APPENDIX A SELECTED PROCEDURE INITIATIVES, CONSENSUS CODES, AND REGULATIONS AFFECTING PROCEDURES Organization AlChE Center for Chemical Process Safety (AlChE/CCPS) 345 East 47th Street New York, New York 10017. American Petroleum Institute(API) 1220 L Street NW Washington, DC 20005. Chemical Manufacturers Association (CMA) 2501 M Street, NW Washington, DC 20037. Federal Emergency Management Agency (FEMA) 500 C Street SW Washington, DC 20472. Selected Documents or Program initiatives Plant Guidelines for Technical Management of Chemical Process Safety: New York: AlChE/CCPS, 1992. Guidelines far Technical Management of Chemical Process Safety New York: AlChE/CCPS, 1989. API Recommended Practice 750: Management of Process Hazards. Washington, DC: American Petroleum Institute, 1990. Responsible Care®: A Public Commitment Washington, DC: Chemical Manufacturers Association, 1988. Responsible Care®: Process Safety Code of Management Practices. Washington, DC: Chemical Manufacturers Association, 1992. Handbook of Chemical Hazard Analysis Procedures: Washington, DC: FEMA, October 1990.
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APPENDIX A
SELECTED PROCEDUREINITIATIVES, CONSENSUS
CODES, AND REGULATIONSAFFECTING PROCEDURES
Organization
AlChE Center for Chemical ProcessSafety (AlChE/CCPS)
345 East 47th StreetNew York, New York 10017.
American Petroleum Institute (API)1220 L Street NWWashington, DC 20005.
Chemical Manufacturers Association(CMA)
2501 M Street, NWWashington, DC 20037.
Federal Emergency ManagementAgency (FEMA)
500 C Street SWWashington, DC 20472.
Selected Documentsor Program initiatives
Plant Guidelines for TechnicalManagement of Chemical ProcessSafety: New York: AlChE/CCPS, 1992.
Guidelines far Technical Managementof Chemical Process Safety NewYork: AlChE/CCPS, 1989.
API Recommended Practice 750:Management of Process Hazards.Washington, DC: AmericanPetroleum Institute, 1990.
Responsible Care®: A Public CommitmentWashington, DC: ChemicalManufacturers Association, 1988.
Organization for Economic Cooperationand Development (OECD)
Organization Resources Counselors,Inc. (ORC)
1910 Sunderland Place NWWashington, DC 20036
Selected Documentsor Program initiatives
Loss Prevention Bulletin (Case Histories)Conference on Major Accidents
Prevention
ILO Code of Practice for the Preventionof Major Industrial Accidents: Geneva:International Labor Office, 1991.
Quality Management and QualityAssurance Standards (9000)ISO 9000— ISO 9004
Quality Systems— Models for QualityAssurance (9001-9003)
Quality Management and QualitySystem Elements— Guidelines (9004)Geneva, Switzerland, 1987.
Adopted AlChE/CCPS as voluntary code.
Council Directive of 24 June 1982 (theSeveso Directive) on the Major-Accident Hazards of Certain IndustrialActivities. Berlin: Official Journal ofthe European Communities, 1989.
Workshop on Prevention of AccidentsInvolving Hazardous Substances GoodManagement Practice, DiscussionDocument Relating to theDevelopment of OECD Guideline forthe Prevention of AccidentsInvolving Hazardous Substances.Berlin: Organization for EconomicCooperation and Development, 1989.
Recommendations for Process HazardsManagement of Substances withCatastrophic Potential. OSHA DocketS-026— Process Safety Managementof Highly Hazardous Chemicals.Washington, DC 1988.
Organization
The World BankInternational Bank for Reconstruction
and Development181 8 H Street, N WWashington, DC 20433
US Department of Labor (DOL)Occupational Health & Safety
Administration200 Constitution Avenue, NWWashington, DC 20210
US Environmental Protection Agency(EPA)
OS-120401 M Street SWWashington, DC 20460
Selected Documentsor Program initiatives
Manual of Industrial Hazard AssessmentTechniques. Washington DC: TheWorld Bank, 1985.
Workshop Procedures SafetyManagement and Risk Control
Occupational Health and SafetyGuidelines
The Phillips 66 Company HoustonChemical Complex Explosion and Fire:A Report to the President.Washington, DC: Occupational Healthand Safety Administration, April 26,1990.
