GREY PAPERS
Process safety is a solved problem that keeps happening.
The frameworks that prevent major process safety incidents are well understood. The persistent gap is in how they are governed, applied, and learned from. A grey paper sits between a journal article and a book — long enough to develop a complete framework, short enough to read in a sitting. These are not opinion pieces or predictions. Each one examines a specific process safety challenge through the lens of what actually works, drawn from 44 years in chemical and pharmaceutical manufacturing and two CCPS standard-of-care publications.
The papers below are organized by the audience they serve. Each develops a single framework in depth, anchors it in documented industry experience, and closes with the questions a leader in that role should be asking. Read the one that speaks to your responsibility — or read all three, since the failures they describe are connected.
CATEGORY 1 — GOVERNANCE & LEADERSHIP
For boards of directors, CEOs, general counsel, and senior operations executives.
The Board’s Blind Spot
Directors who oversee financial risk with rigor but accept process safety reporting at face value.
Boards apply rigorous discipline to financial oversight yet frequently accept process safety reporting at face value. This paper examines why that blind spot persists, what good process safety governance actually looks like, and the structural disciplines — approving risk criteria, receiving leading indicators, obtaining independent audit findings, and holding the CEO accountable — that close the gap. Includes a board governance checklist, a phased implementation roadmap, and the questions directors and executives should be asking.
WHO SHOULD READ IT: Board directors, CEOs, general counsel, COOs and VPs of Operations
LENGTH: 12 pages · ~20 minute read
Related service: Board & Executive Consulting
CATEGORY 2 — OUTSOURCED MANUFACTURING
For procurement, legal, and operations leaders on both sides of the contract-manufacturing relationship.
Process Safety Due Diligence in CM Selection
What pharma and chemical companies should be asking before they sign the contract — not after the incident.
In outsourced manufacturing, process safety failures do not respect contract boundaries — both the contracting company and the contract manufacturer can bear responsibility. This paper lays out a four-phase due diligence framework and shows where it breaks down on both sides of the relationship, drawing on documented incidents. Includes self-evaluation tools, dual due-diligence checklists for each party, and the questions each side should ask before committing.
WHO SHOULD READ IT: Procurement, legal, operations, and executives at contracting companies and contract manufacturers
LENGTH: 13 pages · ~22 minute read
Related service: Outsourced Manufacturing Safety
CATEGORY 3 — INVESTIGATION & LEARNING
For operations leaders and process safety professionals responsible for investigation and continuous improvement.
Process Safety and the Learning Organization
Connecting investigation findings to systemic improvement at the right level of the organization.
Most investigations produce corrective actions that close in a tracking system but do not prevent the next incident, because they stop at the immediate cause and never reach the management system failure behind it. This paper presents the seven-step Root Cause Investigation and Analysis (RCIA) framework, explains how to match corrective actions to the right organizational level, and shows how senior leadership review turns investigations into organization-wide learning. Includes the seven-step process, a learning-summary template, and diagnostic questions for both operations leaders and process safety professionals.
WHO SHOULD READ IT: Plant managers, site directors, VPs of Operations, COOs, and process safety professionals
LENGTH: 14 pages · ~24 minute read
Related service: Incident Investigation & Root Cause Analysis