How much worse would your plant be if you threw away all the emergency procedures?

NEWSLETTER ARTICLE

Procedure - n. (1) act or manner of proceeding in any action or process; conduct, (2) a particular course or mode of action.

A recent client asked our opinion of their emergency procedures. I wanted to laugh and tell him that the procedures were worthless. Instead, I stated a different truth: "They're typical for the industry." Beville rarely criticizes procedures anymore; the problem is so pervasive and recalcitrant that it hasn't merited the effort. Due to a variety of factors, the bottom line is that procedures seem to have no effect on plant operation. Yet, operators are always on special assignment writing new procedures that no one will use.

Typically, the procedures have low utility and value, and possibly in an effort to counter this, the number of procedures has skyrocketed at most plants. More procedures, written and rewritten by different people, usually mean more chances of inconsistency, and, therefore, operator error if they are actually used. As the number of procedures grows, the ability to make widespread formatting and content changes becomes exponentially more difficult. Soon, if not already, plants will be saddled with worthless documents that are too expensive to fix but must be maintained/propagated in the name of "safe operation".

Many plants also use procedures for training. Unfortunately, this results in both poor emergency procedures and poor training manuals. The value of emergency procedures is seen in their real-time use, which is rare. Excuses are plentiful: too hard to find, too bulky, too wordy, not applicable, and so on.

Currently, their single greatest value seems to be that they fulfill a regulatory requirement; they check a box. What must one do to create usable procedures? While not comprehensive, the following should be considered:

1. Focus on the end user, the operator. Like all forms of information presentation, procedures need to be written for the user for a specific purpose. First of all, they need to be written for the job, not for the equipment. If a board operator is controlling three different units, he needs one procedure that integrates the tasks for each unit, not three separate procedures. Secondly, the purpose of the procedure needs to be clear. Is it for training? Or is it for emergency response? The procedure needs to be different for each of these needs.
    
2. Know what your users know. One plant had six pages of information containing such things as required safety equipment, something the operator should already know. Yet another plant had two separate procedures for the same upset. One was to be used when the tank farm had power, the other when it did not. The likelihood of the operator on the unit knowing the status of the tank farm was slim, making his choice of procedure difficult, if not impossible.
    
3. Focus on behavior. What actions must the operator take? The procedure with six pages of safety information did not have prescribed action until page 7, making its utility during an upset situation very low. Well-written procedures focus on specific actions the operator must perform.
    
4. Ensure usable format. Write the procedure in a usable format. Flowchart procedures have been shown to produce superior performance when compared to prose-based procedures, yet most are written in prose. If a mobile operator needs to climb towers while following the procedure, it must be compact, easy to access, and easy to follow.

Using these human factors guidelines as a start, it is possible to create valuable, usable emergency procedures.

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