Guidelines for Writing Effective Operating and Maintenance Procedures

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• Publisher: Wiley-AIChE
• Year: 2011
• Print ISBN: 9780816906581
• eBook ISBN: 9781118215616
• Edition: 1
• Topic: Technology & Engineering
• Subtopic: Chemical & Biochemical Engineering
• Index: Technology & Engineering

The EPA investigation of a 1994 chemical plant tragedy concluded that "the explosion resulted from a lack of written safe operating procedures…" While good written procedures can't guarantee zero accidents, they can reduce the number of accidents caused by human error. This new book shows how to remedy this problem through selecting and implementing actions that promote safe, efficient operations and maintenance, improve quality, continuity, profitability and cost control, build upon and record process experience, and promote the concept that operating and maintenance procedures are vital plant components. It includes practical samples of procedure formats, checklists and many references.

CHAPTER 1

INTRODUCTION TO EFFECTIVE PROCEDURE WRITING

1.1. Why Was This Book Written?

Pick up a dictionary and find the entry for procedure. One definition is: a particular course or mode of action. A simple statement, but to procedure users, writers, and managers concerned with process safety, the word procedure implies much more. The Center for Chemical Process Safety’s approach to Process Safety Management relies on written procedures to document both hands-on operations and maintenance activities as well as to describe the Process Safety Management system itself. This book was written to help select and implement actions that will

• Help reduce accidents
• Promote safe, efficient operation and maintenance
• Improve quality, continuity, profitability, and cost control
• Build upon and record process experience
• Help maintain your competitive edge
• Reflect the best thinking on how to safely operate and manage your facility
• Comply with governmental regulations or industrial initiatives requiring written procedures
• Promote the idea that operating and maintenance procedures are vital plant components

The last item, treating procedures as if they were equipment (just like a pump, valve, reactor, or safety system), is fundamental for building a successful Process Safety Management system. Who would start up a new process without all of the pumps in place and tested? What craftsperson would tackle a pump seal replacement without the required tools and parts? By accepting this idea, that procedures are components, the concepts presented in this book will naturally fall into place.

Effectively written procedures can help to ensure the smooth startup of a new process or help solve a tricky problem. A large company with many sites can share procedures between plants with similar processes. A single site can gain by capturing temporary or seldom performed activities on paper for future use. Reinventing the wheel takes time that is better spent on productive activities.

Developing written procedures forces you to analyze your process, resulting in a better understanding of how to improve it. Safer, more efficient operations and maintenance follow, resulting in enhanced quality, decreased downtime, and lower costs.

Will effective procedures guarantee that your plant can avoid all accidents? No, they won’t and they can’t. However, as a component of your process safety management system, effective use of procedures can reduce the number of accidents caused by human error. Sound management practices encourage written procedures, and regulations now demand them for many processes. The purpose of this book is to make your procedure-writing efforts as productive as possible and to create accurate, effective procedures.

1.2. Book Objectives

There are three objectives for this book. Keep them in mind as you use this book. This book will

• Guide readers in developing effective written procedures to operate and maintain both large and small facilities
• Encourage development of procedure management systems that involve the users, emphasize control of the procedures, and require management and employee commitment to procedure use, accessibility, training, and management of change
• Help procedure writers produce effective, usable procedures that support safe and efficient operations and maintenance through improved communication

1.3. The Current Worldwide Trend Toward Procedures

Operating and maintenance procedures have become an international issue. Europe, Canada, and the United States have all issued or proposed regulations that require procedures for process safety purposes. Industry groups supporting offshore oil exploration have also recognized the value of procedures to improve process safety. The International Organization for Standardization (ISO) includes the control and use of procedures as a key element of a company’s quality management system. These influences affect more companies each year as they seek a global market for their products.

In the United States, the impact of the Occupational Safety and Health Administration’s (OSHA) Rule 29 CFR 1910.119 “Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule” and/or the Environmental Protection Agency’s (EPA) Proposed Rule 40 CFR Part 68 “Risk Management Programs for Chemical Accidental Release Prevention” is already being felt. Developing, training on, and maintaining the required written operating and maintenance procedures is a significant effort. This work represents a major and critical share of the total compliance effort these regulations demand. Your written procedures link the human component to the process.