Federal Register, Volume 57 Number 36,pp. 6356-6417, "29 CFR 1910.119:Process Safety Management ofHighly Hazardous Chemicals;Explosives and Blasting Agents." FinalRule. Washington, DC: February 1992.
Federal Register, Volume 58, Number201, pp. 54190-54219. "ProposedRule 40 CFR part 68: RiskManagement Programs for ChemicalAccidental Release Prevention."Washington, DC, October 1993.
APPENDIX B
COMMON POINTS OF API,OSHA, AND EPA
This appendix shows how the major elements of process safety manage-ment are reflected in APFs RP 750, OSHA PSM Rule, and EnvironmentalProtection Agency (EPA) regulations. The common points of each of thethree documents are listed.
EPA 40 CFR Part 68.28Risk Management Programs for ChemicalAccidental Release Prevention: Proposed RuleDocument the safe and proper way to operateand maintain processes and equipment
(b) Develop and implement written operatingprocedures that provide clear instructionsfor safely conducting activities involved ineach covered process consistent with theprocess safety information.
(1) Steps for each operating phase:(i) initial startup(ii) Normal operations(iii) Temporary operations(iv) Emergency shutdown initiating
conditions and assignmentresponsibilities
(V) Emergency operations(vi) Normal shutdown(vii) Startup following turnaround or
emergency shutdown(2) Operating limits
(i) Consequences of deviation(ii) Steps to correct deviation
(3) Safety and health considerations:(i) Properties and hazards(ii) Precautions to prevent exposure
including engineering controls,administrative controls, and personalprotective equipment (PPE)
(iii) Control measures in event of contactor airborne exposure
(iv) Quality control for raw materials and control of regulated substance inventorylevels
(V) Any special or unique hazards
OSHA 29 CFR 1910.119Process Safety Management of Highly HazardousChemicals, Explosives, and Blasting Agents
(f)(1) Develop and implement written operatingprocedures that provide clear instructionsfor safely conducting activities involved ineach covered process consistent with theprocess safety information.
(i) Steps for each operating phase:(A) initial startup(B) Normal operations(C) Temporary operations(D) Emergency shutdown initiating
conditions and assignmentresponsibilities
(E) Emergency operations(F) Normal shutdown(C) Startup following turnaround or
emergency shutdown(ii) Operating limits
(A) Consequences of deviation(B) Steps to correct deviation
(iii) Safety and health considerations:(A) Properties and hazards(B) Precautions to prevent exposure
including engineering controls,administrative controls, and personalprotective equipment (PPE)
(C) Control measures in event of contactor airborne exposure
(D) Quality control for raw materials andcontrol of hazardous chemical inventorylevels
(E) Any special or unique hazards
API RP 750 Section 5American Petroleum InstituteRecommended Practice 7505.1. Content of Operating Procedures
a. Identify person(s) responsible for eachoperations area
b. Clear instructions consistent with processsafety information
c. Operating conditions and steps for followingphases of operation:1. Initial startup2. Normal operations3. Temporary operations4. Emergency operations including:
Emergency shutdowns and initiatingpersons
5. Normal shutdown6. Startup following turnaround
d. Operating limits1 . Consequences of deviation2. Steps to correct or avoid deviation3. Safety systems and their functions
e. Occupational safety and health considerations:1. Properties and hazards2. Precautions to prevent exposure,
including engineering controls and PPE3. Measures in event of contact or exposure4. Special or unique hazards
(4) Safety systems and their functions
(c) Procedures readily accessible
(d) • Procedures reviewed as necessary toensure they reflect current operatingpractices
•Certify annually that operating proceduresare current and accurate
(e) Develop and implement safe work practices:-lockout—confined space entry—opening process equipment or piping—entrance controlSafe work practices shall apply to employeesand contract employees
68.32. Prevention Program--Maintenance(Mechanical integrity)(c) Establish and implement written
procedures to maintain the on-goingintegrity of process equipment,
(e) Maintenance Inspections(2) Inspection and testing procedures
(3) • Procedures reviewed as necessary toensure they reflect current operatingpractices
• Certify annually that operatingprocedures are current and accurate
(4) Develop and implement safe work practices:-lockout—confined space entry—opening process equipment or piping—entrance controlSafe work practices shall apply to employeesand contract employees
(j) Mechanical integrity.(2) Establish and implement written
procedures to maintain the on-goingintegrity of process equipment.
