Operating Procedures

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Operating Procedures )

What the regulation says:

(f)(1)The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.

(f)(1)(i) Steps for each operating phase:

(f)(1)(i)(A) Initial startup;

(f)(1)(i)(B) Normal operations;

(f)(1)(i)(C) Temporary operations;

(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.

(f)(1)(i)(E) Emergency Operations;

(f)(1)(i)(F) Normal shutdown; and,

(f)(1)(i)(G) Startup following a turnaround, or after an emergency shutdown.

(f)(1)(ii) Operating limits:

(f)(1)(ii)(A) Consequences of deviation; and

(f)(1)(ii)(B) Steps required to correct or avoid deviation.

(f)(1)(iii) Safety and health considerations:

(f)(1)(iii)(A) Properties of, and hazards presented by, the chemicals used in the process;

(f)(1)(iii)(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;

(f)(1)(iii)(C) Control measures to be taken if physical contact or airborne exposure occurs;

(f)(1)(iii)(D) Quality control for raw materials and control of hazardous chemical inventory levels; and,

(f)(1)(iii)(E) Any special or unique hazards.

(f)(1)(iv) Safety systems and their functions.

(f)(2) Operating procedures shall be readily accessible to employees who work in or maintain a process.

(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.

(f)(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.

What it means:

	Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. The process safety information package is to be used as a resource to better assure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are accurate. Operating procedures should be reviewed by engineering staff and operating personnel to ensure that they are accurate and provide practical instructions on how to actually carry out job duties safely.
	Operating procedures will include specific instructions or details on what steps are to be taken or followed in carrying out the stated procedures. These operating instructions for each procedure should include the applicable safety precautions and should contain appropriate information on safety implications. For example, the operating procedures addressing operating parameters will contain operating instructions about pressure limits, temperature ranges, what to do when an upset condition occurs, what alarms and instruments are pertinent if an upset condition occurs, and other subjects. Another example of using operating instructions to properly implement operating procedures is in starting up or shutting down the process. In these cases, different parameters will be required from those of normal operation. These operating instructions need to clearly indicate the distinctions between startup and normal operations such as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also the operating instructions need to describe the proper method for increasing the temperature of the unit until the normal operating temperature parameters are achieved.
	Computerized process control systems add complexity to operating instructions. These operating instructions need to describe the logic of the software as well as the relationship between the equipment and the control system; otherwise, it may not be apparent to the operator.
	Operating procedures and instructions are important for training operating personnel. The operating procedures are often called standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English then procedures and instructions need to be prepared in a second language understood by the workers. In addition, operating procedures need to be changed when there is a change in the process as a result of the management of change procedures. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from one manufacturer to another or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shutdown in order to make a change, then the operating procedures must be updated before startup of the process.
	Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between operating personnel and workers performing work within the process area, such as non-routine tasks, also must be maintained. The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job.

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