Operating Procedures

Process Safety Requirement - Operating Procedures

The employer must develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. OSHA believes that tasks and procedures related to the covered process must be appropriate, clear, consistent, and most importantly, well communicated to employees. The procedures must address at least the following elements:

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 shut down responsibility to qualified operators to ensure that emer gency shutdown is executed in a safe and timely manner;
  • Emergency operations;
  • Normal shutdown; and
  • Startup following a turnaround, or after an emergency shut down.

Operating limits:
  • Consequences of deviation, and
  • Steps required to correct or avoid deviation.
  • 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; and
  • Any special or unique hazards.
  • Safety systems (e.g., interlocks, detection or suppression systems) and their functions.

To ensure that a ready and up-to-date reference is available, and to form a foundation for needed employee training, operating procedures must be readily accessible to employees who work in or maintain a process. The operating procedures must be reviewed as often as necessary to ensure that they reflect current operating practices, including changes in process chemicals, technology, and equipment, and facilities. To guard against outdated or inaccurate operating procedures, the employer must certify annually that these operating procedures are current and accurate.

The employer must develop and implement safe work practices to provide for the control of hazards during work activities such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices must apply both to employees and to contractor employees.