Procedures must be clearly written, with easy-to-follow steps for each operating phase. They
should be written at an education level that all process workers can understand. If workers have
difficulty understanding instructions in English, contractors should consider providing
procedures in a second language understood by the workers, or the workers should be teamed
with others who can explain the procedures and provide necessary guidance. Critical or complex
procedures may be enhanced with job performance aids, such as flow diagrams, photos, or
expanded assembly drawings.
A close relationship exists between training and operating procedures. High-quality procedures
alone achieve nothing unless the operators are trained in their use. When operating procedures
are used for training, the trainer has an opportunity to satisfy procedure review and update
requirements by ensuring that the procedure still represents current practice.
Procedures should include a graded approach to highlighting dangers, such as the military
system of notes, cautions, and warnings. (Notes indicate that care is required. Cautions indicate
that incorrect operation may lead to injury or equipment damage. Warnings indicated that
incorrect operation may lead to serious injury or major equipment damage.)
Safe work practices are also discussed in Section 2.9 because they address nonroutine operations
and often require special authorizations. Safe work practices are more generic than procedures
and describe a program and an approach for conducting an activity (e.g., confined space entry or
lockout/ tagout). Both operating procedures and safe work practices are required for safe process
Seven steps are suggested for developing procedures:
Step 1 Determine the tasks involved in operating a process unit, the relationship between the
tasks, and the order in which they are to be carried out. Use Job Safety Analyses to
identify and discuss hazards associated with each task.
Step 2 Analyze each task and reach consensus on how it should be carried out. The analysis
should be done by senior operators and supervisors, with input from management and
technical staff. Task analysis is often beneficial because it illuminates inconsistencies in
the way tasks are performed by different workers on different shifts.
Step 3 Write the procedures based in interviews or personal experience, and follow the logic
developed in the task analysis.
Step 4 Distribute written procedures to operators for comment and discussion.
Step 5 Perform a PrHA for the procedures. The PrHA team thoroughly reviews the procedures
and generates the safety and health information to be incorporated.
Step 6 Ensure that users receive the proper training.
Step 7 Ensure that procedures are written and structured so that they can be updated regularly to
reflect changes. Note that MOC procedures identify activities that lead to changes in