Routinely reviewing the organization’s process safety systems to spur continuous improvement is one of four elements in the RBPS pillar of learning from experience. This chapter describes the meaning of management review, the attributes of a good management review system, and the steps an organization might take to implement management reviews. Section 22.2 describes the key principles and essential features of a management system for this element. Section 22.3 lists work activities that support these essential features and presents a range of approaches that might be appropriate for each work activity, depending on perceived risk, resources, and organizational culture. Sections 22.4 through 22.6 include (1) ideas to improve the effectiveness of management systems and specific programs that support this element, (2) metrics that could be used to monitor this element, and (3) issues that may be appropriate for management review.
What Is It?
Management review is the routine evaluation of whether management systems are performing as intended and producing the desired results as efficiently as possible. It is the ongoing “due diligence” review by management that fills the gap between day-to-day work activities and periodic formal audits. Management review is similar to a doctor giving a routine physical examination – even when no overt signs of illness are present, life-threatening conditions may be developing that are best addressed proactively. Management reviews have many of the characteristics of a 1st party audit as described in Chapter 21. They require a similar system for scheduling, staffing, and effectively evaluating all RBPS elements, and a system should be in place for implementing any resulting plans for improvement or corrective action and verifying their effectiveness.
Why Is It Important?
Effective performance is a critical aspect of any process safety program; however, a breakdown or inefficiency in a safety management system may not be immediately obvious. For example, if a facility’s training coordinator unexpectedly departed, required training activities might be disrupted. The existing trained workers would undoubtedly continue to operate the process, so there would be no outward appearance of a deficiency. An audit or incident might eventually reveal any incomplete or overdue training, but by then it could be too late. The management review process provides regular checkups on the health of process safety management systems in order to identify and correct any current or incipient deficiencies before they might be revealed by an audit or incident.
Where/When Is It Done?
Management reviews should be conducted wherever RBPS elements are implemented. The depth andfrequency of each management review should be governed by factors such as the current life cycle stage of the facility, the maturity or degree of implementation of the RBPS management system, the level of management performing the review, past experience (e.g., incident history, previous reviews, and audit results), and management’s view of the risk posed by the activities to be reviewed. Most of the management review effort will be focused on operating facilities. While they can be scheduled on an as-needed basis, management reviews of a particular RBPS element are typically conducted at a predetermined interval (e.g., frequencies ranging from monthly to annually are common), and they may be scheduled in conjunction with other regularly scheduled meetings, such as facility safety committee meetings.
Who Does It?
Strictly speaking, every level of management – from the process supervisor to the facility manager to the board of directors – should conduct periodic management reviews. Further discussion in this book focuses on program level reviews, which should be conducted by a manager who is one or two levels above the person responsible for the day-to-day execution of a specific RBPS element. This is usually the manager ultimately responsible for the proper functioning of the facility’s overall process safety management system; however, larger facilities may charter a Process Safety Committee to conduct the reviews under the leadership of a senior manager.
What Is the Anticipated Work Product?
The output of a management review is generally an internal memorandum summarizing the review, any deficiencies or inefficiencies noted, and recommendations for improvement or corrective action. The
recommendations should be given deadlines and then assigned to specific individuals. All outputs of the management review element are intended to facilitate the performance of other elements. In addition, the management reviews provide input that the audits element can use to focus its efforts.
How Is It Done?
Management reviews are conducted with the same underlying intent as an audit – to evaluate the effectiveness of the implementation of an entire RBPS element or a particular element task. However, because the objective of a management review is to spot current or incipient deficiencies, the reviews are more broadly focused and more frequent than audits, and they are typically conducted in a less formal manner.
Nevertheless, like an audit, a management review at least checks the implementation status of one or more RBPS elements against established requirements. The management review team meets with the individuals responsible for managing and executing the subject element to (1) present program documentation and implementation records, (2) offer direct observations of conditions and activities, and (3) answer questions about program activities.
The team attempts to answer such questions as:
- What is the quality of our program?
- Are these the results we want?
- Are we working on the right things?
Organizational changes, staff changes, new projects or standards, efficiency improvements, and any other anticipated challenges to the subject element are also discussed so that management can proactively address those issues. Recommendations for addressing any existing or anticipated performance gaps or inefficiencies are proposed, and responsibilities and schedules for addressing the recommendations are assigned. Typically, the same system used to track corrective actions from audit findings is used to track management review recommendations to their resolution. The meeting minutes and documentation of each recommendation’s resolution are maintained as required to meet programmatic needs. Management review results should be monitored over time, and more frequent reviews should be
scheduled if persistent problems are evident.