Several organizations and individuals have claimed recently that there are too many HES rules and instructions, Ståle Kyllingstad, IKM owner, is one of those. Is this true?
There is no doubt that HES sometimes is the excuse to try to enforce some proposals or actions that actually have other reasons, which may not be so easy to defend. Maybe it’s only “nice to have”, but if it can be stated to have HES implications, then a lot less people will challenge the issue. We should always look critically at such cases.
This also relates to use of for instance “Safe Job Analysis” (SJA) or similar, one of Kyllingstad’s points. It is sometimes easier to state that SJA shall be made, even though we know that the work has been done many times before. But if a SJA is not specified, we may have to defend the decision, and could be blamed if something after all should occur. But if requiring the SJA implies that the SJA will be copied from the previous instance with little or no thought process, it would often be better not to require the SJA. It would probably be better to involve supervisors in actively following up the work task itself on the facility.
Does the same also apply to major hazard risk? We believe those who have voiced these statements may not be fully aware of the distinction between occupational accidents (or working environment) and major accidents, and would thus claim that it holds for all aspects of HES. (And by the way, it has been shown that SJAs often have primary focus on occupational accidents, and far too little on major hazard risk!)
The focus by PSA on barrier management the last couple of years suggests that PSA does not think that there is “too much HES”.
But are we convinced that attention to a series of barrier functions and elements is the right way to go in the current financial climate? Maybe prevention of near-misses is much more important? This is an interesting topic which we hope to research some time in the future.