Climate is what we expect, weather is what we get.
Mark Twain
Individual and collective human behavior displays traits that are, in certain ways, analogous to the natural appearance and impact of weather events. Normalization of deviation is this type of human behavioral trait.
To help make the connection to this analogy, let us accept the following premise. If humans are involved in any type of goal reaching behavior, that activity involves a process. If a process exists, however formal or informal it may be, there can be deviation from that process. Whether we use a simple example, a person preparing their evening meal, or a complex example, a group designing, building, operating, and maintaining a chemical processing plant, the trait of normalization of deviation will undoubtedly appear in some measure. The consequences of such behavior need to be addressed.
- We always hope the weather (that is, our situation) will be fine today. Sometimes we have advance notice of what to expect from a forecast for the weather. This is similar to the chemical plantās most recent audit report with action items. Sometimes an unexpected weather event affects us (as will the effects of our or othersā behavioral deviance).
- Normalization of deviance, like the weather, will appear and it will influence our experience. It is inevitable and can affect our goals in a negative wayāunless we monitor it and react to it.
- The analogy works in the following way.
- The weather is sometimes beautiful all day and night. We wish it were like this every day. The process is running normally. Normalized deviance appears to be non-existent. Procedures and standards are being followed. All is well.
- On other days that start out beautifully, normalized deviance may appear later with low impact, like a nice day with a few clouds or showers that roll through the area. Our process is experiencing some upsets that need to be watched or addressed. We do what we need to do to avoid the immediate effects and things might clear up for the rest of the day.
- On days when the skies turn threatening, normalization of deviationās impact can be like a sudden storm, unanticipated and harmful. It can appear quickly and demand immediate actions not previously part of the planned process. It is like a violent thunderstorm or tornado that appears during a large outdoor public event. A process safety incident or near miss that results from non-compliance with standards would be a processing related example.
- On yet other beautiful days, maybe even on the very day described in the first bulleted example in this list, deviations are being normalized somewhere just outside of our awareness (more likely, right under our noses) and its effects are not sensed at allāor they are ignored like small changes in the weatherāuntil specific events line up at the right time to allow a perfect storm to occur. Then, like tornados or tsunamis, process safety incidents can develop quickly.
Luckily for the chemical processing industry, the analogy above fails in one critical way. Unlike natural weather events, in the case of normalized deviance we can forestall the worst effects of the gradual organizational acceptance of nonconformance when we apply the twenty process safety elements of Risk Based Process Safety (RBPS) [CCPS 2007]:
Process Safety Culture: The combination of group values and behaviors that determine the manner in which process safety is managed. A sound process safety culture refers to attitudes and behaviors that support the goal of safer process operations.
Compliance with Standards: Identify, develop, acquire, evaluate, disseminate and provide access to applicable standards, codes, regulations, and laws that affect a facility and/or the process safety standards of care that apply to a facility.
Process Safety Competency: Maintain, improve, and broaden knowledge and expertise.
Workforce Involvement: A series of activities that (1) solicit input from the entire workforce (including contractors), (2) foster a consultative relationship between management and works at all levels of the organization, and (3) help sustain a strong process safety culture.
Stakeholder Outreach: The efforts to (1) seek out and engage stakeholders in a dialogue about process safety; (2) establish a relationship with community organizations, other companies and professional groups, and local, state, and federal authorities; and (3) provide accurate information about company/facility operations, products, plans, hazards, and risks.
Process Safety Knowledge: The work activities to gather, organize, maintain, and provide information to other process safety elements. Process safety knowledge primarily consists of written documents such as hazard information, process technology information, and equipment-specific information.
Hazard Identification and Risk Analysis (HIRA): All activities involved in identifying hazards and evaluating risk at facilities, throughout their life cycle, to make certain that risks to employees, the public, or the environment are consistently controlled within the organization's risk tolerance.
Operating Procedures: Written, step-by-step instructions and information necessary to operate equipment, compiled in one document including operating instructions, process descriptions, operating limits, chemical hazards, and safety equipment requirements.
Safe Work Practices (SWP) practice: An integrated set of policies, procedures, permits, and other systems that are designed to manage risks associated with non-routine activities such as performing hot work, opening process vessels or lines, or entering a confined space.
Asset Integrity and Reliability: A process safety management system for ensuring the integrity of assets throughout their life cycle.
Contractor Management: A system of controls to ensure that contracted services support (1) safe facility operations and (2) the company's process safety and personal safety performance goals. It includes the selection, acquisition, use, and monitoring of contracted services.
Training and Performance Assurance: Practical instruction in job and task requirements and methods, and the means by which workers demonstrate that they have understood the training and can apply it in practical situations. Training may be provided in a classroom or at the workplace, and its objective is to enable workers to meet some minimum initial performance standards, to maintain their proficiency, or to qualify them for promotion to a more demanding position.
Management of Change (MOC): A management system to identify, review, and approve all modifications to equipment, procedures, raw materials, and processing conditions, other than replacement in kind, prior to implementation to help ensure that changes to processes are properly analyzed (for example, for potential adverse impacts), documented, and communicated to employees affected.
Operational Readiness: The efforts to ensure that a process is ready for start-up/restart. This element applies to a variety of restart situations, ranging from restart after a brief maintenance outage to restart of a process that has been mothballed for several years.
Conduct of Operations: The embodiment of an organization's values and principles in management systems that are developed, implemented, and maintained to (1) structure operational tasks in a manner consistent with the organization's risk tolerance, (2) ensure that every task is performed deliberately and correctly, and (3) minimize variations in performance.
Emergency Management: The work activities performed to plan for and respond to emergencies. : A systematic approach for determining the causes of an incident and developing recommendations that address the causes to help prevent or mitigate future incidents.
Measurement and Metrics: Establishment of performance and efficiency indictors to monitor the nea...
