Writing Technical Procedures

A company’s operating and maintenance procedures and emergency procedures form the basis for everything that a company does. They are the underpinnings of the Operator Qualification (OQ) and Integrity Management (IM) programs. During an audit, they are one of the first things looked at, and all other activities are compared to what the procedures say. During litigation activities, the company’s activities will be compared to the precise wording of the procedures. As companies are scrutinized ever more closely by outside parties, good procedures are becoming more important than ever before.

Who Should Write Procedures

It is almost impossible for any one person to write procedures for an operator. Procedures should be written by a knowledgeable person, but once a procedure is drafted, it should be reviewed by personnel who will be involved with that procedure. It is advantageous for a single person to be responsible for coordinating all the writing, and performing the final editing. This person should maintain a uniform writing style and format within all the various procedures.

Basic Requirements

Procedures must be user-friendly. This is one of those tasks that is easy to say, but very difficult to perform. The procedures should be printed in an easy-to-read font. They must be written clearly. They should be as brief as possible while maintaining clarity. Procedures must give direction and guidance to operator personnel. They need to be written not only to provide that direction and guidance, but in such a manner that they cannot be misinterpreted. Keep in mind that procedures are often read by new personnel or others who are not familiar with operator operations.

Say it Only Once

Over time, it is very easy to introduce conflicts to a manual. The easiest way to reduce conflicts is to say things one time, and one time only. Then the statement can be referenced in other appropriate locations. If the statement is made twice, a modification to one of the statements may not be carried over to the second, and a conflict will be created.

Compliance with Code Requirements

It is essential that procedures comply with Code requirements. Note that certain parts of the Code require written procedures, while other portions of the Code do not.

There has been much confusion regarding whether Code language should be used in procedures. A common sense approach seems to work best. In areas where the Code is specific, it appears best to use the Code language as closely as possible. To modify Code wording simply for the sake of change could easily lead to subtle differences in meaning, whereas the intent is to mean exactly what the Code says.

On the other hand, where the Code is written in performance language, it is necessary for the operator to expand the wording to explain what is most appropriate and acceptable for its own conditions and situations. A good reference for determining what might be acceptable industry practice in complying with the various Code provisions is the Guide for Gas Transmission and Distribution Piping Systems, ASC GPTC Z380.1.

It is essential that the procedures accurately describe what the operator desires employees to perform. If there are any discrepancies between what the procedures say and what is performed in the field, then either the procedure or the action must change. This does not mean that the procedures need to be overly detailed. When it is appropriate (such as in responding to an emergency), the procedures should clearly indicate that the operator intends for the field personnel to have the flexibility to take actions based on field judgments considering the situation at hand and the information known at the time.

Companies should not feel obligated to organize their procedures the way the Code is organized. A company’s procedures are its own possession. They should be organized in whatever way is most appropriate for that company.

Appendices

Much information that is needed or helpful in procedures is difficult to fit into the text because of its bulk. For example, large tables, drawings, and figures may be important, but may not fit easily onto a page with other text material. A simple solution to this problem is to establish appendices after each procedure, if needed. When an appendix is used, it should be clearly linked to the text material that it applies to.

Page Headers and Footers

Each operator typically designs its manuals with unique page header and footer information to meet its own needs. This information may include such things as the operator logo, operator name, the name of the manual, Chapter number and name, Procedure number and name, page number, total number of pages, and revision date. It is very helpful to standardize this information so that it can be clear and brief and so that each page of the manual is clearly identifiable. To conserve valuable space, it is suggested that all this information be placed in the page header, so that there is no need for a footer.

Pagination should be formatted so that the page number is clearly associated with a particular procedure. That way, if a page is removed from a manual, it will not be reinserted into the wrong place in the manual. Page numbers should also indicate the total number of pages in the procedure (e.g., page 3 of 8).

Tables

Often tables can be used to present complex information in a quick and easy-to-understand manner. This is perhaps an extension of the adage “a picture is worth a thousand words”. With modern word processing, tables can be made very attractive and user-friendly. Each table is unique, and not every feature is applicable to all tables, but following are some features that can be used:

• Use dark gray lines rather than black lines so that the material in the table is not overpowered by the table itself.
• Use a light gray (10%) striping pattern to distinguish lines.
• If a table is lengthy, place it in an appendix with appropriate references.
  

