Both OSHA’s and EPA’s process safety standards require operating procedures to contain the “steps required to correct or avoid deviation(s)”, but what exactly does this mean? I really wish OSHA/EPA would have phrased it as “avoid or correct” as putting the words in this order is actual reality. Let’s look at a simple process set-up where the process has two (2) alarm levels:
1) Hi-Level Alarm, and
2) Hi-Hi-Level Alarm
When the operator gets the hi-level alarm, he/she responds to this first alarm with the intent of AVOIDING the deviation. The process has NOT YET gone into a “deviated state” (i.e. has not exceeded the safe upper level), so the steps taken are actually to AVOID the deviation of “exceeding safe upper level”.