Remarks of Howard "Skip" Elliott: Round Table Discussion of the National Transportation Safety Board
March 9, 2020
Good morning, and thank you to Sara Lyons for her work on organizing this event.
I’d also like to thank my friend and colleague, Jennifer Homendy, for her many years of dedicated focus on all things safety, and especially our shared passion for doing all we can to help the emergency first responders in this country.
Events like this are vitally important in advancing the cause of safety, because it allows us to hear a variety of views and opinions from individuals who are deeply committed to the importance of safety and the value of safety management systems, especially pipeline safety management systems.
And, the fact that there may well be differing opinions presented here today should be viewed as a good thing.
New points of view, lively discussions, and collegial debate is necessary if we’re to collectively arrive at even greater levels of safety in the U.S. pipeline industry.
But after working in the freight rail industry for forty years, and during a time where I personally witnessed huge improvements in safety in an otherwise very unforgiving environment for those who chose to take risks, I think it’s important to pause and ensure we’re seeing things in their proper perspective.
It’s easy to see the topic of safety “in the moment,” and not across its historic continuum.
As the Administrator of a federal agency whose primary mission is safety, I regularly talk publicly about setting our sights on achieving zero incidents.
The only reason I can INSIST that this must be the safety target we now strive for, is because of the years of improvements in safety that have brought us to this point in time today.
I’m a fact-based person, and like it or not, depending on your own personal point of view, the facts are that the industries that get talked about most at the U.S. Department of Transportation have arrived at levels of safety that are truly, and undeniably, very good.
So good in fact, that it allows me to declare that to settle on anything less than zero incidents admits defeat. And, when we’re talking about people’s lives and harm to the environment, admitting defeat cannot be considered.
So, when any incident can become an ultimate tragedy, being very good in safety is just a gentle way of saying not quite good enough.
Back in mid-January when Jennifer asked me to speak at this SMS Roundtable, I didn’t hesitate for even a second before saying yes.
The reason was simple.
First I have great respect for the role of NTSB in advancing transportation safety, and great admiration for the unwavering commitment to safety held by both Jennifer and Board Chairman Bob Sumwalt.
The second reason is because I firmly believe that wide-spread implementation of, and sustained adherence to, a properly structured and administered safety management system is the most likely way for us to arrive at zero incidents.
Now you might believe my views about getting to zero incidents to be a bit Pollyanna, or even naïve, and that’s perfectly fine with me. But, if you don’t share that belief, or something very close to it, then I would respectfully question your motives for being here today.
A lot’s been written, lectured, debated, and pontificated about safety management systems for many years and throughout the world. For me anyway, I believe that the nucleus of a safety management system, and the reason it’s such a powerful force in improving safety is the culture it changes.
I’d like today to explain why I believe that. I’d also like to advance an argument for why operators should agree with that vision, and sketch out how they should proceed to execute it. Here’s what we know about culture. It influences what people see, hear, feel, say, and do.
Most importantly, culture influences behavior which impacts decisions and actions in an organization. And ultimately, it’s this behavior that drives safety performance.
We all know that a positive safety culture starts at the top of an organization, and permeates through every aspect of it. It should not be restricted to the operational aspects of pipeline safety, but rather span all organizational areas, until it practically becomes part of the organization’s DNA.
Now that’s a tall order. And it’s also one that’s best-served by collaborative efforts which begin with a common understanding of what comprises a high-quality SMS system and what benefits can be expected to flow from it.
So, here’s why every pipeline stakeholder should be as committed to SMS as we are at PHMSA.
First, pipeline operators have a moral obligation to provide safe service, which they do 99.997 percent of the time. But the remaining point-zero-zero-three percent is not zero, and that matters.
In this group, I shouldn’t have to press too hard to win this point. And only a few words are needed:
• Aliso Canyon
• Lincoln County
• Merrimack Valley
• San Bruno
When safety failures can result in such devastating impacts, hiding behind numbers cannot conceal the responsibility to do better.
Second, and related. the law requires companies to provide safe and reliable service at a reasonable cost. Some have said that we can’t legislate morality, but think about it. In this case, we already have.
