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Administrative Controls vs. Hardware Engineering Controls
- Some of the basic process safety issues involved in the choice are:
- Increased automation may simplify the operator’s role, but may increase the complexity and frequency of maintenance
- Operators may rely on alarms to warn of upset potentials and relax their tracking of operations if a system is overly automated
- Reliance on the operator to take certain actions in emergency situations may not take completely into account fatigue, time to respond, background noise levels obscuring alarms, inadequate numbers or types of communications channels and the like
- The company should assure that hardware/procedure tradeoffs made by designers and hazard reviewers are based on risk analysis results, and that these decisions are predicated upon past company practice. To encourage consistency and equivalency of risk levels, the management system should encourage communication within the organization of hardware/procedure design practices.
- Whenever risk mitigation measures are being recommended or selected, company practice on administrative vs. hardware controls should be considered. This will require a management system in which staff involved in risk control measure selection are familiar with past practice, and in which selections are reviewed by the level of management that approves risk-mitigation measure implementation.
- The documentation of risk-mitigation measures selection should record the choices made between administrative and hardware controls. Such documentation will help assure that human factors were considered in selecting mitigating measures, and that there is an audit trail for later verification that human factors were considered.
- The process safety management system should assure the availability of human factors knowledge. In some firms, human factors specialists are made available to process safety review teams to bring this expertise to the review. In other cases, human factors training is given to staff involved in process safety review work so they will better understand the issues. Either approach requires the commitment of appropriate resources.
- Reference: CCPS(1989) Guidelines for Technical Management of Chemical Process Safety
- Management/Human Factors