Ron Allen, P.E., CSP, CPEA, is senior director of environmental safety, health (ESH) and quality for Imperial Sugar Company. In this interview, Allen explains how he is working to change Imperial’s safety culture and discusses the improvements made within the company thus far.
Please provide a brief description of your professional background and of your position as senior director of ESH and quality for Imperial Sugar Company.
I was among a fortunate group who chose to pursue ESH management as a career during a period that the function was beginning to flourish. Promulgation of OSHA, the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act and other related legislation provided opportunities for ESH professionals to progress from the role of “technical specialists” to take a seat at the management table.
My job changes have been infrequent, but I have had the privilege of practicing my profession with several organizations whose objectives went beyond compliance. I was attracted to Imperial Sugar in the wake of the company’s tragic loss of 14 lives in a combustible dust explosion in February 2008 because of the company’s commitment to make a difference. Imperial’s CEO, John Sheptor, was not only interested in establishing Imperial as the world’s safest sugar refinery, but also in sharing Imperial’s experiences to help other industries handling combustible dust to better understand and manage the associated risks.
Our CEO, John Sheptor, approached me through a mutual contact from the days that we had worked at Monsanto Company. John and I were not directly acquainted but were aware of each other’s work. John easily convinced me that the Imperial position presented an opportunity to make a difference. Not only did the job present the challenge to help realize John’s vision of greatness for Imperial Sugar’s ESH program, but there was also promise of sharing information with other industries to help create a much broader improvement in combustible dust management.
The personal reservations were fleeting. At the time that John approached me, I was heading ESH for one of Eaton’s four global businesses and was responsible for ESH management for a number of plants around the world whose recordable injury rate had been reduced by >90% over the preceding 5 years. All of our plants had been certified to OHSAS 18001, and our USA and Mexican plants had achieved or were on their way to achieving VPP status. As I reflected over the 5 years that were invested to accomplish those results, I realized that the fun and satisfaction was not in gaining the results themselves. The fun and reward came in overcoming the challenges and climbing the mountain to make the results happen. I liken the experience to mountain climbing. There is satisfaction in standing on the summit, but the memories are built upon the climb.
While there were differences in details, the approach was very similar. Over the past 36 years, I have had the privilege of working for many conglomerates that provided me the opportunity to manage ESH in a breadth of industries: metal fabrication, primary metals, chemicals, construction, industrial service, electronics, gas separation, production of catalytic controls, research and development and now food. The ultimate success is always found with the deployment of a consolidated management system that defines responsibilities for all levels of the organization, establishes metrics that are capable of creating continuous improvement, relies on sincere management commitment and meaningful employee involvement, and creates a sense of pride by stakeholders.
Cultural change begins with the expectations and examples set by management. The process starts with the most senior levels of the organization. Imperial Sugar is fortunate to have the commitment and attention of its senior leaders. Our Corporate Safety Council is comprised of all company officers and plant managers. We meet nearly every month. I am the only safety professional on the council.
The Imperial approach—emphasizing a line-driven commitment to safety—will produce superior and sustainable results. It is hard work. We believe in and support BBS, but BBS can take many forms. We are currently building the foundation by defining standard operating procedures, a breadth of EHS programs and procedures, and training/preparing our leadership and employees. We are focused on the program’s continued development so that we will be prepared to take a more traditional approach toward BBS, including the formal and systematic observation of safe and unsafe acts.
While our current approach is not quantifiable, we are taking necessary actions to build for future success. Our current emphasis is on training, correcting, reinforcing and generally raising the bar. We have a team in the early stages of deployment that will determine when and how we transition to a more traditional BBS program that includes formal observations and provides tools for developing leading-edge metrics.
My boss, Ralph Clements (vice president, manufacturing and engineering) is an absolute zealot about consistency between the plants. Our plant managers and ESH managers maintain frequent communications to share ideas and to drive consistency. Consistency is a demand of any program or process that I direct. It is an interesting dance. We share, debate and ultimately reach consensus about the best approach for the corporation. The exercise produces some bruises since all involved parties have a tradition and sense of pride about what they have done or what they have proposed. The process is imperfect, but it seems to be working well enough to keep us moving in the right direction. A consistent approach is very achievable. Absolute consistency, including establishment of identical practices from one operation to another, is more challenging.
