Operating Procedures: Common Difficulties

This post is the third in a series to do with Operating and Maintenance Procedures. The first two posts are Operating Procedures: The Basics’ and ‘Operating Procedures: Don’t Ask Too Much’.

In this post we look at some of the difficulties to do with the writing, publication and the use of operating procedures.

Difficulties with Procedures

In spite of their importance, the operating and maintenance procedures in many facilities are inadequate. All too often they are difficult to use, not detailed enough (or too detailed), out of date, and incomplete (or even missing altogether). Regulatory agencies and auditors frequently cite operating procedures as being deficient. Similarly, incident investigations often find that problems with procedures were an important factor when things go awry.

The fact that procedures may be unsatisfactory does not necessarily lead to problems in normal operations. Most of the time, the operators and maintenance personnel know what to do due to their familiarity with the tasks that they are carrying out.

In some cases, the technicians may deliberately ignore the written procedures. I once worked at an oil refinery that used large quantities of hydrogen fluoride (HF) ― a highly toxic material. The HF was delivered in bulk by a rail tank car. The procedures for unloading the HF were not only out of date, they contained errors. In fact, if an operator followed the procedures exactly as written, there would have been a release of HF ― guaranteed. This error in the procedures ‘didn’t matter’ because ‘no one followed the procedures’. But the risk associated with situations such as this can hardly be exaggerated.

Because the procedures may not be used much during normal, routine operations, it is tempting to put off the effort needed to write them and then keep them up to date. The writing of procedures tends to be given low priority; management puts off the hard work of doing so until ‘we have sufficient time’. Even when good procedures are available, their update and maintenance tends to be of low priority. Hence, they may fall out of date; consequently operators and maintenance technicians lose confidence in them.

Another reason for difficulties with procedures is that the effort required to write and maintain them is often more difficult, time-consuming and expensive that management expects. At first sight, it would appear as if writing procedures, particularly for a facility that is already in operation would be quite simple. All that is needed ― it would seem ― is to write down how the facility is currently being operated and maintained, and then to format the resulting information using a standard protocol.

However those who actually write procedures find that the task is not so simple. In particular, extracting and organizing information can be surprisingly difficult. Doing so involves reviewing engineering documentation (which may be missing, out of date or hard to locate), interviewing technicians (who are not always effective at articulately explaining their work and responsibilities), and observing actual operations that can be difficult to follow, particularly for writers who are not familiar with the intricacies of those operations. Information to do with safe operating limits can be particularly difficult to obtain. Yet it is vital to know those limits, particularly when writing troubleshooting and emergency procedures.

Testing the Procedures

Much of the published literature to do with procedures-writing is written for the software business. In that environment it is feasible to write procedures, and then deliberately make mistakes to ‘see what happens’. Such is not the case on a process or energy facility. It is neither safe nor sensible to ask a technician to deliberately take a wrong action. If the procedures for running a computer program are incorrect then there will be a delay in the final implementation of the program. Serious mistakes in the procedures for drilling a high pressure gas well, say, are not correctible; those procedures must be correct the first time that they are used.

It’s a Project

Because writing and publishing procedures tends to be more time-consuming and expensive than expected, management may fail to dedicate sufficient resources to the effort. For example they may ask an engineer or supervisor to work on the procedures ‘in your spare time’. Such an approach is virtually certain to fail. The writing and maintenance of procedures needs to be treated as a full-fledged project that is assigned a budget, a schedule and a properly qualified team.

Skill Sets

Another difficulty to do with the writing of procedures is that the people who run the facility may have trouble expressing their ideas in writing, while those are good at writing do not have in-depth knowledge to do with the operations. This can create a dilemma for the project manager.

I was once in such a situation. We came up with a response which worked well. The facility was a medium-sized oil refinery whose operating procedures were woefully inadequate. We brought a recently retired supervisor to work with me. (The advantage of having a retiree was that he was ‘mine’ ― he was not being continually pulled away for other duties.)

I started the procedures-writing by asking him how he started his day at the unit for which he was responsible. He said, “I climb Column-100 and look around to make sure that everything is OK”. So I asked him what he meant by the term ‘OK’. This led to silence ― what he was looking for, of course, was steam leaks, maintenance jobs not properly secured, vehicles in the wrong locations, and other warning signs. But this was the first time that he had had to verbalize his actions and his many years of experience.

We proceeded in this manner for a number of days, until we wound up with a good set of procedures. (I should add that the supervisor enjoyed the project, which he would not have done had he been told to write the procedures by himself.)

Design Phase

Most literature to do with the writing of procedures assumes that the facility in question actually exists ― that is up and running. However, those working on the design and engineering of new facilities also have to write procedures, and this can be a challenge because there is no operating experience on which to draw. Consequently, we see statements such as, ‘Heat Exchanger E-101 is designed to cool the boiler blowdown’. This statement is to do with a system that does not yet exist. Is should read, ‘Heat Exchanger E-101 cools the boiler blowdown’.

The topic of writing procedures during the design phase is probably worth a post in its own right.

Further Guidance

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