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North American Regulators Working Group on Safety Culture: Safety Culture Indicators Research Project Continued Learning (2018)

Prepared by

North American Regulators Working Group on Safety Culture (NARWGSC)

25 June 2018

Table of Contents

  1. Background
  2. International Regulators Forum Study using the NARWGSC Indicators
  3. What’s next for the NARWGSC Indicators?
  4. Contact

Background

Regulation of high hazard industries has traditionally relied upon oversight that is heavily focused on compliance to prescriptive regulations or standards. Compliance monitoring represents a snapshot in time and although it serves as a necessary defense against harm, it is a brief interaction that is limited in scope. In recent years, regulators around the world have begun moving to a more systemic approach to oversight.

The introduction of management system requirements and the utilization of data trending to determine risk and subsequent oversight have characterized the shift from traditional interventions to more holistic safety system influence and improvement. Most recently, this approach has been strengthened with a focus on safety culture advancement. This effort reflects a commitment to regulatory excellence and an understanding that culture – the intersection of human and organizational factors – is at the root of a company’s safety and environmental performance. More and more, best-in-class regulators are moving into this space in order to improve outcomes in the public interest.

The North American Regulators Working Group on Safety Culture (NARWGSC) was created to explore this concept. Early on, the group recognized the need for a tool that could be used to gather and share valuable insights about how culture influences safety and environmental protection outcomes. The Safety Culture Indicators Research Project was initiated to meet this need; its objective was to identify a suite of indicators that could be used to facilitate greater awareness and understanding of cultural threats and defenses in the oil and gas industry.

The project engaged operational staff at each of the NARWGSC agencies in order to identify the nature and scope of safety culture signals observed during interactions with regulated entities. The tool was developed for potential use by regulators; however, the NARWGSC members committed to share the results with stakeholders and other interested parties in an effort to support a culture of learning across the sector.

The resulting indicators do not measure Safety Culture directly; instead they point to organizational signals of strength or weakness that may provide an indication of the relative health of the culture.

The Indicators Are...

  • Part of a broader safety culture toolkit that may help others to understand and identify cultural strengths and weaknesses
  • A tool that could be used to identify data points for collection and analysis by culture experts
  • A detailed and more concrete description of the safety culture dimensions found in the Statement on Safety Culture (June 2014)

They are not...

  • An audit protocol
  • A prescriptive list of regulatory requirements
  • A compliance or inspection checklist
  • A tool used for regulatory enforcement
  • Required to be adopted by industry

For more information about this research and to see the entire suite of indicators, please see the study report.

International Regulators Forum Study using the NARWGSC Indicators

The International Regulators Forum (IRF), a group of global safety regulators from the offshore oil and gas industry, also shares interest in advancing safety culture. In late 2015, the IRF established a working group to explore the regulatory use of safety culture indicators. The group proposed that a study be conducted, which would leverage the existing suite of indicators that were developed by the NARWGSC. The overarching goal was to identify key cultural elements/indicators that impact process safety performance and contribute to major hazard incidents.

During the study, the NARWGSC’s indicators were evaluated to determine their validity and usability. Additionally, the study identified a smaller subset of indicators (using the validity and usability ratings) which might be piloted in the future by self-selecting IRF member agencies.

The study results indicate that the suite of indicators received positive ratings regarding face validity (provided by association evaluation) and positive ratings of construct validity (provided by subject matter expert evaluation). It was also determined that in order to effectively collect evidence associated with these indicators, additional assessment methodologies would need to be developed and tested.

A recent workshop at the IRF/Safety 30 Conference introduced the research to stakeholders and explored challenges and successes associated with safety culture assessment. Panelists agreed that there is no “one size fits all” when it comes to evaluating culture. Many different approaches from structured to less formal initiatives may provide meaningful intelligence (signals) about an organization’s culture. Those undertaking this work need to be prepared to learn during the process and adjust course as required. Flexibility and adaptability are critical to safety culture efforts.

The panelists also agreed that conversation and dialogue provide the richest cultural intelligence. Any tool that may be used initially to collect signals (e.g. suite of safety culture indicators, perception survey, etc.) should be used to inform and guide humble inquiry about why specific actions are taken during subsequent conversations with leaders and workers. The goal of these discussions should be to better understand the underlying values, attitudes, pressures, etc. that influence or drive these behaviours and decisions.

During the conference workshop, it was noted that users of any assessment tool (such as the suite of indicators) should make every effort to prevent it from being turned into a checklist or compliance-based instrument. The tool should be used to identify topics for exploration through inquiry/dialogue. If used as a checklist, it will likely impair the conditions required to support organic and sustainable culture development as regulated entities may try to comply with the prescriptive indicators rather than focusing their efforts on understanding their unique cultural threats and defenses.

For more details about the study and to see the results of the safety culture indicators’ evaluation, please see the study report.

What’s next for the NARWGSC Indicators?

The NARWGSC indicators research study is complete and the recent IRF efforts have provided valuable insights about the potential use of the indicators by stakeholders (e.g. regulators, companies, industry associations, safety representatives, etc.).

A number of NARWGSC members intend to pilot the collection of safety culture signals by using some of the indicators (tailored to their unique jurisdictional context). As noted earlier, flexibility is critical to the successful use of the tool and we anticipate that various groups may choose to use it in different ways to gather the most meaningful data.

The NARWGSC encourages and invites those who use the indicators to share lessons learned during the process in support of continual learning and improvement. Comments may be shared using the contact information below.

Contact

 

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