Operating procedures are the written instructions that ensure employees safely and consistently operate covered processes. Under 29 CFR 1910.119(f), employers must develop and implement clear, written procedures for each covered process addressing all phases of operation. These procedures connect directly to your process safety information, drive your training program, and must be certified as current and accurate every year. Ecesis PSM software provides document management with version control and approval workflows to keep your procedures current and accessible.
What OSHA Requires
Under 29 CFR 1910.119(f), employers must develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process. Procedures must be consistent with process safety information and must address:
- Steps for each operating phase: Initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown
- Operating limits: Consequences of deviation and steps to correct or avoid deviation
- Safety and health considerations: Properties and hazards of chemicals used, precautions to prevent exposure, control measures for physical contact or airborne exposure, quality control for raw materials, hazardous chemical inventory control, and special hazard information
- Safety systems and their functions
Procedures must be readily accessible to employees, reviewed as often as necessary to ensure they reflect current operations, and the employer must certify annually that they are current and accurate.
Step-by-Step Implementation
Inventory Procedures Needed
Create a master list of all operating procedures required for each covered process. Organize by process unit and operating phase. Identify which procedures already exist (even informally) and which need to be written from scratch. This inventory becomes your development roadmap and ongoing tracking tool.
Write Procedures Using a Consistent Format
Develop a standard procedure template that ensures every document addresses OSHA's content requirements. Each procedure should include:
- Purpose and scope identifying the covered process and operating phase
- Step-by-step instructions written clearly enough for the intended audience
- Safe operating limits (temperature, pressure, flow, level, composition) with the consequences of exceeding each limit
- Steps to correct deviations from safe operating limits
- Safety and health hazards specific to the operations described
- Required personal protective equipment
- Safety system functions and interlock descriptions relevant to the procedure
- Emergency actions specific to the operations described
Have the procedures written or reviewed by personnel who actually perform the work, and reviewed by engineering for technical accuracy.
Implement Accessibility and Training
Procedures are only useful if employees can access them when needed. Ensure:
- Procedures are available in process areas (physical copies or electronic access at workstations and through mobile devices)
- Each employee involved in operating a covered process has been trained on the procedures relevant to their job tasks
- Language barriers are addressed if employees have limited English proficiency
- Procedure locations are identified and communicated during new employee orientation
Establish Annual Certification
OSHA requires the employer to certify annually that operating procedures are current and accurate. This means more than simply signing a cover page. The annual certification process should:
- Involve operators and supervisors who use the procedures daily in the review
- Verify that procedures reflect any process changes made during the year (cross-reference with MOC records)
- Confirm safe operating limits are still valid
- Update procedures to incorporate lessons learned from incidents, near misses, and PHA findings
- Document the review with reviewer names, dates, and a certification statement
Schedule annual certifications in your compliance calendar to ensure they are not overlooked.
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software ensures your operating procedures stay current, accessible, and properly controlled:
- Document management: Version-controlled storage with built-in review and approval workflows that prevent outdated versions from remaining in circulation
- Mobile access: Operators access current procedures through the Ecesis mobile app directly in process areas
- MOC integration: Change management workflows automatically flag procedures that need updating when process modifications are approved
- Compliance calendar: Annual certification deadlines are tracked automatically with advance notifications to responsible personnel
Frequently Asked Questions
How detailed do operating procedures need to be?
Detailed enough that a qualified employee can safely perform the operation by following the procedure. The level of detail should match the complexity and risk of the operation. Simple, routine tasks need less detail than complex startup sequences or emergency procedures.
Do we need separate procedures for each operating phase?
You need to address all seven operating phases OSHA lists (initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround). These can be separate documents or sections within a comprehensive procedure, as long as all phases are covered.
What counts as annual certification?
A documented statement that the operating procedures have been reviewed and are current and accurate, signed by a responsible person with the date. The certification should be supported by evidence that an actual review was conducted, not just a signature on a form.
Can operating procedures be electronic-only?
Yes, as long as they are readily accessible to employees who need them. Electronic procedures stored in a document management system with mobile access or workstation terminals in process areas satisfy the accessibility requirement. Many facilities maintain a backup set of critical emergency procedures in hard copy.
How do temporary operations affect procedures?
Temporary operations must have their own written procedures addressing the specific conditions, hazards, duration, and limitations of the temporary arrangement. These are typically developed as part of the management of change process and should include clear criteria for returning to normal operations.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
