N－98
An Experience in Japan Process Industry before, after 1984, and then
Koji NISHIKAWA
International Committee of Japan Society for Safety Engineering
Abstract ; The author had jobs in a chemical company of Japan and in public organizations on safety, health and environment entrusted by Japanese government ministries. This paper is a brief history of Japan process safety and the related legislation in the last quarter of 20th century described through the author’s eyes.
On the history of the regulations, the author describes the following three items,
- Big accidents and the succeeded stringent regulations
- International harmonization of the regulations
- Problems for reasonable regulations
Then, the author develops the private opinion on “Integrated Risk Management” to obtain the efficiency of the management or to improve the product competitiveness. Japan process industries have introduced and modified the predecessor’s methods or technology on their traditional corporate culture, for example, Japan industry introduced the product quality control system or standards from USA after the second world war but modified them to the “Total Quality Control (TQC)” as a characteristic bottom-up movement among the workers.
However, as the recent or future problems in Japan the author concerns for losing the vitality or the base ground of the bottom-up culture.
Keywords ; safety culture, risk management, regulation
Preface
The last quarter of 20th Century was a stormy age on the safety and environment problems of Japan process industries. For this periods, the author had jobs as a managing staff on safety, health, environment (S.H.E) in the head office of a chemical company of Japan and as a member of committees on S.H.E problems in several associations of Japan chemical or petrochemical industries, then changed the jobs to public organizations on S.H.E, at the first, gathering and communicating informations on the risk assessments or on the national or international regulations for chemical substances, and at the second, informations, investigations and the education of process safety.
The purpose of this paper is to describe the private opinions on a brief history since 1973 on the regulations and the measures of the process safety in Japan process industries, and then to show the aspect of the recent or future problems in Japan based on the author’s experience.
1.Big Accidents and the Succeeded Stringent
Regulations
Since the first petrochemical complex started in 1958, Japan process industries had rapidly progressed.
Air and water pollutions due to the industry had grown to a big social problems, then extremely stringent regulations for the environmental protection were enforced to Japanese industries till approximately 1975. These regulations become a base of commitments or agreement between each process industry and the community.
The same year of the first oil crisis in 1973, big accidents of explosion and fire occurred consecutively in chemical industries or petrochemical complexes in Japan. In an oil refinery, big oil tank fire occurred and it was very difficult to put out. The biggest accident occurred at a refinery in 1974. A large heavy oil tank bottom fractured and the flushed oil destroyed the protection dike. The flooded oil spreaded to the surface of the front sea on a wide area. The clean up cost was equivalent to approximately 500 million US dollars.
A new law to prevent from petroleum complex disaster was enacted in 1974, and existing laws related to process safety, fire protection and occupational safety were revised to be extremely severe for Japan process industries in 1975~77. In this period the tragedies in Flixborough (1974) or in Seveso (1976) occurred in Europe. Thus Japanese stringent legal regulations for process safety were issued before the Seveso directive in EU or CAER program in USA.
Since 1975, the accidents or incidents in Japan process industries reduced rapidly, by the following four reasons which the author assumed.
1)Japan process industries responded rapidly and seriously to the severe governmental regulations based on the new or the revised law till the restricted time limit for the following examples.
a)Minimum requirements for the process safety
b)Facilities to prevent from spreading disasters
c)Education of workers and preparing national licensed supervisors or plant managers
d)Emergency response
2)Information exchange systems on process safety measures were established in the safety committees in the associations of chemical, petrochemical or oil refinery industries.
3)Workers’bottom-up movements on the process safety were activated in Japanese corporate culture, such as “Training to foresee dangers (KYK) ”, “Total Productive Maintenance (TPM) ”, “Activity for plant cleanliness and good habit (5S) ”, and so on.
4)Local governments efforted to realize the permission / inspection system based on the laws for the management of changes not only of main equipment but also of detail pipings.
As the result of reduced accidents or incidents in Japan process industries, good relationship recovered naturally between government, industry, and the community. Then their mutual trust, understanding and communication were established.
Table 1 shows four legal regulations for safety of process industries in Japan.
Table 1. Legal regulations for safety of process industry in Japan based on the revised laws A,B,C (1975~77) and the new law D (1974) (Four process safety laws) The actual name of laws and ministries are omitted for easier understanding of foreign countries’ people.
Mark ○; applied items by the author’s approximate assumption
Applied Items / LawsA / B / C / D
Competent Authorities (Ministries)
Purpose; Process Safety (Production)
Fire Protection
Occupational Safety
Petroleum Complex Safety
Minimum Requirement of
Process Design
Plant Layout
Process Control
Safety Devise
Fire Fighting System
Guard for workers
Guard against external liquid spill
Guard against toxic gas effluent
Emergency Response
Management of change
Plant Inspection by Government
by Plant Owners
Confirmation for Requirement
Notification of Managers
National License of Managers
Engineers
Supervisors for shifts
Workers
National Education of Managers
Supervisors
Workers
Safety Promoters / K
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2.International Harmonization of the
Regulations
The stringent regulations for Japan process industries comparing with that in the other countries increased the products cost and reduced the competitiveness on the world trade.
In 1983, a consultative organ of Japanese government issued a proposal to restructure the national administration. The proposal included to turn the legal regulations to self-regulation of the private business. This was a tide changing the directions of the regulations.
Severe and serious discussion about how to change the regulations began between the competent authorities and process industries. When the discussion results were accumulated in 1984, the sudden news of Bhopal tragedy attacked Japan government and the chemical industries. Japan government investigated rapidly through
communication network between government and chemical industries and resulted within two or three days after the tragedy that there was almost nothing in Japan on the material like as MIC which was the cause of the tragedy. There were several agricultural chemical companies in Japan, but almost companies did not use MIC. Only in a factory there was very small hold up of the intermediate MIC as a flow through the process.
