Thread Content
Problems with special operations 01: A large number of special operations. In many companies, it has been found that there is a huge number of special operations during daily production and business activities, to an almost astonishing extent. A company once conducted statistics on special operations; under normal circumstances, the number of such operations per month can exceed 20,000 times. Among them, hot work accounts for the largest proportion, with around 10,000 instances, which is about 50% of the total. The sheer volume of such special operations poses great difficulties for enterprises in regulating them in a standardized manner. It also presents significant challenges in effectively managing the risks associated with these operations and ensuring their safety. Companies further standardize the management of special operations, but due to the large number of such operations, it is inevitable that occasionally, in very rare cases, there may be deficiencies or lapses in management. Even if such incidents occur at a rate of 1‰ or 1\", they still pose a risk of leading to accidents. There are roughly three reasons why companies have a large number of special operational procedures: First, the production equipment is outdated, and inadequate preventive maintenance leads to frequent operational issues with these devices, forcing companies to carry out regular repairs and emergency fixes ； Secondly, due to immature technology, there are frequent changes in processes and equipment, which results in the production facilities being modified while they are still in use ； Third, some companies artificially expand the scope of special operations, for example considering all temporary power usage and the use of non-explosion-proof electrical equipment as hot work. 02 The phenomenon of approving safety work permits off-site is widespread. GB 30871—2022, the \"Safety Regulations for Special Operations in Hazardous Chemical Enterprises\", explicitly requires that the approver of special operations shall complete the approval process at the site where the operation takes place. Such a requirement is in place so that the approvers of special operations can go to the site of the operation to conduct a thorough inspection and verification of the implementation of various safety control measures before approving the safety work permit. The purpose is to ensure the implementation of safety measures, rather than merely signing and approving the safety work order as a formality. However, at present, many companies still have the practice of having reviewers and approvers for special operations at all levels conduct their tasks away from the actual site of the operations. In other words, these individuals never go to the site to check whether safety measures have been implemented; instead, they rely on information provided by those involved in the operations, and complete the review and approval of safety operation permits in offices or meeting rooms, which are not the sites where the operations take place. In some cases, such individuals even do not make any effort to understand the conditions at the site of the special operations, and simply sign off on the permits blindly. During a training session, through on-site surveys, the author found that approximately 50% of the participants admitted to having approved special work orders through non-on-site audits in the past. Off-site approval of special work permits very likely leads to unregulated operations, as various safety control measures required at the site of such operations fail to be implemented. There are cases of approving safety work permits outside of the actual work site, and there are mainly two reasons for this: first, insufficient attention is paid to the safety of special operations; there is no proper understanding of the importance of reviewing and approving such operations, with people thinking that it simply involves signing on a safety work permit ； Secondly, enterprises have a large number of special operations, and the relevant personnel do not have time to visit all the operation sites for inspection and approval. As a result, they opt to inspect on-site those operations deemed to have higher inherent risks in order to confirm the implementation of safety measures, while opting for non-on-site inspection and approval methods for other operations. The chief engineer of a subsidiary company once said frankly that one morning he approved over 40 special operations, and he simply did not have the time nor was it possible for him to go to all the sites to conduct inspections and verifications. 03 Handling special work orders just for the sake of filling them out: During numerous safety inspections of enterprises, it was observed that if inspections were conducted after 10 a.m. or in the afternoon, the work order forms at the sites where special work was being carried out were usually completed perfectly, with no obvious issues detected. However, if inspections are conducted between 8 and 9 a.m., which is precisely the time when companies handle approval procedures for special operations, numerous problems within these companies can often be identified. For example: the section for the person in charge of the safety work order and the comments from the relevant unit have been signed by the appropriate persons, but the time field at the end remains blank without any entry ； In the special operation tickets of some enterprises, the timestamps and signatures of the reviewers and approvers at various levels are all written by the same person. These problems exist because enterprises merely aim to fill out a “perfect” work order for inspection purposes. Since both the hot work permit and the confined space work permit require that the time for sampling combustible or toxic gases must not exceed 30 minutes from the start of the work, in order to prevent such issues, the relevant reviewers and approvers simply sign the permits without specifying the times; these times are then filled in by personnel such as supervisors to ensure that there are no problems with the timing indicated on the permits. But in practice, the time interval often exceeds the required 30 minutes, which creates a risk of accidents. 