Developing and Implementing Operating Procedures

By Wendla Reed

My Project
My internship was to review how all the Bay Area refineries determine when a job task needed an operating procedure and how they went about developing and implementing these operating procedures.

During 2003-2008, there were 49 total inspections that included violations specifically regarding operating procedures that were given to refineries within California. These violations against operating procedures amounted to 177,700 dollars in fines (OSHA.gov).

Best Practices
After reviewing how the refineries in the Bay Area determine when a job task needed an operating procedure I pulled out what I considered to be the best practices from each refinery.

Calculating Risk
Two refineries had simple and user-friendly risk matrixes that help calculate the risk involved behind a particular work task.

Risk Matrix from Refinery A

Task complexity, Task frequency, and criticality.

The more complicated the decision tool becomes; the more likely a worker is to not use it, or to use it incorrectly.

Risk Matrix from Refinery D

1-Job Aid/ Work Instruction-No written work instruction required. Task covered in basic or initial training. 2-Reference: Written procedure required. Sign offs not required unless directed by supervision. 3-Critical-Written procedure required. In-hand use of procedure with step by step sign off required. 4Written procedure required, in addition a PHA is required for procedure development and modifications. In-hand use of procedure with step by step sign offs required.

Incorporating additional Process Hazard Analysis to a number 4 square in a risk matrix.

This is a best practice because it shows that this refinery has been reviewing common use of written operating procedures and found that complacency is an issue with complicated and frequently used procedures.

What is Criticality?
Criticality should focus on the potential hazard. If the procedure is done incorrectly then how adverse will the effect be? How will the negative consequence affect the worker (or workers), the surrounding area, and the company?

What is Frequency?
performed frequently = daily or weekly performed infrequently= once every 1 to 3 months performed rarely= once every 6 months to a year

What is Complexity?
Complexity should focus on how long the task takes to complete and the level of involvement of the task. Does it cross over into more then one shift? Does the job task involve two or more operators? Is the number of steps above 15?

Hanging Headers
These help to show the user of the operating procedure the big picture look at the task.
This is a hanging header.

Warnings = human hazard

WARNING: to describe a hazard that can cause injury or death. CAUTION: to describe a hazard that could result in damage to equipment, product, or the environment. NOTE: to provide pertinent information towards a step or to prepare the user for the unexpected.

Proper use of warning, caution, and note boxes

They should say what not to do and briefly why not. Limit how many boxes go on a page. Some companies started adding colored symbols to the far left of the box. Yellow for caution, red for warning, and blue for note.

Attaching a Job Title to Each Step

Some job tasks require several workers to collaborate together in order to complete a task. When a procedure writer takes care to spell out the job title of the person responsible for each step, then they take out the guess work and make it easier to follow complicated operating procedures.

Using DuraPaper
Using a tear resistant, water resistant paper that has reinforced ring holes helps ensure that written operating procedures stay complete. DuraPaper is being taken off the market - a good alternative would be Xerox Ring Tuff Paper sold at officedepot.com for $25 dollars a ream.

Procedure Tracking Tool

Procedure Tracking Tool

This procedure tracking tool is a great idea because it is quick and simple to use and it helps ensure correct use of operating procedures. Once a month, an automatic email is sent out with the raw data collected by the tracking tool.

Guide books should cover:

Procedure format- Standardization makes following operating procedures easier.
Numbering and titling of procedures should follow a logical format.

The guide book should also cover word usage such as:

Writing steps in the command form
Using an action verb whenever possible
Avoiding confusing or vague language

Summary of Best Practices

User-friendly risk matrixes that help calculate the risk involved Incorporating additional Process Hazard Analysis to a number 4 square in a risk matrix. Hanging Headers Warnings = human hazard Proper use of warning, caution, and note boxes

Summary of Best Practices

Attaching a Job Title to Each Step Using a tear resistant, water resistant paper that has reinforced ring holes helps ensure that written operating procedures stay complete. Procedure Tracking Tool Developing a guide book that covers procedure format, commands and action verbs.

Thanks to those people who helped me get all the information I needed in order to compare and analyze the different refineries systems.

Any questions?
Thank you for your time!