Operating Procedures: The Basics

One of the most important PSM elements

In the debate as to which element of process safety is the ‘most important’, operating and maintenance procedures have a claim to priority. Procedures represent the interface between human technicians and the equipment and instruments that they are controlling. If that interface is poorly defined or understood then accidents will take place.

We are starting a short series of posts to do with operating procedures that we hope will help define that important interface.

Importance of Operating Procedures

All regulations and rules to do with process safety management require that operating procedures be written and followed. Regardless of the degree of automation, a human–machine interface will always exist, and that interface will be defined and controlled through the use of procedures.

Not only can high quality procedures help managers and workers achieve safe and efficient operations, but the process of writing the procedures will itself identify better ways of operating and running the operations that they cover. For example, on a multi-shift system it is common for the personnel on each shift to develop their own ways of running the unit. Each method of operation may be acceptable and safe, and the differences between them may be minor. Nevertheless one method will necessarily be superior to the others. The act of writing the procedures can help determine which method to choose, and may even create a way of melding the different approaches.

Properly-written procedures also help establish accountability within an organization. They make it clear as to who is responsible for executing which tasks. This responsibility points in two directions. The technicians need to follow the instructions as written, but management is responsible for publishing procedures that are accurate, timely and usable.

Instructions, Not Suggestions

Operating procedures are instructions — they are not suggestions, guidance or good ideas. Failure to follow written procedures can ultimately be grounds for discipline. This means that, if an operator or maintenance technician believes that an instruction in a procedure is incorrect, then his or her suggestions for improvement should be processed through the Management of Change system. He or she cannot arbitrarily choose not to follow the procedures — with the possible exception of an emergency situation where quick decision-making may be required. On one facility an operator failed to follow a standard procedure regarding locking out a piece of equipment. As a result of his error an incident occurred in which he suffered a serious injury. In spite of his suffering he was still required by his management to take time off without pay because he had failed to follow instructions. That management decision may seem harsh, but it was it was probably just.

However, just as operators and maintenance technicians must follow the procedures, so management is responsible for providing procedures that are clear, succinct, accurate, easy-to-use and that are consistent with the other elements of process safety, particularly training and the information data base. Management is then responsible for for training the operations and maintenance personnel in their use. Hence, if there is an incident that is attributed to an operator failing to follow procedures, it must first be established that the procedure was actually available, that it was correct and usable, and that the operator had been properly trained in its application. Only then is it fair to take disciplinary action.

Strunk and White

In the year 1918 Professor William Strunk, Jr. wrote the book Elements of Style; it was enlarged and updated by E.B. White in 1959. (The fourth edition of the book, usually referred to as ‘Strunk and White’, was published in the year 2000.) Although the book was written all those years ago, the advice in the book should be used by anyone writing operating procedures in the year 2024.

The following quotation lies at the heart of Strunk’s writing philosophy.

Vigorous writing is concise. A sentence should contain no unnecessary words, a paragraph no unnecessary sentences, for the same reason that a drawing should have no unnecessary lines and a machine no unnecessary parts. This requires not that the writer make all his sentences short, or that he avoid all detail and treat his subjects only in outline, but that every word tell.

His use of engineering design as an analogy for writing style should resonate with those writing operating and maintenance procedures. In particular, they should always,

Make every word tell.

It is also important to stress his point that good writing is not the same as short writing. If lots of words are needed, then lots of words should be used.

Red Lights Don’t Stop Cars . . .

. . . Brakes Stop Cars

Operating procedures are a critically important element of a process safety program. However, it is important not to place too much responsibility on the procedures. No matter how well written a procedure may be, and no matter how well trained the operator or maintenance technicians may be in the use of the procedures, the chance of a slip or mistake will always exist. In particular, any procedure that requires a Danger notice is likely to be inherently too risky — the system itself should be re-engineered.

Automation

It might be thought that there is less need for operating procedures on highly automated facilities. Such is not the case because the instruments and control systems must be told exactly what to do; they themselves need procedures. Moreover, procedures for automated systems must be absolutely thorough, complete and accurate. Whereas human beings are capable of filling in gaps in written procedures with a mix of experience, reasoning and common sense, instrument systems are totally dumb; they need to have every step explained to them fully and in detail. Moreover, automated systems are likely to be more complex than those run manually. So, it is even more important to have detailed and accurate procedures.

Further Guidance

For further information to do with operating procedures, please check out our book Process Risk and Reliability Management.