Arc Flash from occurring.

Education to Training

Basic education is about obtaining information. Quality education is about gaining knowledge – or how to apply the information learned at a basic level – but it requires meaningful training after a suitable education to gain the level of knowledge which can be applied into wisdom. The kind of wisdom that enables staff to be effective, safe and compliant in all operational circumstances. The kind of knowledge needed by all staff employed in facilities aiming to be fully compliant to all regulatory, operational, safety and environmental standards.

Proper training is all about gaining wisdom (i.e applied knowledge). Proper training is continuous. Proper training is always relevant.

Compliant, training-focused facility

Putting the theory together and extracting the common requirements, it is clear that facility management needs to focus on process Information, equipment status and people all within plant-context-relevance.

Four key words for both Compliance management and Training are: People, Equipment, Plant Information and Relevance.

Technical example:

Voltage (data) and Current (data) can be combined (applied) to provide Power Information.

A single piece of power information on its own is hardly valuable, but add some context – some relevance – say a time period or cumulative value compared to a standard, and you have the start of some tradable, usable knowledge. MWHrs delivered is tradable knowledge.

Non-technical example:

How do we apply this then to less technical situations? To Safety matters; to environmental issues; to behavior; to people?

One client in southeast Asiavi determined that the number of “incidents” (resulting in lost time injuries) was unacceptably high. It was decided to do something about it. They looked for a way to de-construct the causes for these incidents.



{In a similar manner to the way that one can start with MWHours and work backwards to define the “inputs” – in this case Voltage, Current, Time and Power factor – this client began with INCIDENTS (Knowledge) and de-compiled the information to determine the causative data.}

They determined that a key input to the number of Incidents was the awareness of staff to problem situations that resulted in “non-incidents” or near misses. These problem situations could be the result of faulty equipment or poorly trained staff. They determined that if staff could become aware of every near-miss – and the reasons for that near-miss “non-incident” – and learn from those reasons, that overall safety would improve.

They decided to enforce the measurement (notification & scope & details) of each & every near-miss that occurred – to people and equipment.

Immediate result: Reduction in Incidents

Longer-term result: Training (transferred knowledge) of staff

What is a Compliance management system?

Compliance Systemsvii have three main sections:

Standards: The collation of relevant standards is fundamental in order to determine what the aims, objectives and goals of any system are. Typically these standards will be broken into the following categories:

Operational: matters such as voltage & frequency stability. Planned shutdowns. Standby generating capacity.

Safety: Staff, equipment and network connection safety issues.

Environmental: All actual or potential environmental situations.

Emergency: Network stability. Security.

Procedures: The compliance system will have numerous procedures that formalize the collection of data, escalate deviant measurements, generate alerts and activate workflows, involving relevant decision makers or other processes.

Reports: Various kinds of reports play a large role in an effective compliance system. Month-end reports are required to prove compliance, but more immediate – real-time – reports and notifications and alerts can be used to trigger fast response to deviant process activities.



What is a Training-focused Compliance system?

An excellent training mantra is:

Watch me do it : do it with me : do it with me watching you: do it on your own; do it with someone else.

In an ideal world every new employee / trainee would shadow an experienced person until he/she was fully competent. The experienced person herself/ himself would also be highly competent, and thus the system of excellence would continue and expand. Unfortunately, reality creeps into the mix and new employees are often faced with situations for which they have no experience – sometimes even limited knowledge or basic training.

How does a training-focused compliance system address this issue? Is it even possible?

1. Supporting the easy capture of all compliance-relevant events (situations and conditions)

2. Adding Operations staff comments (and reason codes) to all plant & process events

3. Triggering situation-relevant workflows to involve suitably qualified staff for critical situations

4. Minimizing duplicate data capture while maximizing the scope and availability of all data captured.

5. Supporting integration with other tools and data sources on site, to minimize necessity for duplicate input.

6. Grouping relevant topics and subjects together for comparison.

7. Preparing relevant reports, notes and comparisons for each compliance failure or event logged.

8. Ensuring latest revision SOPs, Technical sheets, Instruction manuals and drawings are linked to each action or intervention.

9. Supporting root cause and incident analysis methodologies in which all staff are involved as soon after an incident (or event) as possible.



10. Providing regular feedback to staff – determined by their discipline and training levels.

11. Supporting mobile technologies for fast response.

Example

A training-focused Compliance Applicationviii installed in many power facilities across North America, Europe and Asia. This application comprises the following modules:

Operations Logbook – electronic (Plant awareness logging). The capture of all Operational, safety; environmental; maintenance, service; manpower, exposure hours are all captured and linked to actual plant data to provide plant-context relevant information.

Handover Information and shift reports ensures that all staff on outgoing shifts follow proper routines and all incoming staff receive all relevant – and accurate – plant information. (True knowledge transfer)

Workflow module: to escalate any matter to the correct level so that meaningful responses are given to all situations.

Context-relevant documentation: instructions, SOP for each “event” or situation. {example, for Permits to Work. The PtW is issued together with all relevant documents, video clips, parts lists and procedures}

Compliance management Module: This application contains NERC, OSHA and EPA specific data and compares the requirements against plant performance, creating log entries in the event of all deviations or non-standard occurrences.

Incident manager: The analysis of each incident – with proper root-cause examination – is a powerful training tool if conducted quickly, consistently and with minimum additional workload on the operations and engineering teams.



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Root Cause Analysis

Immediate Causes

System Causes

Corrective Phase

Network and load-planning communication: It is important to communicate regularly with the network planners – particularly if loads are fluctuating or equipment failure is imminent.

Continuous Training module: As staff gain experience and plant knowledge, it is wise to track this and communicate positive success to staff. Each event in which an employee is involved can be recorded, and the relevant learning experiences can be extracted.



Footnote:

For a more detailed discussion on experiences gained during the design and implementation of systems and applications described in this paper, the author welcomes your contact.

References

i Nerc requirements – http://www.nerc.com/

ii Safety statistics - http://www.osha.gov/oshstats/ and http://www.hse.gov.uk/statistics/

iii Gartner report reference http://www.eia.gov/elec.tricity/data.cfm#e.lecenv

iv Continuous learning http://en.wikipedia.org/wiki/Learning_organization

v PhD Thesis, London, 1998. Don Glass

vi SE Asia client – name withheld at request of the client. Non-published introductions possible, on request.

vii http://en.wikipedia.org/wiki/Regulatory_compliance

viii St James Software has installed many applications in over 27 countries. For futher information visit www.sjsoft.com

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http://www.nerc.com/

http://www.osha.gov/oshstats/

http://www.hse.gov.uk/statistics/

http://www.eia.gov/elec.tricity/data.cfm#e.lecenv

http://en.wikipedia.org/wiki/Learning_organization

http://en.wikipedia.org/wiki/Regulatory_compliance

http://www.sjsoft.com/

intelligent scada systems - iceweb safety/compliance.pdf · properly established compliance...

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