(4) Inspection and testing.(H) Inspection and testing procedures
shall follow recognized and generallyaccepted good engineering practices.
d. Operating limits3. Safety systems and their functions
5.2. Operating Procedures in place beforestartup
5.3. • Reviewed in event of technology orfacility changes.
• Periodically reviewed to ensure currentand accurate (3 to 5 years)
• Review frequency based on degree ofhazard presented
8.4. Maintenance SystemsMaintenance systems should include:• Maintenance procedures and safe work
practices that ensure the mechanicalintegrity of equipment
8.5. Testing and Inspection program shallinclude:b. Testing and inspection proceduresd. Procedures to correct equipment
deficiencies or operations that areoutside acceptable limits
APPENDIX C
HOW TO DETERMINE THETASKS THAT REQUIRE
WRITTEN PROCEDURES
Generally, written operating and maintenance procedures are required bysound business practices or government mandate. Effective procedures providewritten, clear instruction to the employee concerning how a task is safely andcorrectly performed. This helps to ensure that a task is performed withconsistency regardless of the experience level of the employee.
There are different resources for identifying and selecting tasks thatwill require written procedures. Training Needs Assessments, ProcessHazards Analyses, and Job Safety Analyses can assist you in analyzing thespecific requirements of your plant.
Assessing Training Needs
Part of assessing training needs is determining the tasks to be performedfor a given job position or area. Task Lists can be used to identify whichprocedures you need to develop. To generate a Task Listing, you identifythe tasks performed for a specific job position or job area. A task is definedas a meaningful unit of work with a measurable value. A task containsmore than two steps with a clearly defined starting and stopping point. Forexample, "mowing the lawn" is a task. The steps required to perform thetask of "mowing the lawn" in a safe and prescribed manner begin to providethe detail for a written procedure.
You write procedures for safety, environmental, quality, and regulatoryreasons. Regardless of the reason, you can determine the tasks (and the
steps used to complete those tasks) for a specific job position or job areaby:
1. Reviewing information related to the job area or position, includingbut not limited to, existing procedures, training, job safety analy-ses, process safety information, plant history, related industrialexperience, and plant simulations, and incident reports.
2. Observing the job being performed by a competent person; record-ing the tasks and steps as they are actually performed.
3. Comparing your task listing to the existing documents to verifythat you have not missed any tasks.
When you have completed documenting your task listing, most of taskslisted will become procedures titles. The task listing must be evaluatedbased on specific criteria including criticality, complexity, frequency ofperformance and potential hazard. The evaluation determines which tasksbecome written procedures. Although the task steps are not usually detailedenough to be procedures, they provide the foundation for procedure devel-opment.
Process Hazards Analyses
You often identify critical, difficult, or hazardous tasks as part of a ProcessHazards Analysis (PHA). PHA information is another resource used toindicate which procedures need to be written. The PHA also directs you totasks that may require much more detailed procedures or training becauseof criticality or safety issues.
Job Safety Analyses
Job Safety Analyses identify safety and industrial hygiene issues for aparticular job position, area, or tasks. They are a resource for determiningwhich tasks should be described by written procedures. Job Safety Analysescan also identify special cautions and warnings that should be included ina procedure.
APPENDIX D
PROCEDURE PERFORMANCEEVALUATION
This appendix includes a sample procedure performance evaluation docu-ment which can be used by an evaluator to evaluate a trainee's performanceof a procedure. This document, when used in conjunction with an ap-proved, up to date procedure, becomes a performance evaluation tool. Theitems listed on the second page should be customized to your facility'straining program requirements.
How will you verify that a trainee can perform a task (as written in aprocedure) safely and correctly? You can use the procedure performanceevaluation with the procedure while observing the trainee perform orsimulate the procedure. The procedure is the criteria for safe and correctperformance of the task, and the procedure performance evaluation docu-ment is the guideline for the evaluator and the trainee. Upon the comple-tion of the performance evaluation, this document becomes the record ofperformance.
PROCEDURE PERFORMANCE EVALUATION1
Objective:
• The Trainee will demonstrate the ability (actual or simulated) tosafely and correctly perform the operations required by the proce-dure, using the procedure and Qualification Card.
Reprinted by permission of NUS Training Corporation, Gaithersburg, MD, 1992.
