Special Procedures and Training

Where other risk reduction methods cannot adequately mitigate the risk from a hazard, incorporate special procedures and training. Procedures may prescribe the use of personal protective equipment. 

NASA has developed an extremely useful hierarchy of hazard reduction (National Aeronautics and Space Administration, 1993). This method is applicable to all industries. The first step is to design out the hazard. If this is not possible, then the next best is to use safety devices. If safety devices are not sufficient control, then cautions and warnings can be applied. And finally, special procedures and training can be used to control the hazard or mitigate the consequences. 

The facility hazard analysis follows the same path and sequence of order as the hazard analysis process (review Figure 5.2 to refresh your memory). As mentioned in Section 2.6, the safety managanent system in a facility should also use the hazard reduction precedence design out the hazard, use safety devices, use warning devices, and finally, use special procedures and training. 

Recommended mitigating action (DSF, safety devices, warning devices, special procedures and training, caution and warning notes, etc.)... 

Because preparation involves specialized procedures and instruments, most of analytical laboratories have Sample Preparation Sections, such as Organic Extraction and Metal Digestion shown in Figure 4.2. (The General Chemistry Section does not have a separate preparation group, as sample preparation is usually part of the analytical procedure). Because laboratory accuracy and precision strongly depend on the individual s technique, sample preparation personnel must be trained in each procedure, and their proficiency be documented. The laboratory must have a set of SOPs for preparation methods performed and must ensure that the Sample Preparation Group personnel are trained to follow them to the letter. 

EXAMPLE 3 Eaults related to processes, procedures and training faults in control plans and in monitoring special characteristics faults related to software flashing and end-of-line programming. 

Develop procedures and training. Incorporate special procedures and special training to guide personnel in safe operations. Procedures may include the use of PPE. For hazards assigned catastrophic or critical mishap severity, avoid using this step as the only risk reduction method. 

Examples of procedures for conducting hazard studies are shown but these serve only as an introduction to the subject and do not cover the depth of knowledge needed by an individual to conduct such studies. Specialized textbooks and training courses exist for this work, which are largely the responsibility of a process or chemical engineer. The objective here is to show how such studies are used to provide a means of identifying hazards and specifying the requirements for risk reduction. 

Responding to incipient stage fires in confined spaces would be viewed as a special hazard condition under the Fire Brigades standard (29 CFR 1910.156). The employer is required to develop written procedures and train first responders to address situations involving special hazards. 

Tolling presents a special consideration that can make the training step easier. Typically a toller s technical staff, operators and mechanics are knowledgeable in the basic operations and tasks related to the toller s specialty. For example, experienced operators may know operations of the reactors, columns, exchangers, and packaging equipment quite well. The mechanical personnel may be very familiar with the required safe work practices, equipment cleaning procedures and maintenance tasks for standard vessels and piping. 

To limit the potential for deficiencies to escape detection before the product is released, special processes should be documented in the form of procedures and specifications that will ensure the suitability of all equipment, personnel, and facilities, and prevent varying conditions, activities, or operations. Qualification in the context of special processes means that you need to conduct a thorough assessment of the processes to determine their capability to maintain or detect the conditions needed to produce conforming product consistently. The limits of capability need to be determined and the processes only applied within these limits. In qualifying the processes you need to qualify the personnel using them by training and examination as well as the materials, equipment, and facilities employed. It is the combination of personnel, materials, equipment, and facilities which ensure qualified processes. 

The accident could have been prevented with better operating procedures and better training to make the operators appreciate the consequences of mistakes. Modern plants use interlocks or sequence controllers and other special safeguards to prevent this type of error. 

The most important person in the DEA laboratory system is the forensic chemist. DEA requires the trainee chemist to undergo a special six-month training program. He is taught from the outset that each piece of evidence is unique and no step-by-step procedure can be written to cover all cases. 

Design concepts were used to minimize hazards to personnel, to prevent corrosion, and to protect the environment. Special operating procedures, personnel safety equipment, and training completed these design concepts. An extensive ambient-air monitoring network was established to insure that ambient-air standards were met to protect the environment. 

Description of process/environment Quality-related critical parameters Purpose and objectives of the system Major benefits of the system Special requirements Specific training needs System operating strategy Related GMP compliance/regulations Physical and logical boundaries System GMP risk assessment System validation rationale Life-cycle documentation Assumptions and prerequisites Limitations and exclusions Quality-related critical parameters/data Standard operating procedures System requirement specification Supplier and system history... 

At this point a study should be undertaken to determine the benefits to be realized by the new facility as well as the costs to be incurred. Costs arise from not only construction but also ongoing operation and maintenance. These costs are affected by the plant location and the availability of a trained or trainable workforce. Does the day-to-day operation of the facility generally require that special attire be worn Are special procedures, possibly more time consuming than those presently used, required It is important that this study is complete and accurate in order to prevent any unrealistic expectations on the part of management and plant operations and to permit advanced planning for revised procedures once the facility is in use. 

It must be emphasized that EVOP is a routine method for permanent process operation, not an experimental procedure, and that it is used on the plant, rather than pilot, scale. It was developed to avoid undesirable characteristics of full-scale process experiments (e.g., short-term investigations that require special personnel and facilities, and usually make off-specification product). And, EVOP requires no special staff and can be done by the usual plant personnel after brief training. 

The Navy Warfare Development Command should develop and conduct innovative and provocative CW- and BW-relevant wargames and exercises, such as the Breeze series set up for the Commander, Fifth Fleet, and the Commander, Pacific. As an interim measure, it is recommended that CW and BW special weapons and tactics (SWAT) teams be set up by CFFC to validate readiness standards training exercises and tactics, techniques, and procedures (TTPs) for the fleet and shore establishment. 

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