04 Special operations involve complex procedures. In some companies, the management of special operations is quite strict, and the associated procedures are complex. When applying for special approvals, numerous records need to be filled out and processed, which results in a lengthy approval process and imposes an excessive workload on the workers involved. More importantly, overly complicated special approval procedures can render the approval process for special operations a mere formality. This not only fails to effectively manage the risks associated with such operations, but may even have the opposite effect by increasing those risks. It was found that a certain company, when carrying out work in a confined space within a pyrolysis furnace, prepared a total of 15 relevant documents, including a confined space safety work permit, as well as documents such as JSA analyses, safety briefings, and calculations regarding the ventilation volume in the confined space. It seems that establishing these records is a scientific approach, aimed at better managing the risks associated with work in confined spaces. But in practice, the expert team found that while the workers were busy preparing or filling out these 15 records, they had no time to carefully read what was contained in them; they simply filled them out mechanically, relying on memory. This meant that these records failed to serve their intended purpose, and even the confined space work permits, which should have been handled carefully, ended up being filled out in a perfunctory manner. 05 Excessively strict requirements for special operations: Inspections have revealed that in many cities and enterprises, in an effort to better manage the risks associated with special operations, more stringent requirements have been imposed, sometimes even excessively strict ones. This is mainly reflected in the following: First, there is upgraded management for various special operations. Apart from hot work, requirements for enhanced management have also been set forth for other special operations during holidays, weekends, nights, and special circumstances ； Secondly, for special operations with high inherent risks, such as high-risk hot work and work in confined spaces, approval from the company’s top management is required; some companies even demand that all hot work tasks be approved by the company’s top management ； Third, some companies require that special work permits at all levels be approved by the responsible persons of the relevant units, such as workshop supervisors or department heads. These strict requirements are intended for good reasons, but in practice they pose many difficulties for enterprises: from the top management to department heads and then to those in the production workshops, everyone is busy going around the production sites to approve various safety operation permits. This not only affects the normal progress of other production and business activities within the enterprise, but also prevents managers at all levels from fulfilling their responsibilities properly in approving such special operation permits. 3 things to keep in mind to improve the management of special operations 01 Enterprises should control and reduce the number of special operations. They should first focus on establishing a sound equipment integrity management system, carry out preventive maintenance on production facilities, raise the quality standards for the equipment and facilities used in production, ensure strict control over the quality of such maintenance, shift from reacting to problems after they occur to taking preventive measures, and thus reduce the need for maintenance on equipment and facilities during normal production operations, thereby cutting down the number of special operations. At the same time, comprehensive equipment inspection and maintenance management should be implemented, using prefabrication in safe areas as a substitute for on-site maintenance of production units, in order to minimize the number of special operations in the production unit area. 02 Enterprises should standardize the approval process for special operations. Enterprises must understand that going through the approval procedures for special operations is not merely about obtaining a safety work permit; rather, it is important to ensure that various safety control measures such as energy isolation, gas testing, and supervision of the work are implemented through the issuance of these safety work permits. Companies should enforce strict approval procedures for special operations, putting an end to practices such as issuing forms merely for the sake of doing so (signing without indicating the time, or entering false times), as well as the pursuit of \"perfect\" safety operation forms at the expense of ensuring proper safety controls at the site where those operations are carried out. The reviewers and approvers of various types and levels of special work permits must go to the work site to conduct on-site inspections of the implementation of safety control measures there; only after confirmation can they approve the safety work permits. It is essential to prevent the approval of such permits outside the work site. 03 Enterprises should optimize the approval processes for special operations based on actual conditions. A complicated approval process for such operations does not necessarily mean thorough management; rather, enterprises should, while meeting standard requirements and controlling the risks associated with these operations, scientifically optimize and simplify these approval procedures. This way, the personnel involved in the operations have the time and energy to properly understand the details of the operations, the potential risks, and the measures needed to manage them, instead of wasting time and effort on filling out numerous unnecessary forms and documents. GB 30871—2022 \"Safety Specifications for Special Operations in Hazardous Chemical Enterprises\" does not specify who must approve safety operation permits of various types and at different levels; anyone whom the enterprise deems to have the capability to approve such permits, as determined through evaluation, may sign them. Therefore, it is not necessary to require that safety work permits must be reviewed and approved by managers at all levels of the company; other qualified management or technical personnel can also participate in the approval process for such permits. This not only reduces the workload of managers at all levels within the company but also effectively improves the efficiency of approving special operations. In short, special operations carry a high level of inherent danger, but their risks are not uncontrollable. By fully recognizing the high risks and importance associated with special operations, enterprises should study standards such as GB 30871—2022 \"Safety Specifications for Special Operations in Hazardous Chemical Enterprises\" carefully. By taking into account their own specific circumstances, they can carry out preventive maintenance on production facilities, thereby reducing the number of special operations. By formulating scientific approval processes for such operations and implementing effective controls over them, it is possible to regulate these operations properly, manage the associated risks, and ensure safety during special operations.