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Risk Based Process Safety (RBPS)Manage Risk

Operating Procedures

Validated normal, abnormal, and emergency procedures kept current right at the workstation

Strategic context

What this element is and why it matters

Operating Procedures are the codified instructions for running every process, covering 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 of all. Texas City, Tesoro Anacortes, and BP Macondo each surfaced findings against PSM (f) in their CSB investigations, and our team writes and validates procedures so the people on shift can trust what is in front of them.

Operating Procedures

Individual significance for organisations

Operating procedures are the daily operating language of the plant. An organisation with current, validated, workstation accessible procedures runs operations with consistency and guards against the drift between procedure and reality that drives incidents. Operators who trust their procedures follow them, and those who do not fall back on personal notebooks, at which point the management system quietly collapses into hope.

Contribution to Risk Based Process Safety (RBPS)

Operating Procedures convert the output of Hazard Analysis (Element 7) 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 through PSSR (Element 14). MOC (Element 13) keeps them current and Auditing (Element 19) verifies their accuracy. Without the discipline of Element 8, the rest of the operational pillar runs from the wrong baseline.

Key requirements

What compliant execution looks like

Coverage of normal, abnormal, emergency, startup, and shutdown procedures
Authoring grounded in task analysis with operator validation
Annual accuracy certification per OSHA PSM (f)(3)
MOC discipline that triggers a procedure update before any plant change
Workstation accessible delivery through the DCS HMI, tablet, and paper backup
Verification of operator competency and procedure compliance
Implementation methodology

How we implement this element

A focused six step methodology calibrated to deliver operating procedures as a working capability rather than a documented compliance artefact.

Procedure Inventory and Gap Audit

We catalogue your existing procedures, map them against the required scope under OSHA PSM (f), and identify gaps in coverage, currency, and accessibility.

Task Analysis and Authoring

We conduct task analysis with operator input and author each procedure on a consistent template covering purpose, scope, safety, steps, troubleshooting, and references.

Operator Validation

We walk each procedure through with the operating team, capture the practical corrections they raise, and obtain formal signoff before issue.

Delivery and Accessibility

We integrate procedures with the DCS HMI, mobile tablet delivery, or paper at the workstation, make sure the shift team can see them, and place safety critical warnings prominently.

Annual Accuracy Certification

We run the annual procedure walk down per OSHA PSM (f)(3), capture operator signoff that procedures match current operation, and reconcile any MOC backlog.

Compliance Verification

We monitor procedure compliance through observation, behavioural audit, and post incident root cause analysis, and trigger a refresh wherever systematic deviation appears.

Implementation flow

Element implementation flow chart

A decision gated workflow that shows the actual sequence of activities from initiation through steady state operation, with key decision points highlighted.

Start
The PSM owner audits the operating procedures programme
Required Scope Inventory
Normal, startup, shutdown, abnormal, and emergency per OSHA (f)
Gap Identification
We map current procedures against the requirement and flag missing or stale items
Task Analysis
Operator led task decomposition for new and refreshed procedures
Procedure Authoring
A template covering purpose, scope, safety, steps, troubleshooting, and references
Operator Validation Walk Through
Field validation with the shift team to capture practical corrections
Decision
Operator signoff?
Decision gate
Issue and Workstation Delivery
DCS HMI, tablet, or paper at the workstation with safety critical warnings
Training Delivery
Operator training on the new or revised procedure
MOC Integration
A procedure update gate enforced before MOC closure
Annual Certification
An OSHA PSM (f)(3) walk down and signoff
Deliverables

What we produce

  • A procedure inventory and gap register
  • An authoring template with safety, scope, steps, and troubleshooting sections
  • Operator validation signoff records
  • A workstation delivery system spanning DCS, tablet, and paper backup
  • An annual accuracy certification protocol per OSHA PSM (f)(3)
  • A compliance monitoring and refresh trigger framework
Common pitfalls

Where execution fails

  • Procedures that describe an idealised process which does not match the plant
  • Missing MOC discipline, where procedures are not updated when something changes
  • Operators working from personal notebooks rather than the authoritative documents
  • Annual certification done as a paper exercise rather than a real field walk down
Standards & references

Codes this element is built on

OSHA 29 CFR 1910.119(f) (Operating Procedures, US)CCPS Guidelines for Writing Effective Operating and Maintenance ProceduresASM Consortium Effective Procedures PracticesMSIHC Rules 1989 Rule 4 (India)Factories Act 1948 §41B (India procedural requirements)ISA 18.2 and EEMUA 191 (alarm response integration)
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, then integrate it with the other Risk Based Process Safety (RBPS) elements you already operate.