Based on the above rapid investigation, Japanese government was successful to put out the fire of public opinions concerning for the toxic chemicals just after Bhopal accident.
Thereafter the discussion to make legal regulations reasonable was continued and process industries obtained the changes, for example, as follows.
1)self-inspection by the industries was substituted for a part of governmental inspection
2)the management of change by the industries on minor changes of process equipment or pipings was substituted for permissions by the
government.
On the recent years, the efforts for the international harmonization have been continued now. Japanese specific detail construction codes of pressure vessel which were applied as legal enforcement are changing to one of examples of codes which are used worldwide, and the regulations are changing to the minimum requirement of the function of safety.
Many regulations on S.H.E in Japan were modified for the harmonization depending on the U.N. or OECD’s recommendations or guidelines.
3.Problems for Reasonable Regulations
Freedom from the legal regulations gradually contributed to the economic progress in Japan.
However on the S.H.E, there were somewhat of barriers against making regulations reasonable because of the following reasons.
1)Most Japanese people have a tendency to request “Zero Risk” on the product quality for the consumers or on the manufacturer’s safety and the environmental protection for the community.
2)Japanese technocrats are not always positive to change the legal regulations. They have a tendency to insist on keeping their competence in a narrow limited area.
3)There are two different layers of enterprise groups in Japan on the level of management for S.H.E. The first layer consists of big process industries which have good managements of S.H.E under many qualified staffs. The second layer consists of smaller enterprises which have usually poorer managements for self-regulations. The legal regulations should be generally common or equal for all enterprises. The above different level may be the barrier to change from legally enforced regulations to the self-regulations.
A process industries group insisted to integrate four safety laws A,B,C,D, but it was not accepted.
It is very difficult to integrate the existing laws among the network of many other laws on which each different competent authority insist to keep the competence of regulation.
Administration people in Japanese government or process industries are not serious for the plant risk communication to the community which is not yet enforced by law as same as the process safety assessment is not enforced. However most Japanese do not seem to require the legislation of them.
4.Opinion on Integrated Risk Managements
This is author’s proposal to establish business risk management system based on a common method which consists of four steps, i.e.
1st step Foreseeing and Recognition of Risks
2ndstep Analysis or Evaluation of the Risks
3rd step Solution of the Risks
Avoidance, Reduction, Retention or Transfer (Insurance)
4th step Communication of the Residual Risks
We should integrate every management of safety, health, environment, quality, facility, productivity, corporate governance, or emergency crisis, upon a common policy, method and activity. Generic integrated management must reduce the cost of staffs for administration comparing with total separated managements.
The separated management systems like as ISO 9000, 14000 or OSHMS are not efficient.
Risk management is everybody's job and responsibility. Bottom-up activities are the key of success. Easier start of the approach is controlling everybody’s individual risks by themselves. They will recognize many kinds of risks at home or traffic, such as fire, earthquake, robbery, injury, disease, suit, etc. Habit to consider the private risks must be expanded to control their job risks.
On the production field, risk management is everybody’s business and it integrates all related risks not only safety but also health, quality, productivity, competitiveness or trust on the products, and global environment under a production manager. Everybody must be concerned to the corporate policy and the management, and then be interested in needs of the community, the society or the world trade market.
Why now risk management?
Many kinds of business risks we know,
disaster, disease, pollution, failure,
bad quality, bad competitiveness,
emergency crisis, illegal behavier, etc.
Who has seen the “Safety”? Neither I nor you.
But we can see or image easily accident or dangerous situation.
“Safety” is an abstract concept. “Risk” has concrete reality.
All managements must be replaced with risk control.
Table2. Management and Risk
Management / Risk to be controlledSafety / Accident, Disaster
Health / Poison, Disease
Environment / Pollution, Recovery
Quality / Defect, Contamination
Facility / Failure, Damage
Productivity / Cost, Delay
Sales / Losed trust
Crisis / Failure to cope
On one work field, only one manager is responsible
for all management items.
Separated management in administration
should be integrated to “Generic Risk Management System” upon a common policy, method and activity.
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Fig.1. Integrated business management like as organic body
Safety / A / S / PHealth / A / S / P
Environment / A / S / P
Quality / A / S / P
Facility / A / S / P
Productivity / A / S / P
A : Activity, S : System, P : Policy
Fig.2. Integration to Generic Management System
Expected results of the integration are;
Reduced administrative cost.
Increased competence of line management.
Habit to consider risks widely.
Growth of sensitivity for potential hazard.
Social trust for the business.
5.Conclusion on Management Culture
Introduced culture must grow sound on the traditional culture of each country or nation.
It is not a mere imitation. Modification or mixing cultures are often effective to create.
Most Japanese have a characteristic of mixing culture, For example, Japanese popular foods have variety. They are not only Japanese food original but also modified Korean, Chinese, Indian, French, or American foods.
Japan process industries introduced risk assessment or management methods. However they are not always serious for the assessment which in not the solution of risk itself.
Foreseeing risks is most important because we cannot control unforeseen risk.
The next are the decision and practice on the solution.
Quick action to solve the problem must encourage everybody's mind.
Everybody’s mind of risk management is a source of near-miss reports and improvement proposed by workers.
Spiritual culture is not always descriptive. Sometimes practice without any document takes important effect.
Mind changes action. Action changes habit.
Habit changes character. Characterchanges destiny.