Process Safety Management: Can We Please Stop Saying, “If You Didn’t Document It, It Didn’t Happen”?
Ask ten people about process safety management (PSM), and chances are at least seven of them will tell you about mountains of paperwork designed primarily to keep auditors happy. They might say, “I spend so much time doing paperwork that I don’t have any time for my real job!”
We need to talk.
Recordkeeping certainly plays an important role in a good PSM program, but let’s not elevate it above its rightful place. PSM is about people, not paperwork. Good recordkeeping helps us do valuable things like manage activities, properly allocate resources, and identify the need for additional training. However, paperwork by itself is pretty worthless. Let’s not insult the common sense of the people who work every day to keep a process safe and then suggest that their efforts “didn’t happen” because they failed to complete a work order.
Does anyone really believe the absurd corollary: If you did document it, it did happen? I recently conducted a PSM audit and observed a carefully completed hotwork permit posted in an area where people were welding. There were all sorts of combustible materials in the immediate area, including the hotwork permit itself. In this case, the documentation was less than useless— it was actually a fire hazard.
If you want to reinforce the need for good recordkeeping, I suggest you consider the phrase, “You can’t manage what you can’t measure.” This communicates the need to manage and look into the future, which is the only place where you have an opportunity to prevent a catastrophic release. Records help people make decisions that reduce the risk of an accident. I strongly believe that people will quickly identify ways to focus and streamline documents if they actually use those records to make important decisions. Because, seriously, who wants to look at useless paperwork all day?
Something is wrong if you can’t see a connection between the time you spend on recordkeeping and risk reduction. Perhaps your understanding is wrong, but it’s also possible that your process is just inefficient. PSM is a performance standard, which means you have a lot flexibility in how you set up your system to comply with the requirements. Take advantage of that flexibility and focus on management and risk reduction instead of paperwork. And pretty please, with sugar on top, let’s all stop saying, “If you didn’t document it, it didn’t happen.”
Bill Beadie, CIH
Principal Industrial Hygienist