Instructions to Observer:
• Review procedure and checklist with the trainee.• Observe trainee performing (or simulating walkthrough/oral) proce-
dure steps (trainee may use a working copy of the procedure.)• When you observe correct performance of a step or substep, check
and initial the step or substep.• If an action is omitted or performed incorrectly, circle that action
on the procedure. Discuss the omission or error with the traineebefore continuing the qualification session.
• If the trainee attempts an unsafe action or ignores a potentiallyhazardous condition, STOP the trainee and terminate the qualifi-cation session. Discuss the violation with the trainee before allowingthe trainee to reschedule another qualification.
• If specifications are required (for instance: tanks, quantities, valve line-ups), give the trainee appropriate instructions so the session can continue.
• If the procedure requires permission or a request, grant the requestor give permission.
• Do not prompt the trainee or allow anyone to assist the traineeunless required by the procedure or a condition exists which wouldnormally require assistance.
• If a procedure step requires the trainee to verify a condition but youcannot directly observe whether the trainee has checked it, verifythe condition yourself and check the step in the procedure if thecondition is actually satisfied.
• When the procedure is completed, discuss any omissions or prob-lems encountered during the performance (simulation).
• Complete the qualification card.• If the trainee satisfactorily performed (simulated) the procedure,
both you and trainee sign the qualification card.• Attach the procedure to Procedure Performance Evaluation and
return to Training Department.
Instruction to Trainee:
"I am going to observe you . I will follow yourperformance using the procedure. While performing the procedure, youmay use any references you want, including a copy of the procedure for
. You must perform the task alone, with no help fromanyone else, unless assistance is specified in the procedure or there is anabnormal or emergency condition. Do you have any questions?"
Did the trainee:
1. Obtain all special tools or equipmentrequired by the procedure?
2. Verify all prerequisites satisfied?
3. Follow procedure steps in the order written?
4. Obtain required permissions?
5. Obtain/wear all required personal protectiveequipment?
6. Follow all safety requirements?
7. Verify all valve lineups?
8. Know the location of :Local start/stop switches?Valves?Controllers?Control boards and panels?Instrumentation?Equipment?Emergency stops?Remote start/stop switches?Safety equipment
9. Demonstrate ability to safely and properlyuse or operate auxiliary equipment (cranes,hoists.etc.)?
10. Know actions to take in event of alarms ormalfunctions?
YES NO NA
COMMENTSinclude number of
omitted or incorrectlyperformed steps
DATE QUALIFICATION STARTED:OBSERVER'S NAME (print)TRAINEE'S NAME (print)PROCEDURE TITLE, NO., & REVISION NO-
DATE COMPLETED:EMP. NO.:
successfully demonstrated the ability to safelyand correctly perform this procedure.
DID NOT successfully demonstrate the ability tosafely and correctly perform this procedure because (clearly state reason):
TRAINEE'S SIGNATURE DATE
OBSERVER SIGNATURE DATE
ATTACH copy of procedure used to verify performance to Procedure Performance Evaluation andRETURN documents to Training Dept.
APPENDIX E
PROCEDURE CRITERIACHECKLIST
This appendix lists some Procedure Evaluation Criteria which are basedon procedure writing experience, human factors, and lessons learnedincluding recognized formatting and presentation methods that will helpto ensure your procedures are effectively written. While most procedureelements are based on human factors, some are based on technical,administrative, or regulatory factors. Revise this list to reflect your facility'srequirements and include it in your procedure management system.
PROCEDURE CRITERIA CHECKLIST1
PROCEDURE CRITERIA CHECKLIST ITEMS
1 . Does the title accurately describe the nature of the activity?
2. Is the necessary procedure control information included oneach page such as?
Facility or unit name or identifierProcedure titleProcedure numberDate of issue, approval date, required review date, andeffective dateRevision numberPage number and total pages
3. Is the last page of the procedure clearly identified?
4. Are temporary procedures clearly identified?
5. Does every procedure have a unique and permanentidentifier?
YES NO/NA
PROCEDURE CRITERIA CHECKLIST ITEMS
6. Does the procedure Purpose clearly describe the intent orgoal of the procedure?
7. For duplicate processes, are the procedures complete andaccurate for each process?
8. Is all information necessary for performing the procedureincluded or referenced in the procedure?
9. Are all items referenced in the procedure listed in theReferences section of the procedure?
10. Are items listed in the References section of the procedurecorrectly and completely identified?
11. Are procedures written in upper- and lowercase letters?
12. Are Cautions, Warnings, and Notes placed immediatelybefore the step to which they apply?
13. Do Cautions, Warnings, and Notes stand out from proceduresteps?
14. If more than one person is required to perform theprocedure, is the person responsible for performing eachstep identified?
