Pobres y pobreza

Colin is responsible for the corporate management of HSE+ and is identified on Chart C as the most senior of the HSE+ professionals in Company C before restructuring. This is one of several support activities associated with his position, which include some major projects and Operational Excellence. Colin describes his HSE+ role as that of a corporate-level expert available to provide advice and assistance to corporate-level operations managers in meeting their corporate HSE+ responsibilities. Colin expects to be involved in all executive- level decision-making related to operational safety and risk within the organisation but does not involve himself directly with operational activities. Nor is he a direct colleague of either the executive leadership team or of the senior operations managers.

Colin's senior position and corporate functions constitute a potential POSS role due to his functional independence from commercial priorities and his access to the authority of leadership, separated from the CEO by only one level of hierarchy. However, Colin has no authority over (and limited interaction with) the many HSE+ personnel employed within Company C’s operating units. Each of the operating business units are expected to independently implement the corporate HSE+ policies, strategies and procedures throughout their operations; to review and document their ongoing HSE+ performance; and to report any incidents. Colin is unable to give a confident estimate of the number of HSE+ professionals employed in Company C (guessing "several hundred") or to even think of a way in which that number could be readily determined and verified.

Interestingly, when Colin identifies those of his staff who have input into operational safety activities, he does not include his technical support team. They are described as being responsible for technical oversight of operational excellence and improvement throughout the organisation. Colin, however, only discusses the staff members in his corporate HSE+ group, which is responsible for corporate governance and assurance activities. These activities include: the development of corporate policy and strategy; the documentation of operating standards and procedures; and the audits of operating sites and facilities against the requirements of the HSE+ management system. The corporate HSE+ group also collates HSE+ metrics as reported by the operations groups; and investigates reported incidents to review both incident management and the follow-up of actions and recommendations. Colin has designated one member of his staff to maintain and update the corporate HSE+ management system, which broadly covers almost all aspects of operational safety, including technical integrity, risk management and process safety. He has designated another staff member to collate reported data and keep track of various measures by

which operational HSE+ performance is judged. Colin's remaining HSE+ staff members are fully occupied with a tight schedule of worldwide facility audits against the requirements of Company C’s HSE+ policies, strategies and operations management system.

Colin only has a handful of corporate HSE+ Auditors to oversee Company C's worldwide operations. This paucity of personnel resources means that the scope and depth of the assurance activities undertaken through the corporate audit program is quite limited. The established protocol for the corporate audits is that each business unit presents the findings of their own in-house audits to the corporate HSE+ Auditors for their review. The operating units are expected to independently audit their own facilities and operations in order to ensure compliance to the corporate management system and report any issues. It is common practice for the HSE+ Auditors to confirm compliance to this management system but to not validate the in-house audits or verify that the actual operating practices are in compliance with corporate standards. There is a long-held expectation that Site and Facility managers will be diligent in self-reporting: identifying and seeking advice on any non-compliances that they themselves discover during their in-house audits.

Colin is satisfied that this self-regulation does in fact occur but he does not offer any information on verification activities that are undertaken by the corporate audit team to confirm such an assumption. The validity and quality of reported data used to generate the HSE+ metrics that are collated, analysed and reported as operational performance by Colin's team also rely on the operations groups attending to the monitoring activities with diligence and competence. Colin does not have the resources to investigate and separately verify any of the operational safety data that is processed through his department. The assurance activities undertaken by the corporate HSE+ group, as described by Colin, cannot actually be considered to be genuinely independent oversight of operations.

Colin is concerned with how little impact the corporate assurance activities have on operating practices. Colin garners some influence through his capacity as the corporate HSE+ Manager because he presents audit findings and recommendations, and reports on the operations groups' compliance to corporate standards, to executive leadership. However, this influence is limited and it is also undermined by a lack of any authority to enforce the implementation of the HSE+ Auditors' recommendations. Also, the corporate audits are infrequent: typically scheduled from two to five years apart. So, an audit recommendation can easily be ignored for several years without verification, and then several more years before being identified as a recurring issue. A Site Manager who simply claimed that an action from the previous audit is “included in next year's budget" could

have between four and ten years of non-compliant operations before the corporate HSE+ audit team could independently confirm or flag the Site Manager as recalcitrant.

The corporate HSE+ group is not part of any integrated functional group responsible for HSE+ related activities. Colin's HSE+ team is clearly limited to corporate governance, based on a well-documented operations management system that also generates documentation in the form of performance metrics, audit reports and incident records. The assurance activities of the corporate HSE+ group relies on the advice of the operations lines and Colin is not expected to: enforce compliance to corporate standards or audit recommendations; or assist with such compliance by instructing or guiding those HSE+ specialists who are fully embedded within the operating units.

The operational safety governance activities at the corporate level of Company C seem to rely on the appearance of diligence and attention – and only a nominal commitment to operational excellence. This actually obscures the simple fact that operational practices and management processes are not independently monitored or verified for compliance to even the minimum established corporate standards.