Operating Procedures cont'd

DOE-HDBK-1101-96

prepare workers for any event that may reasonably occur. Administrative and special engineering

control measures, as well as required monitoring and surveillance equipment must be described.

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 operation.

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 devel-

oped 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

operating procedures.