We have come long ways with our SOPs over the past 20 years! But we still struggle with annual certifications of these SOPs. If anyone is a non-believer in what I am going to share with you in this article I encourage them to just randomly grab any SOP from your system and walk it down step by step and see if the procedure is 100% accurate and is 100% correct in the way operators actually do the task. Non-believers will be surprised as to the outcome, but it is a turning point in how facilities manage their SOP Annual Certifications.
There are literally hundreds of ways a facility can “annually certify” their SOPs, but I am a firm believer in the method I am going to lay out here. This is NOT saying a different method is wrong, but this method has been tested many times by some of the best process safety experts in the industry.
Step 1 – Setting up system
The number of SOPs a facility will have for a similar process can vary greatly from facility to facility, but none the less, EACH ONE has to be certified on an annual basis. So to make this simple to explain lets use a random number of 100 SOPs. Knowing that some of the SOPs will be 2 pages and some will be 20 pages, I need to consider this in my annual review system. I also take two months out of the year, as we know that it is hard to get much done in November and December due to an increase in personnel vacations and shortened work periods. So this leaves us 10 months to review and annual certify 100 SOPs. In the most simplistic terms, that is 10 SOPs each month that we will be reviewing and certifying. Again is it important to balance out the complexity and length of these SOPs so that we balance the work load over the 10 months.
Step 2 – Walk it down!
The foundation of our review and certification process is having the operators walk down the entire SOP, step by step to ensure that it accurately reflects what is to be done and how it is to be done. Items that tend to fall through the cracks:
a) SOP states to open/close a valve, but the valve requires a scissor lift to reach, but the site policy forbids this equipment from entering the area without a specialized permit.
b) SOP states to verify that process pressure is below X and this is to be verified by using PI-001 gauge. Using the P&ID, we go to the location where PI-001 is to be located and there is no gauge and the operator tells us there has not been one there since he has worked at the facility (8 years!). Also we find that gauges are not of the proper scale to be used as defined in the SOP. For example, pressure is to be verified at 165 psi, but the gauge in place only goes to 125 psi.
c) Verify that the PPE prescribed in the SOP is available to the operators.
Operators complete their walk-down and verify that it is exactly how they do the task and everything is accurately depicted in the correct order (if sequence is a critical parameter). They sign off on their review and then provide this signed SOP to the certifying official. It is VERY IMPORTANT to stress that the official review is done by the people who execute the SOP and the “certification” is based on their assessment of the SOP. Who better to assess the SOP than by the very people who execute the SOP? This helps ensure that your SOPs reflect actual activity and validate that this is the way the workers carry out their task. All too often we find SOPs that were written by engineers and then annually certified by engineers – only to find out that operators very rarely used the SOPs or even remotely did the work as prescribed in the SOPs. Having the engineers certify the SOPs is totally acceptable, but having them do the review and certification within a vacuum without operator input is just asking for increased scrutiny.
Step 3 – Should EHS be involved in the SOP Review?
This is a loaded question, but with a simple answer… YES! I cannot even count the number of times that an incident investigation uncovers actions that the operator is told and trained to take that conflict with a site EHS policy!!!! I would also like to point out that any facility that has to comply with PSM, must also comply with 1910.132(d)(1), which states:
1910.132(d)(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits each affected employee. Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.
What does this mean? It means that the tasks being carried out by our operators in these SOPs need to be assessed for PPE needs. In other words, we need to be able to explain where the PPE requirements in the SOPs came from. OSHA will be looking back to our “certified hazard assessments” to validate this part of our SOPs. Without some type of evidence to document that the SOP PPE requirements came from a certified assessment may be a compliance issue under your PSM inspection.
So SOP annual certification is more than signing a single sheet of paper that states all the SOP are accurate. This annual activity is a critical path to process safety and demands ample resources and attention to ensure a level of detail is obtained in order to achieve the level of process safety we expect from our management system.