Commercial Vessel Compliance

9/26/2016: 2016 Center for Offshore Safety Forum – Safety culture on the Outer Continental Shelf

Assistant Commandant for Prevention Policy Rear Adm. Paul Thomas recently joined Bureau of Safety and Environmental Enforcement (BSEE) Director Brian Salerno at the fourth annual Center for Offshore Safety (COS) Forum in Houston.

The panel was moderated by Charlie Williams, executive director for the COS – an industry sponsored organization focused exclusively on offshore safety on the U.S. Outer Continental Shelf.

For those of you unable to attend, Maritime Commons is providing a condensed version of Thomas’ and Salerno’s remarks in a four-part series. These remarks are not ‘as delivered’ but provide a condensed version of the panel highlights in the ‘panel-conversational’ style. Below are questions and answers from the panel related to safety culture on the Outer Continental Shelf.

Williams: In 3 to 5 years, what are some success factors that you’d look for that the industry’s delivered in safety culture. What are some key things you’d think about that says, ‘Yes, we are progressing safety culture and doing better in the industry’?

Thomas: I’m going to use the word transparency again. I think that is a key indicator on how well safety culture is progressing, not only within a unit, or a company, but across an industry. When I see business practices that insist on safety culture and well-implemented safety management systems across the supply chain, then I will think we’re making progress. When I see industry holding their partners, their suppliers and their customers accountable, then I’ll think we’re making progress. When I see a company that understands and accepts the fact that when a Coast Guardsman is aboard a unit and sees a problem that might be in the SMS area and we alert our partners that maybe we need to dig a little deeper and look at culture here, not just checklist items. When I see acceptance and not only acceptable but welcoming that, then I’ll think we’re making progress.

Salerno: When you consider how far we’ve come in a couple of years, I think it is quite remarkable. Three years ago, we were just going through the first audit cycle there was that push to make sure everyone had a SEMS plan to have the first audit, and so forth, so we’ve made a lot of progress.

The next three to five years, I think is going to be really focused on maturation of that process. One of the great fears that we have with any type of system like this is that it devolves into a paperwork exercise, and that serves nobody’s purpose. A plan on a shelf is useless. If it doesn’t affect behavior at the deck-plate level and throughout the organization, it’s not achieving its purpose. I think as we go forward, we’re really going to want to look at if basic elements of the SEMS plan being put into practice. Is it influencing the way work is done?

Things like the ‘four what’s’ is a good example of how that really penetrates to the workforce level. As people who are trying to receive information and gauge the sense of the safety culture, we’ll be looking for some way to measure that and really be able to tell if it’s really doing what it’s envisioned to do. I think it’s really maturation, that’s what we’re looking for.

Thomas: I would just add that the maturation needs to happen on the part of both the Coast Guard and BSEE. We’re working hard to mature the processes that we use to ensure compliance so that it’s not just a checklist but it is an assessment of culture so that we can help build it if it needs to be built or that we can apply our resources elsewhere if we see that it’s robust.

Charlie: What are some of the characteristics, indicators or things that you’d see specifically in leadership that you think are key to driving safety culture forward in the industry?

Salerno: With leadership, there is no substitute for really believing your own philosophy regarding safety. People can tell when you’re faking it. If you’re putting out company guidelines that say one thing, but you’re sending other messages that, ‘I know we have this focus but your primary focus is cost and schedule,’ and you’re sort of giving people leave to deviate from the policy, obviously there is a breakdown there.

I think the effective leaders from a safety perspective are ones who truly walk the walk, hold people accountable, reward people for doing the right thing and model the best behavior themselves. I know you’re not in the business to produce safety. You’re in the business to generate a product, provide returns for your shareholders and all that. We’re not talking about it as something different and distinct; we’re talking about just embedding this in the process and making it sort of a strategic imperative for the way business is conducted. There’s no substitute for good leadership at all levels in achieving that objective.

Thomas: I think that sums it up. I see the top leadership in this industry, the leaders of [the COS] boards, for example, really serious about this and really dedicated to it. I think the challenge is good implementation all the way down to the deck-plate, and that’s a challenge – it’s a challenge we work through together by building transparency, by sharing data and by sharing lessons learned. I believe the leadership in this room is dedicated, that’s not in doubt in my mind.

Williams: Companies either have good cultures, or they don’t have good cultures. If they have a good culture, it’s a good safety culture, a good leadership culture, a good quality culture, a good efficiency culture, and it’s meaningful to me because tend to say, ‘Well, we’re going to have nine different cultures,’ and I think good culture delivers good safety too.

Salerno: Exactly, and it sounds very subtle and it is very subtle, but it’s actually very meaningful. You can’t just have a bolt-on safety culture, to bolt on to your corporate or company culture. The safety is really an outcome of your corporate or company culture. If you’re doing things in a safe way and if it’s a core value in how you conduct your business, you will have safer outcomes. But to think of something that can be just appended to how you normally do business and think it’s going to have an effect, that’s not going to work. It’s an important distinction, I think.

Thomas: I would say that the corporate culture will extend into cyberspace, and that’s how we will manage the risk associated with cyber. When every employee understands how the barriers that are currently in place for environmental compliance and for safety compliance are impacted by the cyber systems and how those systems need to be managed, I think culture extends into cyberspace.

Williams: In the future, are you thinking about regulating culture? It’s hard to imagine, but would we have a pink list for culture?

Salerno: I don’t see a way to regulate culture. Every company is different; every set of beliefs and behaviors that constitute culture is going to vary from company to company, so for a regulator to even attempt to do that would be foolish. What we can do is try to gauge whether a healthy culture exists. I think that’s achievable. We can certainly encourage it and incentivize it, for you to develop and mature a culture that meets your needs that also has safety as a core element. Things like the safety performance indicators are a pathway to that and can be very beneficial in helping to make those type of assessments to see if there’s something truly meaningful within the unique culture within any organization.

Thomas: I agree; you can’t regulate culture. As I’ve said before, regulation can support it. I think we have some gaps in our regulations now around safety management systems that we’re working to fix. But to really regulate culture? That’s a business to business thing. That’s when you have to say, ‘I’ve got the culture and I’m only working with partners and suppliers and customers who share my culture.’ When that happens, it will be self regulated, and that’s always the best solution.

Williams: Is the Coast Guard aligned with BSEE’s safety culture definition?

Thomas: The culture policy statement that BSEE put out is based on a lot of literature. It’s hard to argue with. We don’t have a similar policy statement. In fact, the Director and I were discussing whether or not we should. For me though, I recognize that we can’t regulate culture. We can regulate management systems, but we can’t regulate culture. I’m not sure if we were able to codify that in a regulation what the purpose would be. But certainly, we think it’s a great definition. All the tenets are in there and we don’t have a different one.

Thomas and Salerno want to continue this discussion on Maritime Commons. If you want to follow up with any questions or thoughts, leave them in the comments below or tweet them to @maritimecommons using #BSEEUSCG.

In addition to this post, please be sure to view the entire series from the 2016 Center for Offshore Safety Forum.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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