Operating Procedures – We Need Them

Every part of an organization is dependent on documented procedures to mitigate risk and improve productivity and performance. – Deborah Kenny

At Bluefield Process Safety, I have had a chance to work on Standard Operating Procedures (SOPs) for multiple organizations. I have worked with some organizations that either lack SOPs for some or most tasks, or ignore existing ones because they are outdated.

Operating procedures are essential to the safe operation of a facility. The information presented here may seem to be common knowledge, and I would love to hear from anyone in an organization who has amazing operating procedures.  However, that isn’t usually the case.

What is a Standard Operating Procedure?

An SOP is a set of written step-by-step instructions that tells workers how to perform a task. For example, a manufacturing facility might have SOPs for drum handling, the clean out of a reactor, and the operation of pumps, as well as SOPs for normal production processes. When operating procedures are followed they reduce deviations from the designed, intentional actions.

What is the purpose of Standard Operating Procedures?

SOPs aim to achieve efficiency, safety, and quality output. They help provide safe operations. Incorrectly performed steps may ultimately lead to a loss of containment, injuries and fatalities, or both. SOPs create consistency in how processes and tasks are performed. They establish accountability for the task performed and assist in reducing miscommunication. SOPs also help workers achieve efficiency and uniformity of performance, while generating consistent product quality. And, because mistakes can be expensive, SOPs protect profitability.

If the benefits from developing and using SOPs was not enough of a draw, it is important to remember that they are required for regulatory compliance with certain OSHA and EPA regulations.

What are the requirements for SOPs under PSM?

Requirements for compliance with Process Safety Management (PSM) can be found in 29 CFR 1910.119 (3)(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.

(i) Steps for each operating phase:

(A) Initial startup;

(B) Normal operations;

(C) Temporary operations;

(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.

(E) Emergency Operations;

(F) Normal shutdown; and,

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

(ii) Operating limits:

(A) Consequences of deviation; and

(B) Steps required to correct or avoid deviation.

(iii) Safety and health considerations:

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

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

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

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

(E) Any special or unique hazards.

(iv) Safety systems and their functions.

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

(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.

(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.

Regulatory language can be a little dry, so let me highlight some of the important requirements from 29 CFR 1910.119 (3)(f).

  • Procedures are required for all phases of operation, including start-up, shutdown, emergency, normal, and temporary operation.
  • Critical steps in a procedure must include a range for operating limits. Any value in an SOP must have a range around it—upper and lower limits. For steps with operating limits, consequences of deviating those limits and steps for corrective action or to avoid deviation are required. For example, if a step in a procedure was “Begin monomer feed at the starting feed rate,” and had a target rate of 40 lbs/min, the range might be 30 lbs/min – 50 lbs/min, the consequence of deviation may be if too much monomer is added before a reaction is confirmed, monomer can accumulate and result in an uncontrolled reaction.
  • Safety and health information must be included or referenced in the procedure. Safety and health information includes chemical properties and hazards for the chemicals in the process, necessary precautions to prevent exposure, control measures in the event of exposure, quality control, and any unique hazards.
  • Procedures must be current and accurate with an annual review and certification and made accessible to employees.

What are Some Common Pitfalls of Operating Procedures?

While SOPs are extremely beneficial, they can very easily be mismanaged, making them less effective.  Listed below are some common pitfalls of SOPs.

  • Not using them
  • Outdated procedures (incorrect set points or operating conditions, wrong equipment numbers, feedback from personnel not incorporated)
  • Procedures are hard to find
  • The procedure is overly wordy, complex, or includes descriptive language, or conversely the procedure is poorly written, or uses bad grammar,
  • Not knowing when to use SOPs (operation not specified),
  • Not knowing how to use SOPs (lack of proper training),
  • The SOP is too long – long procedures lead to corner-cutting,
  • Mismanagement of SOPs (use of outdated paper-based systems, not maintaining a centralized location for operating procedure retrieval and modification, not effectively tracking changes made in new revisions) so that the current version is not the one used

An effective SOP is one that is well written, properly updated, well defined, and well maintained.  If employees are properly trained and SOPs are effective, an organization can achieve the efficient, safe, and quality output the SOPs are designed to produce.

What’s the solution?

Is your organization lacking good SOPs? Could your SOPs use some work? If you want better SOPs, there is no magic solution. It will take time and effort. Because a lot of time and effort is required, it’s crucial to get backing from management.  Without management backing, the necessary time won’t be allocated. Most importantly, make sure to own the problem; if your procedures need work, admit it.

If you are developing or updating your companies’ SOPs and you get a stuck, here are a couple of good references to check out:

AIChE CCPS reference book: Guidelines for Writing Effective Operating and Maintenance Procedures

Sutton Technical Book: Process Risk and Reliability Management 2nd Ed. Or Ebook, Operating Procedures

 

Leave A Comment