New book on pipeline safety has OHS lessons for all

Hopkins Hayes Book CoverAny new book by Andrew Hopkins is a cause for excitement.  The latest book co-written with Associate Professor Jan Hayes* focusses, primarily, on two pipeline disasters in the United States but has sufficient information and thoughts for those OHS professionals outside this sector and jurisdiction.

Nightmare Pipeline Failures: Fantasy planning, black swans and integrity management” is a typically slim volume written in Plain English that benefits from the broad knowledge of its authors.  Readers of Hopkins’ early books will get all of the cross-references.  In some ways, this book can be seen as almost a case-study of Hopkins’ work on mindfulness and high-reliability organisation, as the themes of management perspectives, activity and decision-making occur repeatedly in this book.

The authors question the role of urban planning as a contributory factor to pipeline ruptures by pointing out that

“Urban planners would not dream of allowing residential development under high-voltage power lines, but they seem willing to tolerate encroachment on high-pressure gas pipeline corridors.” (page 2)

This statement could equally apply to other service corridors such as rail corridors and to other services such as optic-fibre communications.

James Reason’s cheese is illustrated in the introduction but the explanation of this theory is a little thin, probably assuming that most readers will already be familiar with this.  However comprehension is not helped when the illustration, like many used, only includes two words – Hazards and Losses. The emphasis should be on the slices of cheese, the Defences.  Illustrating the process arrowing through the Swiss cheese holes implies that the Defences are static.  Any use of Reason’s Swiss cheese theory should be accompanied by an example of when the Defences work, or when the cheese holes are not aligned.

The authors emphasise that

“Understanding the human and organisational causes is vital for accident prevention” (page 6)

and it is this perspective that makes a book about pipelines relevant to those outside that industry sector.

The book also discusses the differences between worker safety, public safety and process safety and the role of compliance culture.  The authors write that

“In so far as our two pipeline companies were concerned about public safety at all, they seemed to believe that all that was required was that they strictly comply with the pipeline safety regulation and all would be well.  We demonstrate … that this is a fallacy.” (pages 9-10)

As occupational health and safety (OHS) laws grow to include obligations to non-workers and non-traditional safety issues, this type of discussion is important.  Companies and their personnel need to be inclusive of a range of voices and perspectives in order to gain the best advice and to consider the most options.

This leads onto the discussion of “fantasy planning” in the book.  This sector resonated with me by reminding me of many of the Risk Registers I have seen.  The authors describe some of the control plans as

“… wildly optimistic and full of unjustified assumptions and inaccurate data. Their function is symbolic rather than instrumental, that is, they serve as statements that the hazard is under control, rather than as real instruments of control.” (page 10)

“Fantasy Cheese” perhaps.

Such plans are there to indicate a process exists, perhaps as part of a tender obligation, rather than control a hazard.  Tightening up such plans may occur from targeting the risks and hazards in specific sectors or processes first, and with a smaller assessment team, and then collating and comparing these plans and registers with those from other organisational sectors.  This multi-stage process would require time but would better fit the duties of OHS/WHS due diligence.

Int he discussion of “fantasy planning”, the authors address the trendy “black swan” metaphor.  I have heard this mentioned in many OHS forums over the last few years.  It seems very attractive to some safety and risk professionals but it never seemed to have sufficient substance.  Although Black Swan is mentioned in the book’s title, it only receives around three pages of discussion and this is disappointing.  An analysis of this metaphor deserves attention in its own book or monograph.

Although scant attention is granted, the authors are scathing of the analogy.  They point out that Black Swans were only unforeseeable to European explorers.  To indigenous Australians, they were simple part of life.  They say that the analogy

“… seems to be nothing more than a contemporary version of the idea that major accidents are inevitable.  There is a long tradition of this kind of pessimism, another well-known example being the theory of normal accidents, a theory which, on analysis, turns out to be vacuous.” (page 10)

In Chapter 7, the Hayes & Hopkins discuss the work of Nassim Nicholas Taleb on Black Swan and extract some general tips from Taleb’s works.  They write that it is important

“…to look beyond models and seek a diversity of views about what could go wrong and what the most vulnerable parts of the system are.” (page 90)

They reiterate the similarities with those researching high reliability organisation, such as, amongst others:

  • learning from small failures,
  • being sensitive to operations,
  • committing to resilience, valuing reliability over efficiency.

It is in this context that this book about pipeline disasters establishes its relevance beyond the principle topic.

Profit v Safety

Hayes & Hopkins devote a short chapter to senior management priorities, particularly in the United States regulatory context, but the book’s introduction summarises the chapter well:

“[the] situation at PG&E was particularly detrimental to safety because, as a regulated public utility, it could not increase profit be increasing charges to customers.  The only way profit could be increased was to cut costs, in particular, costs in relation to maintenance and the assurance of technical integrity.  This is likely to be an issue for many other regulated public utilities around the world.” (page 11)

This is also the case faced by many government authorities outside the utilities sector and indicates a lack of understanding of or commitment to safety in the first stages of projects and processes.

Professionals in the pipeline sector will get the most benefit from this book but there is sufficient in the general safety and decision-making processes of the public utilities and disaster under investigation for the non-pipeline OHS professional and executive.

The book benefits from a non-US perspective on US incidents and the authors emphasise that the only reason these specific incidents are used is that they provide the most amount of information for analysis.  More significant incidents have occurred in Belgium, Taiwan and Nigeria.

It is also a very good blend of the writings, perspectives and experience of both authors.

Kevin Jones

* Jan Hayes wrote a working paper on one of the pipeline ruptures as part of the Regulatory Institutions Network and is available HERE

Note: Wolters Kluwer CCH provide SafetyAtWorkBlog with a review copy of the book.

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