“I found that the recipes in most – in all – the books I had were really not adequate. They didn’t tell you enough…I won’t do anything unless I’m told why I’m doing it. So I felt that we needed fuller explanations so that if you followed one of these recipes, it should turn out exactly right.” — Julia Child
My first exposure to batch procedures was as a kid, when I used my mom’s copy of the Betty Crocker’s Cookbook, the ring-bound version that laid flat on the counter. Each recipe started with a list of ingredients. If I was missing anything, there was a section with a handy guide of substitutes. Then there were the preliminary steps: “Heat oven to 350° (med.).”, “Grease and flour two-layer pans, 8 or 9 x 1½” or an oblong pan, 13 x 9 x 2”, for example.
Once I had the ingredients gathered and performed the preliminary steps, I could begin actually processing. First, the recipe told me what ingredients to charge and in what order: “Sift together (the dry ingredients)”, “Add (the liquid ingredients)”. It assumed that I knew what size of mixing bowl to use, however. Then the recipe gave me a sequence of processing steps: “Beat 2 min., medium speed”, “Scrape sides and bottom of bowl constantly”, “Pour into pans”, “Bake X min., or until cake tests done”, “Cool”, and “Frost”. I loved that there was a quality control test in the recipe – “or until cake tests done” – but I was never confident that I was doing the test (described elsewhere, not in the recipe) correctly.
Betty Crocker taught me what to expect from a batch procedure. That’s probably true for a lot of us.
A Betty Crocker recipe, however, would not meet the requirements that the Process Safety Management (PSM) standard establishes for operating procedures.
PSM Requirements to Address Operating Phases
The fourth element of the PSM standard, 29 CFR 1910.119, addresses operating procedures in paragraph (f). The standard starts by listing seven operating phases that must be addressed by operating procedures:
A. Initial startup
B. Normal operations
C. Temporary operations
D. Emergency shutdown
E. Emergency operations
F. Normal shutdown
G. Startup following a turnaround, or after an emergency shutdown
Arguably, a Betty Crocker recipe addresses Initial startup (preheat the oven, grease and flour the pans), Normal operations, Temporary operations (the list of substitutions, the choices of pan sizes), and Normal shutdown (Cool, frost). However, Betty Crocker is completely silent on the subjects of Emergency shutdown, Emergency operations, and Startup following a turnaround or after an emergency shutdown.
Apparently, Betty Crocker cooks don’t have emergencies.
The absence of these operating phases from many operating procedures used in the chemical process industries may be a consequence of their absence from most cookbooks.
PSM Requirements for Operating Procedures
Operating procedures that comply with the requirements of the PSM standard not only address the seven operating phases, they also include certain types of information:
- Operating limits, including consequences of going outside those limits and steps required to correct or avoid going outside those limits
- Safety and health considerations including, among other things, the properties and hazards of the materials in the process, and any special or unique hazards, as well as the necessary precautions and control measures for dealing with all of these hazards.
- Safety systems and their functions.
Of these, a common challenge is in writing operating procedures in terms of operating limits rather than just operating targets. After all, Betty Crocker lists “6 eggs” in the ingredients and “350°” in the preheat instructions, not “5 to 7 eggs” or “332.5 to 367.5°”. And it certainly doesn’t offer any advice on what to do if we go outside of those limits.
However, the PSM standard is asking us to put a safe range around that every target in our operating procedures.
Operating Procedures Better Be Right
There are too many cooks and chefs who say, “I hate recipes,” or “Recipes are just starting points—express yourself.” That approach definitely doesn’t fly with OSHA. If an OSHA inspector were to hear an operator say, “Yeah, that’s the procedure, but that’s not how we do it,” that would almost guarantee a citation for violating 29 CFR 1910.119(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.
But Wait, There’s More
In addition to addressing the need for operating procedures for seven distinct operating phases (and what they should contain), OSHA has also used 29 CFR 1910.119(f) to require a separate set of safe work practices. These are listed in 29 CFR 1910.119(f)(4).
Although the list starts of with the phrase “such as”, OSHA expects these specific safe work practices:
- Lockout/tagout (which is already required by 29 CFR 1910.147);
- Confined space entry (which is already required by 29 CFR 1910.146);
- Opening process equipment or piping (which is also already required by 29 CFR 1910.147; and
- Control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel (which is already required in the PSM standard for contractors, in 29 CFR 1910.119(h)(2)(iv) ).
I’m not sure why OSHA repeats these requirements in 29 CFR 1910.119(f) when they already exist elsewhere. I hope it is not simply to give them the opportunity to cite a violation twice.
Complying with OSHA’s Requirements
Learning to comply with OSHA’s requirements for operating procedures has ruined cookbooks for me. I see a list of ingredients with amounts and wonder “plus or minus how much?” I see a temperature and immediately wonder, “Within what limits?” And if I am interrupted in the middle of preparing a recipe, what exactly am I supposed to do? And when I get back to the kitchen, how do I resume? Cookbooks don’t tell me.
When what we’ve learned about operating procedures comes exclusively from cookbook recipes, we are not going to be able to comply with OSHA’s requirements. For some of us, it will be enough to supplement what we’ve learned from cookbooks about formatting recipes with OSHA’s additional requirements. For others of us, it is going to mean setting aside what we’ve learned from Betty Crocker and developing a fresh format designed specifically to meet OSHA’s requirements.
