2018 RETA Breeze Jul-Aug

SAFETy What is a Maintenance Procedure? Why do I care?

Normal operations; Temporary operations;

Safety systems and their functions. Operating procedures shall be readily accessible to employees who work in or maintain a process. e operating procedures shall be reviewed as o en as necessary to assure that they re ect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. e employer shall certify annually that these operating procedures are current and accurate. e employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; con ned space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. ese safe work practices shall apply to employees and contractor employees. In the preamble: “OSHA believes that it is important for employees to use consistent work practices for jobs posing equivalent hazards. It may, indeed, introduce dangers if an employee has to vary the work practices used for a job depending on slightly di erent circumstances unrelated to safety. e Agency attempts to make its standards consistent across industries for similar situations, but it is not always possible

We are constantly ooded with good practices, suggestions, recommendations, and requirements. Whenever I see a new one, the rst thought is “Do I care?” Well this is one of those times when the answer is a resounding YES! First let’s look at what a maintenance procedure is not. A Maintenance Procedure is not a Standard Operating Procedure. Per Wikipedia, “An SOP is a written document or instruction detailing all steps and activities of a process or procedure. ISO 9001 essentially requires the documentation of all procedures used in any manufacturing process that could a ect the quality of the product. [1]”. is is taken from the Guidance on the Documentation Requirements of ISO 9001:2008 OSHA (Occupational Safety and Health Administration) has de ned the scope of Standard Operating Procedures. e employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. Steps for each operating phase: Initial startup;

Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to quali ed operators to ensure that emergency shutdown is executed in a safe and timely manner. Emergency Operations; Normal shutdown; and, Startup following a turnaround, or a er an emergency shutdown. Operating limits: Consequences of deviation; and Steps required to correct or avoid deviation. Safety and health considerations: Properties of, and hazards presented by, exposure, including engineering controls, administrative controls, and personal protective equipment; Control measures to be taken if physical contact or airborne exposure occurs; Quality control for raw materials and control of hazardous chemical inventory levels; and, Any special or unique hazards. the chemicals used in the process; Precautions necessary to prevent

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