Risk Based Process Safety (RBPS)Manage Risk

Operating Procedures

Validated normal / abnormal / emergency procedures current at the workstation

Strategic context

What this element is — and why it matters

Operating Procedures are the codified instructions for running every process — normal operation, startup, shutdown, abnormal-situation response, and emergency response. The element maps to OSHA 1910.119(f) and is the most operator-visible PSM artefact. Texas City, Tesoro Anacortes, and BP Macondo each included PSM (f) findings in their CSB investigations.

Operating Procedures

Individual significance for organisations

Operating procedures are the daily operating language of the plant. An organisation with current, validated, workstation-accessible procedures executes operations with consistency and protects against the procedure-vs-reality drift that drives incidents. Operators who trust procedures follow them; those who don't work from notebooks, and the management system collapses into hope.

Contribution to Risk Based Process Safety (RBPS)

Operating Procedures convert Hazard Analysis (Element 7) output and Process Knowledge (Element 6) into actionable instructions for the workforce. They directly enable Conduct of Operations (Element 15), Training (Element 12), and Operational Readiness / PSSR (Element 14). MOC (Element 13) keeps them current; Auditing (Element 19) verifies their accuracy. Without Element 8 discipline, the rest of the operational pillar runs on the wrong baseline.

Key requirements

What compliant execution looks like

Normal, abnormal, emergency, startup, shutdown procedure coverage
Task-analysis-based authoring with operator validation
Annual accuracy certification per OSHA PSM (f)(3)
MOC discipline triggering procedure update before plant change
Workstation-accessible delivery (DCS HMI, tablet, paper backup)
Operator competency and procedure compliance verification
Implementation methodology

How we implement this element

A focused 6-step methodology calibrated to deliver operating procedures as a working capability — not a documented compliance artefact.

Procedure Inventory & Gap Audit

Catalogue existing procedures; map against required scope per OSHA PSM (f); identify gaps in coverage, currency, accessibility.

Task Analysis & Authoring

Conduct task analysis with operator input; author procedures using consistent template (purpose, scope, safety, steps, troubleshooting, references).

Operator Validation

Walk procedures through with operating team; capture practical corrections; obtain formal signoff before issue.

Delivery & Accessibility

Integrate with DCS HMI, mobile tablet delivery, or paper at workstation; ensure shift-team visibility; embed safety-critical warnings prominently.

Annual Accuracy Certification

Annual procedure walk-down per OSHA PSM (f)(3); operator signoff that procedures match current operation; MOC backlog reconciliation.

Compliance Verification

Monitor procedure compliance through observation, behavioural-audit, and post-incident root-cause analysis; trigger refresh on systematic deviation.

Implementation flow

Element-implementation flow chart

Decision-gated workflow showing the actual sequence of activities — from initiation through steady-state operation — with key decision points highlighted.

Start
PSM owner audits operating procedures programme
Required-Scope Inventory
Normal / startup / shutdown / abnormal / emergency per OSHA (f)
Gap Identification
Map current procedures against requirement; flag missing / stale
Task Analysis
Operator-led task decomposition for new / refresh procedures
Procedure Authoring
Template: purpose, scope, safety, steps, troubleshooting, references
Operator Validation Walk-Through
Field validation with shift team; capture practical corrections
Decision
Operator Signoff?
Decision gate
Issue & Workstation Delivery
DCS HMI / tablet / paper at workstation with safety-critical warnings
Training Delivery
Operator training on new / revised procedure
MOC Integration
Procedure update gate enforced before MOC closure
Annual Certification
OSHA PSM (f)(3) walk-down + signoff
Deliverables

What we produce

  • Procedure inventory and gap register
  • Authoring template with safety / scope / steps / troubleshooting sections
  • Operator validation signoff records
  • Workstation delivery system (DCS / tablet / paper backup)
  • Annual accuracy certification protocol per OSHA PSM (f)(3)
  • Compliance monitoring and refresh-trigger framework
Common pitfalls

Where execution fails

  • Procedures describing idealised process that doesn't match plant
  • MOC discipline missing — procedures not updated on change
  • Operators working from notebooks, not authoritative documents
  • Annual certification done as paper exercise, not field walk-down
Related elements

Explore related elements in this framework

All elements in this framework

Risk Based Process Safety (RBPS) — full element index

Implement this element

Talk to us about implementing Operating Procedures

We can scope this element implementation against your facility, regulatory context, and existing management-system maturity — and integrate it with the other Risk Based Process Safety (RBPS) elements you already operate.