The Occupational Safety and Health Administration (OSHA) requires that PSM Standard Operating Procedures (SOPs) provide instructions clear enough that employees will be able to effectively utilize them. SOPs must be documented in sufficient detail and provide specific direction so that employees can follow the procedures and determine how to safely perform service and maintenance activities.
The Occupational Safety and Health Administration (OSHA) requires that PSM Standard Operating Procedures (SOPs) must be documented in sufficient detail and provide specific direction so employees can determine how to safely perform service and maintenance activities.
The lack of procedural clarity and specificity in SOPs can result in employees failing to isolate the key specific valves, permitting possible exposure. Simply listing valves by their functionality, such as liquid valve or hot gas valves, may lead to confusion and error. It is recommended that SOPs use valve numbers to identify the particular valve(s) that must be opened and closed as indicated on the Piping and Instrumentation Diagrams (P&ID).
To eliminate any confusion among operators and maintenance staff, each of the following elements must be addressed in the SOPs:
1. Steps for each operating phase:
- Initial startup
- Normal operations
- Temporary operations
- Emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner
- Emergency operations
- Normal shutdown
- Startup following a turnaround or after an emergency shutdown
2. Operating limits:
- Consequences of deviation
- Steps required for avoiding or correcting deviation
3. Safety and health considerations:
- Properties of, and hazards presented by, the chemicals used in the process
- Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment
- Control measures to be taken if physical contact or airborne exposure occurs
- Quality control for raw materials and control of hazardous chemical inventory levels
- Any special or unique hazards
- Safety systems and their functions
Once written and implemented, SOPs are to be reviewed as often as necessary. However, they must be certified and updated annually to ensure they reflect current operating practices, changes in the process chemicals, technology, equipment and facilities. Keep in mind that an SOP revision would also require Management of Change in accordance with PSM best practices.
If you have questions about developing specific SOPs, email me at firstname.lastname@example.org.