How often do the operators within your PSM/RMP covered process(s) actually use their operating procedures? Hourly, Daily, Weekly, Monthly, every three years during refresher training?
How often do we think they should be using their operating procedures?
How many times have you pulled the SOP binder off the shelf to find it covered in dust and not one blemish on any page – in other words, they just sit on a shelf and are there because some government agency requires us to have them?
“Operational Discipline” is a phrase you will not find in the PSM or RMP standards, but it is a significant need in PSM/RMP-covered processes. Simply put, EVERYTHING we do within a covered process is analyzed, then written down in detail, and trained on. NO FREELANCING! And when those occasions arise where we have a situation that an SOP does not cover we use a Safe Work Permitting process or the MOC tool to analyze, write down in detail, and train personnel on how to safely perform the necessary task(s).
When this disciplined approach is taken, SOPs and their content, become valuable and usable documents that are used at least daily; without this disciplined approach, SOP binders become dust collectors and paperweights.
Over the past several years we have been faced with the debate of “in-hand procedures” for the highly critical tasks; this means the SOP is printed and the operator(s) will have the SOP in their hand as they perform the tasks stated in the SOP. Too many organizations think this is foolish until there is an incident or an auditor actually audits the SOPs and training…
It is really unfair to put an operator in this position, but sometimes key points need to be made to demonstrate what operational discipline looks like.
The facility’s current practice is to perform five (5) critical tasks at least daily within a covered process. A look at the SOPs in the control room show zero signs of use; seems the only time they are handled is when the binder is updated each year with the newly approved SOPs. So pick one, just one, and sit down with a randomly chosen operator who is trained on and actually performs the task(s) within the SOP selected. Have them walk through the SOP, step-by-step, explaining how they perform the tasks.
If the SOP contains all of the following minimums (and detailed steps on how to carry out each task):
1910.119(f)(1)(ii) Operating limits:
1910.119(f)(1)(ii)(A) Consequences of deviation; and
1910.119(f)(1)(ii)(B) Steps required to correct or avoid deviation.
1910.119(f)(1)(iii) Safety and health considerations:
1910.119(f)(1)(iii)(A) Properties of, and hazards presented by, the chemicals used in the process;
1910.119(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
1910.119(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs;
1910.119(f)(1)(iii)(D) Quality control for raw materials and control of hazardous chemical inventory levels; and,
1910.119(f)(1)(iii)(E) Any special or unique hazards.
do we actually think that an operator, even if he/she is Albert Einstein’s son/daughter that is a lot of information to recall from memory, remembers each step and all that data? And don’t forget, this is just one SOP – there could be dozens of other SOPs he/she will need to remember as well. Just memorizing the Safe Upper and Lower Limits and the consequences of deviating from those limits can be too much for any ordinary man or woman to recall; much less the detailed steps they will be required to complete to avoid or correct the deviation. And this is an example of “normal operations”, remember we have to have procedures for:
1910.119(f)(1)(i)(A) Initial startup;
1910.119(f)(1)(i)(B) Normal operations;
1910.119(f)(1)(i)(C) Temporary operations;
1910.119(f)(1)(i)(D) Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
1910.119(f)(1)(i)(E) Emergency Operations;
1910.119(f)(1)(i)(F) Normal shutdown; and,
1910.119(f)(1)(i)(G) Startup following a turnaround, or after an emergency shutdown
Folks, there is just NO WAY we should buy into the idea that well-disciplined operations do not involve the DAILY USE of the SOPs. If someone can put forth the argument that the SOPs are not needed for safe operation, then the SOPs are garbage and we are in a worse position.
Many facilities have had over 29 years to get their SOPs to the level of detail necessary to ensure process safety – now it is time to instill OPERATIONAL DISCIPLINE.