3

Accountability

3.1. Overview

3.7.7. Introduction and Definition

Accountability is the obligation to answer for one's actions that are related to an
organization's goals and objectives. It is an essential part of an effective manage-
ment system. Because accountability is associated with positive rewards for good
performance, as well as penalties for poor performance, it gives teeth to the
responsibilities assigned through the management system. Documentation of
accountability should be maintained throughout the life cycle of the process
through the use of policies and procedures which designate specific individual
responsibilities. The accountability for the assigned responsibilities should be
stated in a clear and concise manner.

3.7.2. Goals and Benefits

The principal goal of accountability is to ensure the development of a process
safety management (PSM) policy and program which will endure throughout the
life cycle of a process. Supporting this principal goal are more specific goals to:
• establish a corporate culture in support of the PSM effort;
• provide perspective on the scope of the PSM program; and
• demonstrate management support.
Well-documented accountabilities must be established for each management
function; planning, organizing, implementing, and controlling (see Table 1-1).
The benefit to be obtained from documented accountabilities is to ensure that the
PSM system accomplishes each of these management functions.
3.2. Description of Documentation

In order to effectively manage PSM, there should be a documented program

outlining the overall objectives and describing how they will be achieved. Specific
objectives which should be considered for documentation include:
continuity of operations;
continuity of systems;
continuity of organization;
control of exceptions and variances;
management accessibility;
employee involvement;
communications; and
reduction in incidents, injuries, and property losses.
Specific instructions for how PSM is to be implemented and how these goals
are to be achieved are typically described in a system of documents beginning with
a general statement of PSM values and policies and concluding with detailed
procedures. These increasingly detailed documentation requirements are dis-
cussed further in this section.

3.2.7. Statement of Values and Policies

The Chief Executive Officer (CEO) of an organization is typically the sponsor or
advocate of process safety, and leads by example. In this role, the CEO usually
issues a statement articulating the organization's values and describing in simple
but direct terms what the organization expects to achieve through PSM. The
statement should be signed and dated, and should be renewed on a periodic basis
and upon replacement of the CEO. This statement should be communicated to
all employees. Two examples are included as Figures 3-1 and 3-2.
Note that such statements can also be issued at other levels of the organization,
but require the endorsement and commitment of top management at that level.

3.2.2. More Detailed Documentation

Policy statements describe required organizational behavior in the broadest sense
and do not specify how to act in particular situations. To achieve an organization's
PSM goals, more detailed documentation must be provided. Dowell describes a
pyramid model where criteria and guidelines provide interpretation of policy
statements and serve, in turn, as the basis for more detziledstandards andprocedures.
Typical documents promulgated at the corporate level may include:
• corporate safety guidelines;
• corporate engineering standards;
 Diamond Shamrock

COMMITMENT TO SAFETY

It is the policy of Diamond Shamrock to:

• Maintain a safe, clean workplace.
• Provide training in safe job performance.
• Ensure that unsafe conditions are recognized, reported, and
promptly corrected.
• Comply with applicable safety laws and regulations.
Diamond Shamrock is committed to the safety and well being of our
employees and customers. Protecting human life from harm and property
from loss is a key responsibility of every employee. We must always THINK
SAFETY before and during every task.

-7~P
/ /Z?Z^-—-i
Roger R. Hemminghaus
Chairman and
Chief Executive Officer

Diamond Shamrock P.O. Box 696000, San Antonio, Texas. 78269-6000. Phone: 210 641-6800

FIGURE 3-1. Process Safety Management Policy—Example 1

• process or product specific standards;

• plant design procedures;
• equipment integrity standards;
• emergency response guidelines; and
• PSM audit guidelines.
 The DuPont Commitment
Safety, Health and the Environment
We affirm to all our stakeholders, including our employees, customers, shareholders and the public, that we will conduct our business
with respect and care for the environment. We will implement those strategies that build successful businesses and achieve the greatest
benefit for all our stakeholders without compromising the ability of future generations to meet their needs.
We will continuously improve our practices in light of advances in technology and new understandings in safety, health and environ-
mental science. We will make consistent, measurable progress in implementing this Commitment throughout our worldwide opera-
tions. DuPont supports the chemical industry's Responsible Care8 and the oil industry's Strategies for Today's Environmental
Partnership as key programs to achieve this Commitment.