15. Is a signoff line provided for verifying critical steps of aprocedure? (Optional)
16. If the procedure requires coordination with others, does itcontain a checklist, signoff, or other method for indicatingthe steps or actions have been performed or completed?
17. Are steps written in short, concise sentences?
18. If a step contains more than two items, are they listedrather than buried in the text?
19. If two actions are included in a single step, can the actionsactually be performed simultaneously or as a single action?
20. Are steps that must be performed in a fixed sequenceidentified as such?
21. Are operating or maintenance limits or specificationswritten in quantitative terms?
22. Does the procedure provide instructions for all reasonablecontingencies?If contingency instructions are used, does the contingencystatement precede the action statement?
YES NO/NA
PROCEDURE CRITERIA CHECKLIST ITEMS
23. If conditions or criteria are used to help the user make adecision or recognize a situation, do they precede theaction?
24. Are conditional instructions easy to understand? If an actionmust meet more than two requirements, are therequirements listed?
25. Are calculations clear and understandable? For complicatedor critical calculations, is a formula or table included orreferenced?
26. Can graphs, charts, and tables be easily and accuratelyextracted and interpreted?
27. Do procedures that specify alignment such as valvepositions, pipe and spool configurations, or hose stationhook-ups• Specify each item• Identify each item with a unique number or designator• Specify the position in which the item is to be placed• Indicate where the user records the position if applicable
28. Do Emergency Operating Procedures contain provisions forverifying• Conditions associated with an emergency (initiating
conditions)• Automatic actions associated with an emergency• Performance of critical actions
29. Do Maintenance Procedures include required followupactions or tests and tell the user who must be notified?
30. If a procedure must be performed by someone with aspecial qualification, are the required technical skill levelsidentified?
YES NO/NA
Endnote
1. Adapted from the NUS Training Corporation's Procedure Writing WorkshopManual, Seventh Edition, Gaithersburg, MD, 1995.
APPENDIX F
SAMPLE PROCEDURE FORMATS
The sample procedure formats in this appendix are derived from actualprocedures used in industry. They show various ways of presenting infor-mation in a T-format. Although each format is slightly different, they allinclude:
SAFETYNOTE: X XXX XX X XXX. XXX XXX X XXXX. XXX XXXX XXX.
7.1. Xxxx-xxxxxxxx123.7.1.1. Xxxx xxx xx xxx.7.7.2. X xx xxxx x.
7.2. XXX x xxx x.7.2.1. XXX x xx xx.
END
APPENDIX G
SAMPLE FORMATS OFOPERATING LIMITS TABLES
The following appendix includes two samples for formatting operatinglimits tables. These can be customized to meet your facility's specificrequirements. These samples also demonstrate the interaction betweenoperating limits tables and procedures. The required actions in the tablescan either be the actual required steps with all necessary explanatoryinformation or a reference to the applicable procedure. The steps orreferences to procedures should follow the development criteria listed inChapter 5.
Required Actions
Listed actions orreference to aprocedure.
Consequencesof Deviating
Outside of SafeOperating Limits
SafeLowerLimit
SafeUpperLimitRequired Actions
Consequences ofDeviating Outside
of NormalOperating RangeAlarms
NormalOperating
Range(units)
ProcessVariable
(variable andmonitoringlocation)
JUNE 1996OPERATING LIMITS TABLE— PROCESS B
Process B Operating Limits Table
CCPS CHEMICAL FACILITY
STANDARD OPERATING CONDITIONS ID#Document #Page 1 ofEquipment Name
Tag/Loop #SystemRef. P&ID#PM#
Remarks:R— Reason for Limit or
Effect of Exceeding LimitC— Correction and/or
Control ActionT— Troubleshooting GuideNever Exceed Interlocks Alarms Operating Range
Min Max Min Max Min Max Min Max
Name/LocationDescription
Where "NEVER EXCEED" limits are applicable, any deviation outside these limits willrequire a document incident investigation.
