Mitigation Strategies - Preparation and Prevention
- Selection, employment, development, guidance, and rewarding of the best operations staff available.
- Creation of an incentive system that rewards compliance with the company mission and principles and severely discourages shortcuts.
- Clear-eyed risk analysis of each contemplated procedure change or new venture, quantifying the potential for and cost for each identified risk.
- Establish Standard Operating Procedures (SOPs) based on known effective mitigating strategies for each identified risk.
- Put in place a non-conformity identification, capture, documentation, analysis, and management-of-change of SOPs process to prevent incident repetition.
- Establish a candidate counterparty review program with absolute veto authority, free from any overt or subtle commercial influence.
- Put in place a routine audit program to verify compliance with SOPs. Recognize that every requested departure from SOP represents a heightened risk requiring intensive executive and management focus before proceeding.
- Identify qualified operations experts at strategic locations to provide on-scene representation for unusual operations and rapid response for incidents.
- Have on retainer an expert outside attorney.
- Provide each principal staff member in "the chain of transportation" with liability insurance covering European Criminal Pollution Sanctions defense and fines.
- Have at least two members of the operations staff HAZWOPER certified and issued with US Coast Guard Port Security (TWIC) cards.
- Prepare a major incident response plan and conduct annual exercises of the plan, including participation with key counterparties.
- Create a set of counterparty agreements that clearly delineate responsibility for unplanned events.
- Participate in industry organizations, forums, and associations to be aware of emerging risks and learn about intelligent mitigating strategies.
The good news is that almost all petroleum movements arrive safely at their destination.
Major incidents are the rare exception and occur because of multiple errors and omissions at all operational levels, usually with the root cause based in management failure to recognize and manage risk.
Prevention is the key.