Lead the PHA team to think through the safeguards that are in place that are intended to:
1) PREVENT the event from initiating.
But we KNOW it will eventually happen, so have them think through what’s in place that will:
2) PROTECT assets (people and equipment) once the LPOC event has begun.
Lastly, have them think about how they will
3) MITIGATE the consequences of the event.
In each discussion of P-P-M model, make it clear that we desire
1) ENGINEERING CONTROLS (passive and active), then
2) ADMINISTRATIVE CONTROLS and lastly,
3) PPE personnel would be wearing at the time of the LOPC event
I have found this type of structure really makes the team think through their controls/barriers/safeguards in a hierarchical manner. And when we are done and we have more PPE listed than Engineering and Administrative Controls, we can all recognize that we are approaching PS in an upside-down way.
We want engineering controls in our P-P-M model; heck, we even want passive engineering controls over active engineering controls where possible! And when it comes to “SOP/Training” as a safeguard, PLEASE make sure the SOP/Training covers the specific deviation that led to the failure mode. Far too often, we see “SOP/Training” listed as a safeguard on every line item, only to find that the SOP provides no guidance on the failure being discussed. But it opens the door to improving the SOP/Training to address the failure mode when we can identify this opportunity.