Third, the aggressive implementation of SMS just makes good business sense. Everyone knows that the business of pipelines, and energy more generally, is challenged these days in the area of public perception.
In such an atmosphere, every accident holds the potential to disrupt the industry, which is currently booming despite those challenges.
We’ve also seen that pipeline operations can be affected by adverse perceptions. In September, 2018, after the Merrimack Valley explosions, there were calls to require SMS implementation by all operators.
I can tell you from personal consultations that these calls had important supporters on Capitol Hill.
And, I can also tell you that whatever PHMSA believes about the value of voluntary buy-in, we’re probably still only one bad accident away from a Congressional mandate to that effect.
So, what do we mean when we speak of a culture-based approach to safety?
Well, PHMSA was busy in Houston, Texas last week addressing that question with a wide-variety of pipeline industry stakeholders as part of a broader pipeline safety forum we sponsored.
One session at this event was devoted solely to SMS and safety culture.
And, to underscore the interest in this topic, there were over 250 people in attendance and another 2,500 hits on the webcast of the meeting.
PHMSA was also honored that NTSB’s Sara Lyons was able to be in attendance.
The event in Houston demonstrated a broadly shared commitment to SMS and safety culture, and developed a common understanding which we hope and expect will lead to better performance and public safety.
To create the culture we seek, operators must begin with some bedrock principles. Their safety regimes must be driven by individual values and a commitment to accountability.
They must encourage employees at every level to do what’s right, no matter what.
They must be driven by safety for all. Employees, the public, the environment, and company assets.
And, they must be positive, engaging, and proactive.
Moving to a proactive safety paradigm will require a change in the way we think about and measure safety.
We must move away from defining safety as the absence of things. Safety should be conceived as more than merely no violations, no injuries, and no accidents. It’s better conceived as the PRESENCE of safety in our minds, in our processes, and in our strategy.
Traditionally, safety strategy has evolved in response to past incidents and accidents. This creates a reactive mechanism, and it leaves us vulnerable to the somewhat clichéd, but real phenomenon of “fighting the last war.”
To adopt a more proactive approach means to actively collect data that identify and address current hazardous conditions.
Applied consistently, that framework will allow us to move to a more predictive model.
One that systematically analyzes safety risk data and performs forward-looking analytics to identify potential or future problems.
A strong safety culture goes hand-in-hand with this kind of paradigm shift.
In my 40 years focused on railroad safety, I had a front-row seat to observe the development of safety culture, and the 70 percent decline in railroad accidents that tracked right along with it.
So, I’d like to share some of the elements of that evolution which I think will adapt readily to pipeline operations, and could deliver the same kind of impressive advancement of better safety outcomes.
The roadmap to a strong safety culture has the following points of interest:
• Demonstrate commitment and accountability to safety, pervading every aspect of the operation.
• Promote questioning attitudes, because predictive analysis requires them.
• Promote open communication and reporting, not just within the organization, but also across the industry when possible.
• Avoid normalization of deviance: When a risk factor is observed, aggressively eliminate it.
• Eliminate production pressures and reduce workplace complacency: Vigilance is the price of safety.
• View and speak of safety as an investment, not as a cost.
• Empower employees to find and fix problems.
• Make bold changes when necessary – and trust predictive analysis that suggests they’re necessary.
• Make safety the highest priority, always, and everywhere.
We need to be predictive and create safety gains through implementation of SMS and do all we can to strengthen our culture of safety.
As I said at the outset, it’s a good thing that this meeting will see different opinions and viewpoints expressed.
I’d like to close with a clear statement of the parameters of that discussion, in the form of what PHMSA expects of those charged with the responsibility for pipeline safety.
PHMSA’s expectation is that industry will comply with existing and new rules and regulations.
We also expect industry to know their system and to go beyond compliance to help achieve zero incidents, with a strong focus on prevention, and that means a concerted and across-the-industry commitment to safety culture and Safety Management Systems.
Ladies and gentlemen, thank you for your time this morning. And thanks for coming to this Round Table, and for having me here to set the stage for it.