Over the years we have seen a very large movement to skinny down PSM/RMP operating procedures. At first glance this movement makes a lot of sense; but with any great idea comes pitfalls and it is the pitfalls that I would like to discuss in this posting. Recently we came across the end results of this movement gone awry… an SOP that had been annually certified but yet contained not one piece of the required data – EVERYTHING was either referenced or linked to other documents. I mean even the tasks listing in how to carry out the procedure referenced the JSA that had been done for the job. An SOP that would have been 10 or so pages was a single sided 8.5X11″ piece of paper. And they did this to the vast majority of their procedures. So of course the facility defends their position saying that it is a “common practice” in industry to do this referencing and therefore was a “generally accepted practice” – yes they even created a new term for it! So rather than argue the fundamentals I began to test the references and links and as I expected there were serious problems. From broken links – to out of date data, they ended up with well over 100 deficiencies with their SOPs and that was just me spending 3 hours reviewing their SOPs; imagine what I could have found had I had six months to do the inspection. Here are a few things to consider when referencing or linking other documents to the SOPs in order to meet the content requirements of 1910.119(d) and (f)…