Below, I've documented three (3) of the fourteen (14) PSM Elements I believe implementing your e-procedure process would positively impact; both compliance and performance.
OPERATING PROCEDURES: The "MO" for most organizations is to develop and maintain consistently formatted procedures with very prescriptive management protocol. This is an excellent strategy to ward off regulators; briefly. Today's compliance officers are more savvy than yesterday's and recognize procedure performance is more critical to safe operations than procedure maintenance. Regulators and organizations used to be content to audit and manage procedure encyclopedias that simply served as a safe harbor for dust bunnies. This heightened focus on procedure performance opens the door for your e-procedure process.
TRAINING: The majority of organizations deploy a similar management strategy for training as they do for procedures; maintain an exotic "matrix" and measure their compliance by generating training attendance and/or exception reports. Like procedures; focus is on compliance with minimal attention paid to performance. Having "real time" access to learning modules "in the field" will result in enriched skills leading to event free execution of tasks.
MECHANICAL INTEGRITY: All maintenance activity is "governed" through the MI Element of PSM. Having "in the field" access to PM protocols; JHAs/JSAs, vendor/manufacturer information; engineering specifications and other maintenance directed procedures/training improves both human and equipment reliability and performance.
Tim; your process pumps life into and adds value to procedures by nurturing "real time" use and feedback. Having "in the field" access to drawings; pictures and to the entire pallet of the organization's databases is HUGE and will result in immediate ROI in the form of improved performance; fewer unplanned events and overall enhanced organizational health.
The 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:
Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
Normal shutdown; and,
Startup following a turnaround, or after an emergency shutdown.
Consequences of deviation; and
Steps required to correct or avoid deviation.
Safety and health considerations:
Properties of, and hazards presented by, the chemicals used in the process;
Precautions necessary to prevent 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.
Safety systems and their functions.
Operating procedures shall be readily accessible to employees who work in or maintain a process.
The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.
In lieu of initial training for those employees already involved in operating a process on May 26, 1992, an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.
Refresher training. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.
Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process equipment:
Pressure vessels and storage tanks;
Piping systems (including piping components such as valves);
Relief and vent systems and devices;
Emergency shutdown systems;
Controls (including monitoring devices and sensors, alarms, and interlocks) and,
Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.
Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.
Inspection and testing.
Inspections and tests shall be performed on process equipment.
Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.
Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.
In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used.
Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions.
The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.