Equipment Identification - Need / Call to Action

Incidents Continue to Happen 

Maintain a Sense of Vulnerability

A Sense of Vulnerability Is Healthy – Just because it has not happened yet (or here) does not mean it will not happen in the future!

• Is a sense of vulnerability a critical part of the mindset of every employee and contractor?
• Do you require consistency in practice from everyone in the organization?
• Do you have systems in place to determine if inconsistencies exist?
• Do people believe that “yes, it can happen here”?
• Do people believe that “yes, we have similar vulnerabilities”?
• Have you experienced similar incidents but without consequences (i.e., near misses)?
• Do you combat organizational overconfidence that can be stimulated by past good performance?
• Do discussions on potential vulnerabilities take place between operations and senior leadership?
• Do systems exist that can identify improper or insufficient Equipment Identification?
• Have you experienced incidents or near misses due to improper or incomplete labelling, tagging, or identification?
• Are Equipment Identification checks included on Return to Operation or Return to Service checklists?

Prevent Normalization of Deviation

Normalization of deviation is defined as…..

Signs of Normalization of Deviations – Does this describe your organization?

• If a deviation is absolutely necessary, are there defined steps that should be taken (i.e., a written variance procedure)?
• Do these defined steps (or variance procedure) require a detailed risk assessment and approval from multiple levels within the organization?
• Are the expectations clear that no one individual alone is permitted to determine whether a deviation is permissible?
• Do you allow operations outside established safe operating limits without a detailed risk assessment?
• Are willful, conscious, violations of established procedures tolerated without investigation or without consequences for the persons involved?
• Can employees be counted on to strictly adhere to safety policies and practices when supervision is not around to monitor compliance?
• Are you tolerating practices, or conditions that would have been deemed unacceptable a year or two ago? 
• Are all employees empowered to stop work for any situation deemed unsafe?
• Are all levels of the organization comfortable with calling out identified gaps?
• Have you experienced incidents or near misses due to improper or incomplete labelling, tagging, or identification?

Evaluate Your Program

Do you audit your Equipment Identification program to ensure the program is yielding the intended results?

Do you review the following items?

• Written procedures?
• Roles and responsibilities of persons involved in Equipment Identification activities?
• Training and competency provided to persons involved in equipment identification activities?
• Hazard assessments performed before equipment identification activities are conducted?
• Job observations performed on equipment identification activities?

Items to consider when evaluating your Equipment Identification program include:

• How is the identification and tagging of equipment and materials done as a practice?
• Is the local procedure in line with the codes and regulations specifying requirements for various classes of material equipment/pipeline tagging? 
• How frequently are the unique identifiers reviewed and corrections or updates made to highly critical equipment?
• Does the Permit to Work (PTW) cover how to identify incorrect tagging of the equipment?
  
  • Are there corrective actions prescribed if any discrepancies are found that might result in a hazardous situation?
• Do you check equipment identification, tagging, or marking before issuing a permit?
• Are spares identified properly? Do you have a procedure to check the tagging of new spares?
• Are any work flow documents referred to before issuing a job permit?
• Are changes to the equipment made that are not identified or labeled properly?
• Are there tasks that are done on a daily basis such as sampling or unloading of tankers that have nearby incompatible material connection?
• Have incompatible materials been identified and segregated in bulk storage locations?
• Have you experienced incidents or near misses due to improper or incomplete labeling, tagging, or identification of equipment?
• Are equipment identification checks included on Return-to-Work or Return-to-Service checklists?
• Are equipment identification checks included on field inspection checklists?

Continually Improve Your Program

Are you considering improvements to prevent future incidents due to Equipment Identification deficiencies?  Few ideas you may want to consider:

• How frequently do you review US Chemical Safety Board (CSB) reports, CCPS Process Safety Beacons, internal learnings and alerts from incidents, or any other relevant incident communication having Equipment Identification learning potential with all members of the organization?
• How often do your senior managers visit the field to identify any improper Equipment Identification in highly hazardous areas?
• Do you have a requirement to periodically update any review program that targets identification of improper equipment tagging and marking?
• Do your workers (those closest to the work), have a method to point out deficiencies and suggest improvements to your program?

Organizational Culture

A successful Equipment Identification program depends on the actions of individuals within the organization.  Do the values and behaviors of your organization determine the manner in which your Equipment Identification program is managed and executed?

• Does management and supervision reinforce desired behaviors to ensure they become integrated into the group’s values?
• Are performance expectations / standards clearly established?
• Is open and effective communication encouraged and supported?
• Has management established safety as a core value?
• Does management and supervision provide strong leadership?
• Has management formalized a safety culture emphasis and approach?
• Does management work to ensure employees maintain a sense of vulnerability?
• Are individuals empowered to successfully fulfill their safety responsibilities?
• Does management ensure open and effective communication exists?
• Does management support and foster mutual trust?
• Does management establish and enforce high standards of performance?
• Does management defer to expertise?
• Has management established a questioning / learning environment?
• Does management require timely responses provided to safety issues and concerns?
• Does management provide continuous monitoring of performance?