“It is beyond a doubt that all our knowledge begins with experience.”- Immanuel Kant

In the hustle and bustle of our modern world, we take shortcuts to save time with minimal risks. Look at how we consume entertainment.  The NFL Red Zone is popular since it gives fans a continual highlight reel of their favorite teams without having to watch tedious parts in between.  While podcasts can be sped up on most mobile apps for those who cannot wait because no one has time to keep up with every subscription. There is even a service that will give you the SparkNotes version of nonfiction books.  With that in mind, it is no wonder not all pertinent information we use daily gets documented for other’s use.

Looking for Knowledge in All the Wrong Places

I have had the privilege to work in a few different industries, and there has been a certain commonality in each position I held that drives me up the wall: Tribal Knowledge.  There seems to be information tidbits missing from documentation that are used to perform essential parts of the job. These pieces either can be found out by asking a more experienced member of the team or by spending extra time figuring it out for yourself.  Seems quite counterintuitive to me.  I have asked the same question every time after I have dug for the information:  Why hasn’t it been written down?

Tribal knowledge is normally defined as any unwritten information that is not commonly known by others within a company.  The “tribe” can be a group of employees that have extensive experience or time within the company, like specialists or managers that have been promoted internally.  This knowledge is useful but requires those who have it to relay it person-to-person. In contrast, written procedures have the information available at all times of the day.  The main purpose of having written procedures in a workplace is so that uniform work can be done.  If the work involves hazards, the documentation should address them so that the employee completing the task can make sure it is done safely.  As they continue to work on a process or job, discoveries can be made that make the unit or job run smoother or safer.  In those situations, it is advantageous to add the new information and have the procedure revised and updated.  What normally happens is that this information gets lodged in the mind of the person who found it and they continue working as updating paperwork is never convenient.  Then, the employee either moves on or up and a new employee uses what is on the books, however outdated.  No matter how inconvenient, written documentation allows for an easier transfer of knowledge to those unfamiliar.

Photo Credit: Daniel McCullough via Unsplash

OSHA’s World: Better if Written Down

In the process safety world, OSHA and the EPA require plenty of documentation to be available for their PSM and RMP audits.  However, there are regulations that do not mention how they should be implemented in detail, just that they need to exist for the PSM standard.  Emergency Action Plans and mechanical integrity inspections to name two.

Emergency Action Plans

According to PSM Standard CFR 1910.119(n), an Emergency Action Plan is required, but only needs to be written when the employer has 10 or more employees (CFR 1910.38(b)) or when complying with Hazardous Waste Operation Emergency Response (HazWOpER).  The EPA RMP standard requires more specific information to be included (a plan, procedures for equipment, training, and update procedures), but if you are not covered by that standard, I would not brush a detailed approach aside.  The benefits of documenting your plan in detail allows it to be present to all current and future employees, and if used for training or drills before an actual emergency; it can allow for calmer and collected execution.  Additionally, it would allow the individuals responsible for coordinating to communicate with emergency service personnel to ensure that both parties are aware of possible hazards and resources that can be used.  A practice where the plan is routinely reviewed with a group from the local emergency services would also benefit if the plan were continually updated and documented.

Preventative Maintenance

The Mechanical Integrity section of the PSM Standard (1910.119(j)(4)(ii)) requires that “[i]nspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices.”  Good engineering practices and manufacturers’ recommendations can cover the essential elements, but it would be smart to have the company’s maintenance practices compiled, even if the information is readily available from equipment manufacturers to make the preparation for auditing easier, especially if you plan to count routine work or inspections as a possible safeguard during a Process Hazard Analysis.  It can also benefit training, as other operators and technicians will have a standard to work with.

Balance is Key

Keeping those suggestions in mind, it all comes down to the individuals involved to decide if the new information is worth adding.  A small change that is more a preference of the employee which fits within in the scope of current documentation should not require a change.  Most big changes to fit new equipment or changes to the process would require a Management of Change (MOC).  That would include an update to the required documentation.  Anywhere between those extremes could become useful if the current operator is unavailable to be reached when those processes or tasks must be performed.

Writing Can Have A Big Impact

These are to name a couple places where an extra effort in documenting tribal knowledge can go a long way.  I imagine you can think of other areas where information is floating out there, waiting to be communicated to those next in line.  I have made a habit to take the opposite of trail etiquette into the working world: leave a trace.  If you know that the way functions are carried out do not match what is in the record, it might be worth checking what other information could be added.  Who knows?  It might be that there is money left on the table to run your process with greater efficiency and safety.  It could be possible that a few small changes can make everyone’s life on the line a little bit easier.  Consider what changes have been made to how units or processes run versus what is written in SOPs, maintenance procedures, or if new hazards have been taken into account, but not documented.  Documentation, like the process itself, evolves and improves throughout its lifespan, so take the inconvenient time to prevent new eyes from spending more.