Determining Procedure Management System Requirements

Table 2-3, List of Procedure Elements, lists the elements related to procedures and procedure control and indicates which guideline(s) and/or regulation(s) identify the element. It is intended to be used as a checklist to help you determine which elements are appUcable or required for your facility. Methods for addressing the elements required to design an effective procedure management system are discussed in Chapter 3.

Determine your procedure management system requirements. 

Chapter 2 discussed various initiatives and regulations that may be applicable and that help determine what procedure management system must deliver. The checklist presented as Figure 3-2 addresses some common requirements and can be customized to meet your facility s needs. 

The general purpose of an audit may be to determine if the toller has management systems and documented procedures in place to ensure process safety, environmental responsibility, product quality and traceability of materials. The need to audit could be to evaluate compliance with regulations or accordance with client requirements related to specific performance elements. A subjective rating system for ranking management systems audit results is often used. An example of one that might be appropriate is shown below ... 

The audit team, through its systematic analysis, should document areas that require corrective action as well as where the process safety management system is effective. This provides a record of the audit procedures and findings and serves as a baseline of operation data for future audits. It will assist in determining changes or trends in future audits. 

Evaluate each task to determine if the task will require a written procedure. Factors that determine if a task requires a written procedure can be the frequency, criticality, and complexity of performing the task. Other factors can include regulatory requirements such as the OSHA 1910.119 Process Safety Management Rule procedure requirements. For example, starting a simple pump may not require a written procedure because it is a very simple task that people are trained to do from memory. However, starting a compUcated pump with many auxiliary systems or a pump that is critical to safety may require a written procedme to ensure the pump is always started correctly. 

Basically, CMMS/EAM provides computer software programs designed to assist in the planning, management, and administrative procedures required for an effective maintenance process. The need for a maintenance management system, whether manual or computerized, is determined by the need to perform effective maintenance on assets, equipment and facilities. We can think of CMMS/EAM as providing the business system for maintenance operations. 

BS OHSAS 18001 2007. Occupational Health and Safety Management Systems— Requirements, a British Standards Institution pubhcation. In the 2007 revision, requirements for risk assessments are more explicit. The guidehnes now say The organization shall estabhsh, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment, and determination of necessary controls. Significantly, the term tolerable risk was replaced by acceptable risk. ... 

For each risk assessment/SIL determination study, dutyholders should be able to justify each claim, and data used in the risk assessment, and ensure that appropriate management systems and procedures are implemented to support those claims. For COMAEI top-tier sites this will form part of the demonstration required within the safety report. Of particular importance is the reliability and diversity of the independent layers of protection. To avoid common mode failures extreme care should be taken when claiming high reliability and diversify, particularly for multiple human interventions. 

To determine the procedures you need you should design the system from the top down. Some requirements will apply to many operations such as document control, corrective action, and quality records whereas other requirements may apply to only one operation, such as auditing and management review. A matrix showing this relationship is given in Appendix D. 

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