Even before these regulations existed, groups such as the American Institute of Chemical Engineers’ Center for Chemical Process Safety (CCPS), the Institution of Chemical Engineers (IChE), the Chemical Manufacturers Association (CMA), and the American Petroleum Institute (API) all promoted written procedures as a sound management practice. This practice, if firmly held, can lead to improved plant safety and product quality. Table 1-1 lists some organizations and documents that recommend or require procedures.

TABLE 1-1
Organizations and Documents Recommending or Requiring Procedures

ORGANIZATION	DOCUMENT
AIChE Center for Chemical Process Safety (AIChE/CCPS)	Guidelines for Technical Management of Chemical Process Safety, AIChE/CCPS, New York, New York 1989.
American Petroleum Institute (API)	API Recommended Practice 750, Management of Process Hazards, American Petroleum Institute, Washington, DC, 1990.
Chemical Manufacturers Association (CMA)	Responsible Care®: A Public Commitment, Chemical Manufacturers Association, Washington, DC, 1988.
U.S. Environmental Protection Agency (EPA)	Risk Management Programs for Chemical Accidental Release Prevention; Proposed Rule 40 CFR part 68, Environmental Protection Agency, Washington, DC, 1993.
International Organization for Standardization (ISO) or in the United States of America American National Standards Institute (ANSI) 9000-1, 9001, 9002, 9003, 9004-1	Quality Management and Quality Assurance Standards (9000) ISO 9000-ISO 9004, Quality Systems—Models for Quality Assurance (9001-9003) Quality Management and Quality System Elements—Guidelines (9004) International Organization for Standardization, Geneva, Switzerland 1987.
US Occupational Safety and Health Administration, US Department of Labor (OSHA)	Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule 29 CFR 1910.119, Occupational Safety and Health Administration, Washington, DC, 1992.
Organization for Economic Cooperation and Development (OECD)	Workshop on Prevention of Accidents Involving Hazardous Substances Good Management Practice, Discussion Document Relating to the Development of OECD Guideline for the Prevention of Accidents Involving Hazardous Substances, Organization for Economic Cooperation and Development, Berlin, 1989.
Official Journal of the European Communities	Council Directive of 24 June 1982 (the Seveso Directive) on the Major-Accident Hazards of Certain Industrial Activities, Official Journal of the European Communities, Berlin, 1989.
The World Bank	Manual of Industrial Hazard Assessment Techniques, The World Bank, Washington, DC 1985.

Whether a guideline, a regulation, or a recommended practice and whether for process safety, environmental, or quality reasons, a strong operating and maintenance procedure system will benefit your company.

1.4. Who Should Use This Book?

Anyone who needs procedures to ensure safe operations will benefit from using this book. Operating and maintenance procedures are important tools for many industries, especially those using or manufacturing chemicals. Refineries, commodity chemical plants, waste processors, plastics manufacturers, specialty chemical plants, and agricultural chemical processes—these all are obvious examples of processes that may use chemicals. Other, less obvious facilities with process safety and quality concerns include the food and beverage industry, pharmaceutical plants, pulp and paper plants, water and sewage treatment plants, utilities, household products plants, and many factories that manufacture everyday items.

Developing procedures is a team effort. The following functions at your facility will benefit from written procedures.

• Operations and Maintenance—Operators and maintenanc...

Table of contents

• Cover
• Half Title page
• Title page
• Copyright page
• Preface
• Acknowledgements
• Glossary
• Chapter 1: Introduction to Effective Procedure Writing
• Chapter 2: Process Safety, Environmental, and Quality Considerations
• Chapter 3: How to Design an Operating and Maintenance Procedure Management System
• Chapter 4: Writing Operating and Maintenance Procedures
• Chapter 5: Elements of Effective Procedures
• Chapter 6: Writing Emergency Operating Procedures
• Chapter 7: Procedure Control
• Chapter 8: Procedure Development Costs and Benefits
• Appendix A: Selected Procedure Initiatives, Consensus Codes, and Regulations Affecting Procedures
• Appendix B: Common Points of API, OSHA, and EPA
• Appendix C: How to Determine the Tasks That Require Written Procedures
• Appendix D: Procedure Performance Evaluation
• Appendix E: Procedure Criteria Checklist
• Appendix F: Sample Procedure Formats
• Appendix G: Sample Formats of Operating Limits Tables
• General References
• Index