Excavation - 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?

Prevent Normalization of Deviation

Normalization of deviation is defined as…..

The gradual process through which unacceptable practice or standards become acceptable. As the deviant behaviour is repeated without catastrophic results, it becomes the social norm for the organization.

– Sociologist Dr. Diane Vaughan (The Challenger Launch Decision, 1996)

A gradual erosion of standards of performance as a result of increased tolerance of non-conformance.

– CCPS Glossary (iPhone Application)

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

• If a deviation is absolutely necessary, are there defined steps that must 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 your the expectations clear that no one individual alone is permitted to determine whether a deviation is permissible?
• Do you allow operations outside established limits without a detailed risk assessment?
• Are wilful, 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?

Evaluate Your Program

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

• Are all employees empowered to stop work for any situation deemed unsafe?
• Are excavated areas reviewed for underground hazards such as electrical cables, pipelines, etc.?
• Are marked-up drawings of excavated areas approved by a qualified Supervisor available in location?
• Do you allow initial ground penetration without an approved drawing, showing existing underground utilities?
• Is it company practice to perform a joint site visit by Operations, Maintenance and Utilities personnel to identify and to mark underground utilities?
• Is it company practice to attach excavation plans to permits?
• Do you allow work to proceed without completing excavation checklist?
• If the excavation is to be entered, is a Confined Space Entry permit in place?
• Is all equipment and materiel located safe distance away from the excavation site?
• If the excavation is to be entered, is proper access/egress available?

Do you review the following items?

• Written excavation procedure?
• Excavation certificates/permits?
• Excavation checklists?
• Roles and responsibilities of persons involved in excavation activities?
• Training and competency provided to persons involved in excavation activities?
• Hazard assessments performed before excavation activities are conducted?
• Job observations performed on excavation activities?

Have you audited your Excavation permits and discussed the results of the audits? Was there evidence that:

• Permits were not completely filled out?
• Permits were not signed?
• Permits showed evidence that the standby watchman failed to check the site after job completion?
• The permit writer was not trained?
• The standby watchman was not trained?
• Permit conditions were not communicated within the subject work team?
• Work was not coordinated between work groups (permit writing group vs. group(s) that perform the work)?
• Work extended beyond the authorized period of time?
• The work area covered by the permit was too large?
• Certain technical provisions of the permit were not followed?
• Gas detection was not performed properly or continuously?

Have you evaluated your Excavation audit program?

• To ensure the quality of the audit process (i.e., protocols, sampling strategies, etc.)?
• To ensure the competency levels of the auditors?
• Does your Excavation procedure reflect the desired intent and is this intent adequately detailed in procedural instruction?
  
  • Is the “goal” of your program to complete the permit or to use the permit as a tool to facilitate the execution of safe work?
• Does the execution of the procedure yield the intended results? Are you evaluating your program for:
  
  • Procedural Compliance – are actions and tasks in compliance with procedural requirements? (Paper Control), and
  • Program Health – is your system providing the intended results? (Actual Execution)
• Do you know of any site or company incidents related to excavation?
• Have you discussed the results and causes within your organization?
• Do you know of any site or company near misses related to excavation?
• Have you discussed the results and causes within your organization?

Continually Improve Your Program

Are you considering improvements to prevent future incidents?  Here are some ideas you may want to consider:

• How frequently do you review CSB, Process Safety Beacon and other relevant incident communication having learning potential with all members of the organization?
• Do you track specific excavation-related metrics that can be used to determine program effectiveness and improve performance?
• Have you benchmarked your program against other programs in your industry?
• How often do your senior managers visit the field to watch excavation in action?
• Do you have a requirement to periodically update your program?
• Do your workers (those closest to the work), have an easy method to suggest improvements to your program?

Organizational Culture

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

• Does management and supervision reinforce desired behaviors to ensure they become integrated into the group’s values?
• Are high standards of excavation performance 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 the 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?