Safety is our top priority at Crestwood, and we strive to maintain our reputation as a safe and good neighbor in the communities in which we live, work and operate. We are committed to building a strong safety culture where all employees are committed to safety, meeting or exceeding all required industry performance standards, and continuously seeking to improve safety performance.
We demonstrate our commitment by ensuring that our pipelines, processing, and storage facilities are safe, and by providing our employees with the tools and training necessary for them to make the right decisions and prevent incidents.
Safety at Crestwood is managed at all levels of the company, from the Boardroom to the field. Our CEO outlines our operating principles and commitment to safety in an Executive Commitment, while our Environmental Safety & Regulatory (ESR) Policy outlines our management programs and key safety principles, and expectations for all employees and contractors. Our key safety principles are:
- Assemble the people with the right skills for the task at hand;
- Utilize safe work practices and behaviors;
- Ensure conformance with all policies and procedures;
- Ensure full compliance with all applicable regulations;
- Promote safe operational control of facilities, vehicles and assets;
- Ensure all safety devices are in place and properly functioning;
- Provide engineering designs in conformance with applicable industry codes and standards;
- Immediately address and correct any unsafe condition;
- Seek timely assistance from technical and subject matter experts as necessary; and
- Ensure that the maintenance of vehicles, equipment, and facilities is performed regularly, identifies failures, and is documented in a consistent manner across the company.
To execute our safety commitments, our Safety team – comprised of Directors, Managers and Advisors, as well as our Vice President of ESR – works to ensure that our assets are constructed, maintained and operated in compliance with applicable local, state and federal environmental, health and safety regulations. Within each of our operations, our Safety Advisors work directly with local personnel to ensure compliance with federal regulations and conformance with Crestwood policies. The Safety Advisors continually monitor our safety and health practices, provide feedback, and make recommendations for continuous improvement. In addition, they also lead incident investigations, conduct safety training, and assist with contractor safety management. We require our contractors to understand, adopt, and adhere to our safety management programs and performance standards. We are resolutely committed to safety and we ensure that any contractor or service provider we work with is equally committed. For more information on our contractor safety metrics, see Supply Chain Management.
We communicate Crestwood’s employee safety procedures and expectations through our corporate Safety Manual, provided via our company intranet. Additionally, our Vice President of ESR holds regular Safety Unplugged virtual meetings and publishes a Safety Scorecard to share best practices and reinforce critical safety protocols, such as Stop Work Authority and the importance of safety training.
Twenty percent of our company’s compensation plan hinges upon Crestwood’s performance on both leading and lagging safety metrics. The leading indicators include near misses, unsafe acts and safe acts, while lagging indicators are Total Recordable Incident Rate (TRIR), Preventable Vehicle Incident Rate (PVIR), Lost Time Incident Rate (LTIR) and Notice of Violation / Notice of Enforcement (NOV/NOE) Count.
A key safety principle is to assemble the right team and ensure they have the right skills to complete their tasks safely. Our Learning Management System (LMS) hosts safety training for all employees, as well as Safety Skills course offerings for applicable employees. The Safety Skills courses include Lock Out Tag Out, Ground Disturbance, Hot Work, Fall Safety, First Aid and CPR. We also provide asset-level in-person training for our employees. We track completion rates of safety training to ensure everyone has received and understands the information. In 2018, almost 100 percent of employees completed our required safety training.
“Our commitment to safety is a deeply held value. No one plans to be unsafe, and through constant evaluation and discussions, we strive to eliminate unsafe acts. That is why we conduct “safety ride-alongs” with drivers, hold an annual Driver’s Summit, conduct face-to-face training and publish a monthly newsletter. Safety is more than just talking points in a meeting, but a mentality that I see throughout the entire company.”
Transportation Trainer for the Northeast
To evaluate the success of our programs, we leverage internal and third-party audits of our process safety management facilities. Our sites receive periodic compliance inspections in addition to our ESR tiered inspection program audits. Our contractors and sub-contractors receive Field Audit Network (FAN) audits, which are conducted following the ISN evaluation tool to standardize the inspection process. FAN is a network within ISN where participating companies share information and findings about contractors performing work for them, through a standardized audit protocol. We plan to conduct five FAN audits in 2019.
To assess the driving behaviors of our transportation fleet, we installed Lytx vehicle cameras in 2018. With this system, one camera faces outward on the road, while the other faces the driver, and they are triggered to record during situations that may indicate risky behavior, such as sudden stops and hard turns. Event data is collected, reviewed, and used for coaching by our ESR team.
We track a number of metrics to measure our performance. Crestwood utilizes a web-based system to record and track all injuries, illnesses, spills, releases, near misses, regulatory inspections, and other metrics related to Environmental, Safety, and Regulatory compliance. The system tracks closure of action items related to investigations, and creates and manages workflows, trend data, and electronic Management of Change (eMOC) processes. All incidents are risk ranked within the incident management system and investigated accordingly. In 2018, we focused our efforts on collecting leading indicator data, including near misses, witnessed unsafe acts and conditions, and witnessed safe acts and conditions. This complements our traditional tracking on incident frequency and severity rates.
In 2018, we achieved significant reductions on a number of our safety metrics, including:
- 9 percent reduction of Total Recordable Incident Rate (TRIR)
- 6 percent reduction of Lost Time Incident Rate (LTIR)
- 59 percent reduction of Preventable Vehicle Incident Rate (PVIR) for employees and contractors
- 67 percent reduction of Notice of Violation (NOV/NOE)
Health & Safety Incident Rates: Employees
Total Recordable Incident Rate (TRIR)
Lost Time Incident Rate (LTIR)
Preventable Vehicle Incident Rate (PVIR)
Health & Safety: Notice of Violation Count
Notice of Violation (NOV/NOE) Count
Health & Safety: Safety Training
Percentage of Employees Who Completed Safety Training
Health & Safety Incident Rates: Contractors
Total Recordable Incident Rate (TRIR)
Number of Preventable Vehicle Incidents
Safety Shares with Safety Unplugged
Communication is an immensely powerful tool when it comes to improving safety at Crestwood. In 2018, we initiated structured monthly Safety Unplugged virtual meetings to communicate our safety incidents, near misses, and best practices across the Company. Crestwood’s Vice President of ESR leads the meetings, illustrating safety and health commitment from top leadership. This program further bolsters our safety culture, and – along with our strong programs and processes – helped to improve our safety performance in 2018.
While we are proud of our safety accomplishments to date, we will never be fully satisfied until we reach zero injuries, illnesses, or incidents. Looking ahead, one area of focus will be improving overall contractor management. We are also in the process of standardizing our safety inspection program to streamline our processes for audits and assessments.
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