“For having lived long, I have experienced many instances of being obliged, by better information or fuller consideration, to change opinions, even on important subjects, which I once thought right but found to be otherwise.” — Benjamin Franklin
The first time you ever encountered a weasel word was probably when your mom said, “Maybe,” or when your dad said, “I’ll think about it.” You’ve been conditioned from an early age to be suspicious of weasel words, and to demand clarity in responses to your requests.
It should be no different when a team is developing recommendations during a process hazard analysis (PHA). There should be clarity. When someone is assigned responsibility for addressing a recommendation, they should know what it is that they’re supposed to do.
This is the reason that many people will scoff at a recommendation that begins “Consider…” and dismiss it as weasel words.
Are they right?
The Purpose of the PHA
When a PHA team convenes, its purpose is to identify the process safety hazards of the process, and when necessary, recommend measures to reduce the risk of those hazards to a tolerable level. The team that identifies hazards may also have the expertise to know the best measures to reduce the risk of those hazards. But they may not.
What are the criteria for judging what is best?
- Does the recommendation reduce the risk, and does it reduce it enough?
- Does the recommended measure introduce new hazards, and if so, are the risks of those hazards tolerable?
- Are there more cost-effective ways to achieve the same or better risk reduction?
None of these are questions to tackle more than superficially during the PHA. When the PHA team identifies a hazard with higher than tolerable risk, it may collectively know exactly what needs to be done to address the hazard. More likely, though, it will have some ideas of what could be done, but not be clear on the details. It is not the role of the PHA team to work out those details. That is for the person or team assigned responsibility for addressing the recommendation.
Addressing and Resolving Recommendations
The Process Safety Management (PSM) standard, 29 CFR 1910.119, describes the requirements of PHAs in paragraph (e). It states that there must be “a system to promptly address the team’s findings and recommendations” and that recommendations must be “resolved in a timely manner and that the resolution is documented”.
The standard doesn’t state that the team’s findings and recommendations must be implemented as stated. It allows for the possibility that recommendations may be ill-considered. It allows for the possibility that recommendations may be good, but that there are better approaches.
All of this requires focused effort that is not part of the PHA team’s brief. It requires consideration.
Can “Consider” Be a Weasel Word?
Some fear that a recommendation that begins “Consider…” can be reviewed and simply disregarded. “Yep. I considered it and we’re not doing it.” But that meets neither the intent nor the explicit requirements of the PSM standard. The standard requires that each recommendation be addressed and resolved, “and that the resolution is documented.” No, it is not enough to write down, “I considered it and we’re not doing it.” The documented resolution needs to show how the recommendation is being implemented, and if it is not being implemented, to justify why an alternate course of action is better.
It is helpful to write the recommendation with the need for flexibility in mind. Don’t simply replace “Install a relief valve on Surge Vessel 2” with “Consider installing a relief valve on Surge Vessel 2”. Instead, phrase the recommendation as “Consider how best to assure that Surge Vessel 2 has adequate pressure relief in compliance with applicable codes.” If the team is certain that the answer is to install a properly sized relief valve, then expand the recommendation to “Consider how best to assure that Surge Vessel 2 has adequate pressure relief in compliance with applicable codes, e.g., install a relief valve.”
Follow-Up on Recommendations
Every recommendation generated by a PHA team requires follow-up. Which means that every recommendation generated by a PHA team creates work for someone to do. But not every recommendation generated by a PHA team is a good recommendation. Structuring a recommendation to begin with the word “consider” acknowledges that there may be better ways to address the hazard that the team has identified. The person charged with addressing and resolving the recommendation will not mistakenly believe that they have been locked into a single approach when better approaches are available.
To Change Opinions
Teddy Roosevelt, a man of bluster and bombast, said, “Weasel words from mollycoddles will never do when the day demands prophetic clarity from greathearts. Manly men must emerge for this hour of trial.” PHAs are not a time for bluster and bombast from manly men, however, but a time for thoughtful consideration. In the words of Franklin, there will be many times when you are obliged “by better information or fuller consideration, to change opinions”. Please consider writing your recommendations to reflect this wisdom.
