1

INTRODUCTION TO
EFFECTIVE PROCEDURE
WRITING
1.1. Why was Thls Book Wrltten?
Pickup 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 concemed 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
lmprove 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 govemmental 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
1
2 1. INTRODUCTION TO EFFECTIVE PROCEDURE WRITINO
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 sea! 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 ObJectlves
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, accessi-
bility, training, and management of change
Help procedure writers produce effective, usable procedures that
support safe and efficient operations and maintenance through
improved communication
1.4. Who Should Use This Book? 3
1.3. The current worldwlde Trend Toward Procedures
Operating and maintenance procedures have become an intemational
issue. Europe, Canada, and the United States have ali 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 Intemational 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 ( OSHAJ Rule 29 CFR 1910.119 "Process Safety Manage-
ment 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 ChemicalAccidental
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 critica! share of
the total compliance effort these regulations demand. Your written proce-
dures 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 (IChEJ, the Chemical
Manufacturers Association (CMAJ, and the American Petroleum Institute
(APIJ 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 sorne organizations and documents that recom-
mend or require procedures.
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 Thls 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 chemi-
cals. Refineries, commodity chemical plants, waste processors, plastics
4 1. INTRODUCTION TO EFFECTIVE PROCEDURE WRITING
TABLE 1-1
Organizations and Documents Recommending
or Requiring Procedures
ORCANIZATION DOCUMENT
AIChE Center for Guidelines for Technlcat Management of Chemicat
Chemical Process Safetv Process Safety, AIChE/CCPS. New York, New York
IAIChE/CCPSJ 1989.
American Petroleum API Recommended Practlce 750, Management of
lnstitute <APIJ Process Hazards, American Petroleum lnstitute,
Washington, oc. 1990.
Chemical Manufacturers Responslble Care: A Public Commitment, Chemical
Association <CMAJ Manufacturers Association, Washington. oc. 1988.
U.S. Environmental Rlsk Management Programs for Chemical Accidenta/
Protection Agency <EPA> Release Prevention; Proposed Rute 40 CFR part 68,
Environmental Protection Agency, Washington. oc.
1993.
lnternational Organization Quality Management and Quality Assurance Standards
for Standardization USO> 19000> ISO 9000-150 9004,
or in the United States of Quality Systems-Mode/s for Quality Assurance
America American (9001-9003)
National Standards Quality Management and Quality System Elements-
lnstitute <ANSI> 9000-1, Guidelines !9004J
9001, 9002,9003,9004-1 lnternational Organization for Standardization.
Oeneva. Switzerland 1987.
US Occupational Safety Process Safety Management of Highty Hazardous
and Health Administration. Chemica/s; Exp/osives and B/asting Agents; Final Rule
us Oepartment of Labor 29 CFR 1910.119, Occupational Safetv and Health
<OSHAl Administration, Washington, OC, 1992.
Organization for Workshop on Prevention of Accidents tnvotvfng
Economic Cooperation Hazardous Substances Good Management Practice,
and Oevelopment<OECDl Oiscussion Oocument Relating to the oevelopment of
OECO Ouideline for the Prevention of Accidents
lnvolving Hazardous Substances. Organization for
Economic Cooperation and oevelopment, Berln.
1989.
Official Journal of the Council Directive of 24 June 1982 <the Seveso
European Communities DirectiveJ on the Major-Accident Hazards of Certain
Industria/ Activities, Official Journal of the European
Communities. Berln. 1989.
The World Bank Manual of Industrial Hazard Assessment Techniques.
The World Bank. Washington. oc 1985.
1.4. Who Should Use This Book? 5
manufacturers, specialty chemical plants, and agricultura! chemical proc-
esses-these ali are obvious examples of processes that may use chemicals.
Other, less obvious facilities with process safety and quality concems
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 maintenance per-
sonnel use procedures on a daily basis and are essential contributors
to developing effective procedures. Their regular use of procedures
can ensure revisions are made in a timely fashion.
Management-Effective procedures capture the approved mode of
operation and maintenance. Written procedures are the best way to
communicate this information provided that there is regular review,
comment, and response from the users. This book recommends
administrative practices, including approval and review responsibili-
ties and control methods.
Engineering-Process hazard evaluations, process control improve-
ments, tumarounds, and startups all benefit from effective proce-
dures that accurately describe how to operate and maintain process
equipment. This book presents the basic methods for ensuring that
the procedures are effective and are reviewed for accuracy.
Safety-Written operating and maintenance procedures provide
information on hazards and the actions required to mitigate them.
Lessons leamed from incidents can also be included in the proce-
dures when applicable. This book describes how to alert users of
hazards before performing a task.
Environmental-Using written procedures minimizes accidental
chemical releases to the environment due to unsound operating and
maintenance practices. If an incident occurs, the use of procedures
should specify the proper response.
Training-Written procedures are inextricably linked to operations
and maintenance training. Well-written procedures provide a solid
means of meeting the need to train workers on safe operations and
maintenance. This book describes why procedures are important
training tools.
6 1. INTROOUCTION TO EFFECTIVE PROCEDURE WRITINO
Anyone given the responsibility forwriting a new procedure or updating
an existing one at your facility is a "procedure writer." Writers will benefit
from this book by having a common basis for making decisions conceming
style, content, and level of detail. Procedure users may include operators,
maintenance craftpersons, Process Hazards Analysis (PHA) team mem-
bers-potentially anyone in the plant. Each can benefit from this book by
gaining an understanding of how procedures are written. This knowledge
will help users gain the confidence needed to recommend changes in
procedures when required.
1.5. Where Do vou co From Here?
Even if your procedures aren't written, they do exist. They exist in the
experience you and your co-workers have gained over the years. That
experience, combined with this book, could be all you need to begin writing
your procedures.
Chapter 2 examines several voluntary guidelines and regulatory re-
quirements dealing with written operating and maintenance procedures.
Understanding the elements found in these guidelines and regulations
helps to produce well-written, usable procedures that will assist you in
reaching your process safety, environmental, and quality goals.
Chapter 3 describes the importance of written procedures and how to
design a system for guiding procedure development and revisions. This
procedure management system works with Management of Change to
ensure procedures are selected, developed, and reviewed consistently using
a planned framework that allows their easy use and maintenance.
Chapter 4 addresses procedure writing, including format selection, the
types of references and resources needed, and the human factors of proce-
dures. It describes how to begin writing, how to address technical data, and
special considerations for maintenance procedures and batch processes.
Chapter 5 provides a starting point for developing a list of elements for
writing effective procedures to meet your facility's needs. Due to your
operations, maintenance, and regulatory concems, you may want to add
facility-specific procedure criteria to this list or delete criteria not applicable
to your situation.
Chapter 6 discusses severa! factors to consider when identifying and
writing for abnormal or emergency conditions. W e define an operating
emergency as an event which can result in an accidental chemical release
1.5. Where Do You Go From Here? 7
or injury if appropriate actions are not taken. Such actions are described in
Emergency Operating Procedures (EOP).
Chapter 7 presents the basic requirements to access, review, approve,
control, and maintain procedures. It also discusses the wide range of
choices you have in selecting the level of control your plant needs.
Chapter 8 summarizes why operating and maintenance procedures are
a critica! part of Process Safety Management, the typical costs associated
with procedure development, and the retum on investment.
BIZARRO By DAN PIRARO
Figure 11. The lmportance of effective procedures.
Reprtnted by permtsston of Chrontcte Features, S<11 Francisco, CA.