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PULP & PAPER MAGAZINE: Proper policies and procedures help manage, enforce hot work programs


   

The last in a series of articles on safely performing hot work in mills highlights useful tips to help manage and enforce a mill's hot work program

June 2007
By David Johnson, P.E.

In the pulp and paper industry, many business disruptions are the result of fire. Often, the result is a multi-million dollar hole in a company's bottom line. In the wake of such an event, the property insurer typically provides reimbursement for the repair or replacement of damaged buildings and equipment, as well as for profits lost during the period of disruption. However, losses of market share, critical business, skilled labor and even damage to corporate reputation are consequences a company may face on its own.

For this reason, management plays a critical role in managing hot work at pulp and paper mills. Managers who are as committed to preventing property loss as they are to widening profit margins often: 1) make themselves aware of all the inherent risks in their facility (hot work among the many); 2) develop and implement effective policies and procedures to address those risks; and 3) employ strict management and enforcement of those policies and procedures. By doing so, they control ignition sources that could otherwise lead to hot work related fires and, in turn, the immediate cease of business.

This article is the third and last in a series of articles on safely performing hot work in mills. Parts 1 and 2 focused on loss prevention measures pulp and paper facilities can take before, during and after conducting hot work activities to prevent costly property damage and business downtime (see Pulp & Paper, December 2006, p. 44, and March 2007, p. 33). Here, Part 3 highlights useful tips to help manage and enforce a mill's hot work program.

Figure 1 - As part of a mill's in-house hot work auditing process, verify that all information in the paperwork, like a hot work permit, is accurate.

Walking the Talk

If preventing loss is a top-of-mind priority for a manager or supervisor, that thinking has a good chance of trickling down to others. Conversely, if it is not a priority, a very different and perhaps very costly message is sent.

For example, if a manager walks by a contracted welder who is conducting improper hot work on a multi-million dollar paper machine and does nothing, what message is sent? Knowing that the welder likely has little, if any, stake in the mill's production or profits to begin with, how much will he or she have now? More importantly, how will what the manager does or does not do resonate with actual mill employees? Each time a manager compromises the value of the company's hot work program, the risk of fire is elevated. Mitigating that risk potential, then, is a great way to help ensure a mill's business avoids interruption and continues thriving.

The following steps can be used to measure the effectiveness of a mill's existing hot work loss prevention efforts. First, identify the activities you're already doing well as best practices. Then ask yourself: Are they being practiced throughout the organization? Are they applied to the same degree for every shift? What areas could you improve upon? And keep in mind that anyone involved in managing and regulating hot work practices in the mill has really only two choices - facilitate the risk, or nullify it.

Step 1

Create and enforce an in-house hot work policy and training program. Like any policy, a hot work program is most effective if it is properly maintained, continuously reviewed and updated as needed. Establishing a formal policy statement, along with procedures for how to operate and manage hot work in the mill, can go a long way toward preventing hot work related fires. Above all, however, personnel involved with overseeing this process should understand all the construction and occupancy hazards within the facility.

When developing a hot work policy, know that it should:

  • Be clearly communicated to all employees, temporary employees and contractors, especially when changes or modifications are made
  • Be endorsed by the highest levels of management
  • Include specific assignments of responsibility and accountability to those who operate and maintain the process
  • Indicate the consequences for failing to observe the rules involved
  • Clearly identify areas where unique hazards may be present, and have precautions outlined for hot work related activities that take place nearby
  • Be posted conspicuously enough to encourage safe hot work activities throughout the mill

When developing a hot work training program, a mill should:

  • Include basic education, such as the definition of hot work, the fire hazard hot work represents and how unsupervised hot work can cause severe property loss. Also include:
    - The mill's particular construction and occupancy hazards
    - Basic fire prevention measures and precautions
    - Emergency communication and response procedures
    - Required maintenance of hot work equipment
  • Indicate the need to avoid hot work whenever possible by using alternative methods
  • Include ways to prevent hot work related loss, and emphasize that hot work policies and procedures - in addition to responsibilities, accountabilities and consequences - should be adopted by senior management
  • Include all relevant employees and contractors when introducing the procedures or any subsequent procedural changes

Step 2

Help contractors embrace property loss prevention. How well you prepare a contractor on hot work practices and procedures at the mill can directly affect the level of risk represented by their work. Because contractors are just as likely to cause a hot work related fire as employees, it's important to hold them accountable in accordance with the mill's hot work policy.

Once selected, the hot work contractor should be formally indoctrinated with the mill's hot work program (including policies and procedures) prior to starting a job. In fact, the contract itself should expressly require the contractor's strict adherence to this program. Any breach of this agreement can certainly decrease the contractor's chances of working at the mill in the future.

Step 3

Develop a formal in-house auditing process. Having an in-house auditing process to periodically review human-driven risk can help identify areas where changes or improvements are needed.

To maintain objectivity, it is strongly recommended that mills use in-house personnel who are not normally involved with this supervisory process but who, at the same time, are educated in the requirements of proper hot work supervision. Indeed, even the best hot work management processes can develop weaknesses when the same people are always tasked with supervising the daily activities of this hazardous work. The sidebar describes the types of audits in a formal process.

In-house Auditing Reduces Human-Driven Risk

For a formal in-house hot work auditing process, the audit should come in two phases: spot (while hot work is in progress) and permit (reviewing paperwork).

Spot Auditing. This involves auditing hot work operations while they are in progress. You can do this before, during and/or after hot work is conducted to ensure all proper precautions and procedures are being followed as indicated in the policy.

This method is the quickest way to ascertain what is really going on during hot work operations. Ask yourself: Is the hot work being conducted in a pre-determined "safe" area? Is fire protection equipment ready, available and operational? Is a fire watch actually watching the hot work job at hand? Has all combustible material been removed from the area?

Permit Auditing. For every hot work project, the fire safety supervisor or other qualified employee completes a hot work permit. Though intended as a system of checks and balances - a way to verify applicable precautions have been taken before hot work begins - permits are documented proof that employees understand, and will abide by, the policy.

Some warning signals to look for when reviewing/auditing hot work permits:

  • The precautions checked fail to match the hazards present in the area the work was done.
  • The person completing the permit does so quickly and carelessly, simply by drawing a line down the "yes" column.
  • Some facilities have been known to pre-fill dozens of hot work permits in advance, just to save time. Once the hot work permit is posted, it's good to consider whether the information is valid or not.

The truth is, mills won't know if a problem exists unless the paperwork is audited. Once the audit is performed, certain trends will emerge that can help management understand where a particular breakdown may be taking place. For example, perhaps the audit would show that an employee consistently makes the same error in judgment, or there are shortcuts during a particular shift, placing operations at risk. This evidence can be used to make enhancements such as the following to your company's hot work program:

  • Retraining an employee/employees
  • Revising or updating your training program
  • Modifying procedures that may not be clearly written
  • Disciplining an employee or employees for shoddy performance or shortcutting

Risk vs Reward

A company that manages its risks properly and communicates the effectiveness of such efforts to its many stakeholders will find it not only can gain a competitive advantage, but also can boost financial performance, enhance shareholder confidence and help protect the value its business creates.

Property threats inherent in pulp and paper mills, such as hot work, should compel companies to elevate risk management to a priority despite the time, personnel and budget cost it requires. With what's at stake, best practices in maintaining business continuity should be a burning desire every employee shares - from top to bottom.

Dave Johnson, P.E., is operations vice president and engineering manager for forest products operations at FM Global in Dallas, Texas.

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