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the activity. This will allow them to determine the scope of the assessment and which applicable
activity policies and procedures to review when developing the assessment plan. Sections 5.4 and
5.8 provide a detailed explanation of assessment planning and the use of assessment techniques.
The elements of the program should be defined by activity administrative procedures and policies.
The most important policy to note is what components require labeling. If the activity chooses
not to have a labeling program, the assessment of this area of conduct of operations becomes a
walkthrough of the activity, to identify all damaged or missing labels.
It should be noted that even if the decision has been made to not have a labeling program, it may
be necessary to assess labeling determine what effect the quality of labeling is having on other
areas, such as use of procedures, emergency actions, control of equipment status, maintenance,
lock and tag, engineering, etc.
6.18.3 Observation. Observations of equipment and piping labeling should be conducted
during walkthroughs of the activity and operations in progress.
During the assessment, assessors should walk through the activity and look for:
Systems and equipment that are required to have labels but are not actually labeled
Components that are missing labels or have damaged labels
Labels that do not correlate with diagrams, schematics, drawings, and procedures
Markings on equipment and components that indicate label deficiencies
Markings or corrections made to labels, indicating deficiencies in the labels themselves
Labels that differ in nomenclature from procedures and drawings
Once an observation has been completed, compare what was observed to the requirements
contained in activity policies and procedures to identify any apparent deviations from
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