I have visited several gas plants across the United States. Gas plants are complex facilities. They operate at high pressure with flammable materials and dangerous products. Gas plants are regulated by Process Safety Management standards to address the inherent hazards of operations.

When visiting gas plants, I make it a habit to stop in the control room and the maintenance office and engage operations folks in conversation. One thing I like to ask is whether the operators can show me the procedure for whatever operation is being done at the time. From there, it’s a discussion about how the procedures are used (or not), who wrote the procedures, do they work, and how are they revised.

I had the opportunity to compare two gas plants operating for the same client. They weren’t exactly the same in terms of size, age or complexity, but they were similar enough. They were operated by the same leadership team in the same country with some rotation of leaders between the sites. However, the approach to procedures varied significantly between the two plants.

One plant had operations procedures that were written, understood, and followed. The other plant, not so much. Why would there be so much variation between two plants in the same country and within the same company?

A look back in time provided some insight to the variation. Both sites had procedures. Site One commissioned a revision of all operating procedures and hired a retired plant engineer to write the manuals. And write he did. Volumes of detailed procedures were created. And when he was done, it was all codified in a manual. That sits on a shelf.

Thumbing through the manual, 1989 and 1996 seemed to be the latest revision dates of several policies. I didn’t use Microsoft’s analysis to tell me what grade level the procedures were written. They had long, run-on sentences with big, complicated words and very few illustrations.

Site Two, however, was a different story. This plant had just completed a review of their procedures, but the review had been conducted by the operators who used the procedures. Each page had lots of white space, a few diagrams, and a writing style that was simple and easy to understand.

At Site Two, operators carried their procedures in a notebook. Each notebook had a page for a signature that verified the employee was competent in that procedure. When competency was achieved, the signature was applied. While there are fancy systems to do the same thing, this actually worked.

Supervisors and peers cared about certification. The notebooks made it visible. Other tools, like ‘draw and describe’ and competency tests were used to support the certification process.

It should come as no surprise that Site Two used their procedures, and their operators knew what each procedure was and how to execute them. Leadership at the site focused on the use of procedures as part of their safety walk-abouts. They made it important.

Procedures at Site Two were also regularly reviewed. They were revised as if they were part of a regular preventive maintenance schedule. They were also reviewed as part of management of change processes when equipment was added, modified, or eliminated. And operators were confident that the procedures were right — because they created them and signed off on them. The culture of Site Two was to follow the procedures. If the procedures didn’t work, they were empowered to revise them.

The way to make sure a procedure gets used is to engage operators (and maintenance) in writing the procedures. Ensure that the procedures are written clearly, in a way that reflects how the work actually gets done. It’s easy to delegate the assignment to an ‘expert’ who will get the procedure technically correct, but operationally unusable. Look to the way lean manufacturing describes standard operating procedures:

• Few words.
• Step by step instructions.
• Illustrations.

The next time you are out in the field, review the procedures. Is your organization operating like Site One or Site Two?

Tips for Writing Procedures

When writing procedures

• Include the people who will use the procedures in the development process
• Ensure leaders engage employees in dialogs about procedures
• Keep the language of the procedures in ‘operator speak’
• Treat process knowledge and certification on procedures as the same thing
• Change the procedures if they don’t work in the field

About the Author

Laurence Pearlman is a Director with Corven, Inc. in Lisle, Illinois, U.S.A. He advises energy and natural resource clients on safety performance improvement and change management. Laurence specializes in engaging employees and leaders to drive ownership and sustainability of safety processes. Previously, Laurence worked for Amoco, BP, Exxon, and Pfizer. He is an adjunct professor at the University of Illinois. He was part of the team that assessed the culture of BP Refining after the Texas City incident and identified leadership and cultural interventions to reduce risk. He holds degrees from the University of Illinois and the University of Iowa.

EHS Journal Articles by Laurence Pearlman

• Is Your Contractor Safety Program in the Toilet? Maybe it Should Be!
• Does Operational Discipline Replace Strong Safety Leadership?
• Safety Incidents: Leadership, Learning, and a Single Word
• Contractor Safety Management—Getting Back to Basics

Photograph: Ring Binder 3 by Michaela Kobyakov, Linz, Upper Austria, Austria.

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