Episode 48 - Operating Procedures for Process Safety Management (PSM)

Episode 48 explains the Operating Procedures element of OSHA’s Process Safety Management Standard (29 CFR 1910.119). Dr. Ayers focuses on why written procedures are essential for consistency, safety, and compliance — and why deviations from procedures are a major root cause of catastrophic incidents.

The core message: Operating procedures turn process safety information into safe, repeatable action. Without them, every shift becomes an experiment.

 

🧭 Purpose of Operating Procedures

Operating procedures ensure that:

• Workers operate processes safely and consistently

• Hazards are controlled during all operating modes

• Critical steps are not skipped or improvised

• Operators understand limits, consequences, and required actions

• The process stays within safe operating boundaries

Procedures are the playbook for safe operations.

 

🔄 Operating Modes That Must Be Covered

Episode 48 highlights that procedures must address every operating mode, including:

• Normal operations

• Startup (one of the highest‑risk phases)

• Shutdown (normal and emergency)

• Temporary operations

• Emergency operations

• Upset conditions

Each mode has unique hazards and must be documented clearly.

 

📋 Required Content of Operating Procedures

Dr. Ayers outlines the essential components:

1. Operating Limits

Procedures must specify:

• Safe upper and lower limits

• Consequences of deviating from limits

• Corrective actions to take

Operators must know what normal looks like and what to do when it isn’t.

 

2. Step‑by‑Step Instructions

Procedures must include:

• Detailed steps for each operating mode

• Sequence of actions

• Required verifications

• Communication expectations

Vague or overly general procedures lead to inconsistent execution.

 

3. Safety and Health Considerations

Procedures must address:

• Chemical hazards

• PPE requirements

• Engineering controls

• Administrative controls

• Exposure prevention

• Emergency actions

This connects operating procedures to the facility’s hazard information.

 

4. Safety Systems and Interlocks

Operators must understand:

• What safety systems exist

• What they protect against

• What to do if they activate

• What conditions require shutdown

Safety systems are only effective if operators know how they work.

 

🔧 Why Procedures Fail in Real Facilities

Episode 48 highlights common weaknesses:

• Procedures not updated after changes (MOC failures)

• Operators relying on “tribal knowledge” instead of written steps

• Procedures too vague or too complex

• Procedures not accessible in the field

• Operators not trained on updated procedures

• Procedures written by engineers with no operator input

• Emergency procedures missing or incomplete

These failures often show up as root causes in incident investigations.

 

🔗 How Operating Procedures Connect to Other PSM Elements

Operating procedures are tightly linked to:

• Process Safety Information (PSI) — procedures must reflect accurate PSI

• Training — operators must be trained on current procedures

• MOC — changes require procedure updates

• Mechanical Integrity — procedures must reflect equipment capabilities

• PHA — hazards identified in PHAs must be addressed in procedures

Procedures are the operational expression of the entire PSM system.

 

🧑‍🏫 Leadership Responsibilities

Safety leaders must:

• Ensure procedures are accurate, current, and accessible

• Require operators to follow procedures — no shortcuts

• Involve operators in procedure development and updates

• Ensure procedures are updated through the MOC process

• Provide training whenever procedures change

• Audit procedure use in the field

• Treat deviations as learning opportunities, not blame

The episode’s core message: Strong procedures create strong operations. Weak procedures create risk.