Specific requirements exist in all Safety Management Systems Guidelines/Requirements (e.g., Process Safety Management, Risk Management Program, Safety and Environmental Management Systems) for the creation, content, quality review, and periodic update/certification of Operating Procedures. However, the creation and actual implementation of Operating Procedures is fraught with challenges that often result in safety deficiencies, regulatory citations, and in some cases, unfortunate tragedies.
Although Operating Procedures concepts involve the straightforward documentation of specific steps and precautions to take for safe and effective operation, many process facilities struggle with:
- securing the focus and specific content from operations personnel for the creation of quality procedures
- securing feedback from operations personnel if procedural steps do no coincide with actual practices
- ensuring the steps outlined in procedures avoid introducing additional process hazards
- creating procedures that are in a user-friendly format and written to facilitate training and understanding
- identifying the most effective level of information and depth to include in the procedure
- determining sensible levels of detail for consequences of deviation and the appropriate corrective actions
- implementing meaningful competency testing
- assigning the correct "skill set" to the development and update of Operating Procedures
- addressing all modes of operations, including defining appropriate responsibilities
Beyond the requirements, good-quality Operating Procedures are critical for encapsulating operational best practices for all of the different operating modes that the process may have to address and also provided a basis for ensuring consistent quality assurance. The objective of this paper is to convey an understanding of the challenges that must be considered with the development of Operating Procedures and provide tips and specific examples that will facilitate the creation and ongoing application of this important element of Safety Management Systems.
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