Forms

Each form should be identifiable by a unique name and a form number. Often forms are referred to informally by a variety of names. For clarity, it is important that procedures be consistent with the names applied to forms. This effort is helped if the operator has a List of Forms.

It is very helpful to print the distribution and the required retention of each form directly on the document. This can be accomplished using small print at the bottom of the form. This helps to ensure that the proper retention is maintained, and that forms exceeding the required retention are systematically destroyed.

Index

An Index can be an extremely helpful tool for users of the manual, particularly for those who may be new to the company or to the department, or who may not be familiar with company operations.

The Index might cover an entry two or even three times, since a user may not always look for the same key word. For example, the required cover for plastic pipe could be listed under “cover, plastic pipe” and also “plastic pipe, cover”.

Electronic Format

Not many years ago, procedural manuals were typically visualized and used in the form of hard copy manuals. Today, many companies are using electronic formats. Even personnel in the field have access to procedures electronically.

There are many advantages to the electronic format. Probably the most obvious is the ease of making modifications, and the speed with which the modifications can be made available to the users.

Another very obvious advantage is that field personnel can have access to the entire manual. It was common for personnel to carry a few key pages of the operations manual that applied to the job they intended to perform that day. Now that information, along with all associated reference material, is quickly available if needed. And if the job changes as the day progresses, the procedures for the new task are also readily available.

Color is another tool that can easily be used. Color in hard copy manuals may be prohibitive, but with electronic formats, there is no additional cost to include color. Color in graphs or charts can show much more information very quickly and easily. Even photographs can easily be included.

Another advantage, often not thought about, is the improvement in security and retractability of the information. A non-rewriteable CD can be prepared, labeled, and dated after each change to the manual. This CD can be stored at a secure location off site so that the company can easily reproduce the manual exactly as it existed on any given day in the past. This can be a great help to a company’s Legal Department.

Hyperlinks

One of the greatest benefits of an electronic format is the ability to use hyperlinks. Procedures within a manual are often interlinked with many other procedures within the manual. With hyperlinks it is very easy to navigate instantly to a referenced link, and then back again. Wherever a hyperlink is used, provision should be made for the user to return to the original location. A complete manual may contain thousands of hyperlinks.

Each entry in the Table of Contents, the List of Forms, and the Index should be hyperlinked to the appropriate reference location. A good, useful index can be many pages long – hyperlinks can be used to “fast forward” to the desired part of the index (e.g., the beginning of listings starting with the letter “p”).

Hyperlinks can be used to navigate to another section of the same procedure, to an appendix, or to a completely different procedure.

Update Procedure

It is helpful to establish a procedure for continual review of the manual. Each month certain sections or portions of the manual can be reviewed by appropriate personnel. Over the period of a year, the entire manual will have been updated. This continuing review should be coordinated by one person, but the reviews should be performed by personnel familiar with the particular tasks. The review procedure can include a monthly schedule, which can then be documented.

Liability Reduction

There is no way to completely eliminate liability for a company, but there are many ways to reduce exposure without compromising the effectiveness of the procedures.

Phrases like “This procedure shall be strictly followed” should be avoided. The implication is that it is not necessary to follow all the other procedures. It should be clear to employees and contractors that, if a procedure states that something shall be done, it must be done.

Adjectives like “thoroughly” in the phrase “the pipe shall be thoroughly cleaned” should be avoided. The phrase “the pipe shall be cleaned” is just as effective, and is much clearer.

Words like “immediately” should be used with great caution. The intent is usually to have an action performed as soon as practicable, considering all the other factors that are occurring at the time and at that location, and not to drop everything no matter what the consequences are. The phrase “as soon as practicable” is usually better.

Pipeline Safety Policy

It is often helpful to create a procedure to generally cover the company’s pipeline safety policy. This procedure would serve as an umbrella over all the other procedures. It provides a place to write general guidelines that all engineering and operations personnel should be familiar with.

System Description

A description of the pipeline system is not required in an Operations and Maintenance Manual, but it can be very helpful to new users. What are the sources of supply, and what are the pressure systems in use? What kind of pipe is used? What is the age of the system? Are there storage facilities? Are there any other significant features of the operator’s piping system? These and other helpful pieces of information can be placed into the system description.