Highest Standards of Performance, Business Excellence
We will adhere to the highest standards for the safe operation
of facilities and the protection of our environment, our
employees, our customers and the people of the communities
in which we do business.
We will strengthen our businesses by making safety, health
and environmental issues an integral part of all business
activities and by continuously striving to align our businesses
with public expectations.
Goal of Zero Injuries, Illnesses and Incidents
We believe that all injuries and occupational illnesses, as well
as safety and environmental incidents, are preventable, and
our goal for all of them is zero. We will promote off-the-job
safety for our employees.
Continuously Improving Processes, Practices and
Products
We will extract, make, use, handle, package, transport and
dispose of our materials safely and in an environmentally
responsible manner.
We will continuously analyze and improve our practices,
processes and products to reduce theirriskand impact
throughout the product life cycle. We will develop new
products and processes that have increasing margins of safety
for both human health and the environment.
We will work with our suppliers, carriers, distributors and
customers to achieve similar product stewardship, and we will
provide information and assistance to support their efforts to
do so.
We will assess the environmental impact of each facility we
propose to construct and will design, build, operate and
maintain all our facilities and transportation equipment so
they are safe and acceptable to local communities and protect
the environment.
We will be prepared for emergencies and will provide
leadership to assist our local communities to improve their
emergency preparedness.
Goal of Zero Waste and Emissions
We will drive toward zero waste generation at the source.
Materials will be reused and recycled to minimize the need
for treatment or disposal and to conserve resources. Where
waste is generated, it will be handled and disposed of safely
and responsibly.
We will drive toward zero emissions, giving priority to those
that may present the greatest potentialriskto health or the
environment.
Where past practices have created conditions that require
correction, we will responsibly correct them.
Conservation of Energy and Natural Resources, Habitat
Enhancement
We will excel in the efficient use of coal, oil, natural gas,
water, minerals and other natural resources.
We will manage our land to enhance habitats for wildlife.
• Replaces November 1971 Policy r.~. .__ _ „ _ _ ,
July 1994 FIGURE 3-2. Process Safety Management Policy— Example 2
Open and Public Discussion, Influence on Public Policy
We will promote open discussion with our stakeholders about
the materials we make, use and transport and the impacts of
our activities on their safety, health and environments.
We will build alliances with governments, policy makers,
businesses and advocacy groups to develop sound policies,
laws, regulations and practices that improve safety, health and
the environment.
Management and Employee Commitment, Accountability
The Board of Directors, including the Chief Executive
Officer, will be informed about pertinent safety, health and
environmental issues and will ensure that policies are in place
and actions taken to achieve this Commitment.
Compliance with this Commitment and applicable laws is the
responsibility of every employee and contractor acting on our
behalf and a condition of their employment or contract.
Management in each business is responsible to educate, train
and motivate employees to understand and comply with this
Commitment and applicable laws.
We will deploy our resources, including research, develop-
ment and capital, to meet this Commitment and will do so in a
manner that strengthens our businesses.
We will measure and regularly report to the public our global
progress in meeting this Commitment.
« 1 - 1 - 1
 Many facilities develop more detailed procedures, conforming to corporate
policy and guidelines but addressing the requirements of the particular location.
Some examples of such facility documents are listed below.
Safety Manuals—Safety manuals should describe practices and procedures to
be followed in operations. These may range from procedures for the safe perform-
ance of potentially hazardous operations to practices for personal protective
clothing and equipment.

Job Descriptions—The purpose of job descriptions is to provide direction for

the employee, assist in training, and provide a paper trail for auditing. The job
description should include the responsibilities for specific process safety activities,
and should be critiqued to ensure consistency and clarity. Job descriptions may
include:
hazard communications;
hazards of particular tasks;
specific operating procedures;
emergency procedures;
start-up and shutdown procedures; and
safe work practices.

Employee Involvement—Facility PSM documentation may include a state-

ment concerning employee involvement. This statement may include the follow-
ing considerations:
• overall policy;
• employee communication and awareness;
• employee responsibility; and
• employee involvement in accident investigations, process hazard analyses,
and operating procedures preparation.

3.2.3. Responsibility and Accountability

The PSM program documentation should describe responsibilities in terms of
who, what, when, and how. Accountability for required actions should be
addressed throughout the program documentation. The documentation should
address:
• who, by job title, will be delegated responsibility and for which sections
of the overall program;
• what they wiU be responsible for (e.g., for approval or modification of
procedures, documentation, training or auditing. Different individuals
may be responsible for different functions);
• availability of the necessary resources;
• measurement of performance; and
 • the precise conditions for authorization of exceptions or variances to the
policy.
It is important that the criteria and responsibility for variance approval be
clearly documented. In many cases, this responsibility may be reserved to senior
management.

3.2.4. Measurement
Many organizations adopt targets for safety performance using measurable in-
dexes. Typically, these include safety and loss prevention statistics and PSM
activities, such as:
• reduction of hazardous inventories;
• lost-time accident rate;
• reportable releases; and
• property losses.
The measurements to be used and corresponding goals should be clearly
stated in the PSM program documentation.

3.3. Records Management

3.3.1. Policies and Practices

To ensure continued effectiveness of PSM, the accountabilities and responsibilities
for PSM program documentation should be documented initially and revised as
organizations, processes, and technology change.
Specific guidance for more detailed elements of PSM documentation (e.g.,
Operating Procedures) will be provided in subsequent chapters. It is equally
important, however, that responsibilities for maintaining the broader policy and
interpretative documentation (e.g., policy statements or corporate PSM guide-
lines) also be clearly established.

3.3.2. Records Revision and Retention

It is imperative that PSM documentation remain current (e.g., procedures are
updated to reflect current requirements and out-dated information is purged from
the files). Thus, it is important that PSM documentation be managed in accor-
dance with the overall corporate records revision and retention policy. The policy
should specifically address each element of the PSM program, since different
elements may require different retention schedules. Accountability and responsi-
bility should be assigned for the maintenance of PSM records for each element.
For additional guidance, refer to Chapter 4, Records Management.

3.4. Auditing

To ensure continued effectiveness of accountability and responsibility for PSM as

organizations, processes, and technology change, the PSM documentation system
should be periodically audited. External and internal audits of individual account-
ability for each of the PSM elements will help ensure that the program objectives
are met and any identified deficiencies are corrected. The audit program should
address the following issues:
• Is there a documented program for establishing PSM responsibility and
accountabilities?
• Does a means exist for updating the program, as required?
• Is the program being followed, as described?
• Are the records from the program implementation being properly man-
aged?
For additional guidance, refer to Chapter 14, Auditing and CCPS Guidelines
for Auditing Process Safety Management Systems.

3.5. References

AIChE-CCPS, Guidelines for TechnicalManagement of Chemical Process Safety, 1989.

AIChE-CCPS, Plant Guidelines for Technical Management of Chemical Process Safety, 1991.
Dowell, A. M., Getting from Policy to Practices: The Pyramid Model (Or What Is This Standard
Really Trying to Do?), 1992 Process Plant Safety Symposium, February 1992.