I do not think any single feature makes our rebuilt packaging and bulk loading operations unique, but feedback from respected consultants and insurance executives indicate that the rebuild has an extremely strong combination of controls. The engineering controls may be most visible, but behind those engineering controls are a series of procedural, training and maintenance controls that provide additional layers of safety. Our 115-year-old Gramercy plant observes the same principles as the rebuilt portions of the Port Wentworth plant. We have made similar engineering, procedural, training and maintenance changes. The differences relate to your question about consistency. The approaches are consistent, but some of the final details vary depending on circumstances and differences between the facilities.
Every combustible dust has its own unique properties. A common mistake is made in generalizing about combustible dust risks. Even sugar is subdivided into a broad series of products based on their combustible or explosible risks. Many factors, including particle size, moisture content, particle shape, and concentration, dictate final risk.
A first priority of any operation that handles dust is to understand the combustible and explosible properties of its products. Even within our industry, the profiles of combustibility and explosibility are so unique that each sugar manufacturer should analyze its own products. Without analysis, there is no assurance that competitors’ products would have the same characteristics as ours. The same concept applies for industries that produce metal dusts, wood dusts, grain dusts, etc. Complete understanding can only be achieved through laboratory analyses of relevant final products, raw materials and intermediates.
Many factors must be considered when determining the hazard or risk level represented by a combustible dust. A few are maximum explosion pressure (Pmax), maximum rate of pressure rise (Kst), minimum energy needed to ignite a cloud (MIE) and minimum explosible concentration—similar to lower explosive level (MEC). When compared to the broad spectrum of combustible dusts, sugar is far from the most hazardous.
The list is too long to accurately summarize. We rely on consensus standards for guidance, and while excellent for guidance, as consensus standards, they have their limitations. Consensus standards often use the word “should” versus “shall,” which allows users some latitude in determining how the standards should be applied. They are sometimes vague and, on occasion, the standards conflict with one another. We have relied heavily on outside experts with much experience in dealing with the relevant standards and their application in the real world.
With vigor! Good housekeeping is essential when managing combustible dust risks. Our process begins with a formal housekeeping policy. That policy drove creation of department-specific housekeeping requirements and processes for auditing our housekeeping practices. Our senior management set the right example by ordering plant shutdowns when housekeeping was disappointing. Local managers followed and that led to shutting down departments when housekeeping improvements were needed. The process continued to cascade to frontline supervisors and employees as they better understood and appreciated the need for good housekeeping. Now they feel empowered to take necessary actions to maintain desired levels of housekeeping, even if it means shutting down their equipment. While we have made great gains in this area, the job is never complete. We know that it is management’s responsibility to keep the standard high. However, it is pleasing to see employees at every level supporting the process.
We worked with Chilworth Global (a professional process safety firm) and ExxTend (a firm specializing in adult learning, including delivery of CBT products) to develop three separate CBT modules addressing combustible dust management. The most fundamental module is designed to orient office employees, contractors whose work would not require an extensive background in combustible dust hazards and those rare, unaccompanied visitors.
The other two modules were designed for plant employees and contractors who would have a similar need for combustible dust training as our own employees. A fourth module is in the early stages of development that will provide instruction on detailed maintenance regimes required to preserve the integrity of operating equipment (e.g., bucket elevators, screw conveyors) and safety devices (e.g., explosion panels, suppression canisters).
ASSE was my first employer following graduation from West Virginia University. At the time, I felt that I had landed the best job of the graduating class. I still feel that way. My first boss, ASSE managing director Wayne Christensen, instilled a work ethic that has guided me through my 36-year career. I also met people who directly or indirectly influenced every step of my career. Working for ASSE was like a continuation of my graduate school studies. As a student, I studied about the contemporary leaders of the safety profession. As an ASSE employee, I had the privilege of working with them! ASSE also provided a great opportunity to interface with the regulatory and legislative processes and to work with colleges and universities that were developing curricula to educate future safety professionals. I am still grateful for the opportunity and experience.
What are your safety goals and objectives for Imperial for the remainder of 2010?
Many of our goals relate to injury reduction/elimination, compliance, training, development of the management system, and outreach. Outreach relates to our efforts to share our combustible dust experience with external audiences—like the readers of this interview. Our outreach efforts have included working with other sugar producers, customers and other entities handling combustible dust.