A Safe Operating Procedure is a variation of the term Standard Operating Procedure (SOP). An SOP is a formal detailed work instruction, often used in manufacturing and logistics, to ensure that work is completed in the manner required for quality purposes. Where appropriate, the SOP takes account of the risks so that it can be considered a safe work procedure.
There are times where it is not appropriate to rely on informal organisational knowledge that is passed between employees through social interactions and work-related discussion that is not centrally governed.
Formal SOP records are a documented, standardised and a centrally managed way of working that enable approval and oversight for improving business decision making. A formal SOP record is typically a set of step-by-step instructions designed by an organisation to help workers carry out routine operations.
SOPs aim to achieve quality output, consistency of performance and efficiency, while reducing miscommunication and failure to comply with work instructions including those for ensuring the safety of workers. There is no set format on how this should be recorded but there are common inclusions to any format and there are sources of best practice for writing work procedures.
|SOP Document No.||A unique number that can be used to identify, locate and reference this work procedure.|
|SOP Title||An intuitive title to assist with recognising the work procedure.|
|Scope of SOP (description||Describe the purpose of the work procedure and it's context to the wider processes. This will include any assumptions and prerequisites that are relied upon for the SOP to be valid and safe.|
|Relevant People||Identify who the document is intended for, it will need to list the roles and responsibilities, and contact information for coordinating personnel.|
|Relevant articles & work equipment||Where the work procedure uses certain equipment, substances or tools etc then these shall be referenced in the work procedure. The detail/accuracy used for the reference shall be in proportion to risk/consequence that may occur should the incorrect article be used for the job.|
|Related Risk Assessments||Where the work procedure is supported by one or more risk assessments these shall be recorded against the SOP for auditing and review purposes.|
|Section||For longer or more complex work procedures identify the discrete sections to make it easier to read.|
|Step by step process||This section is where the procedures are broken down into step-by-step instructions with the relevant information. For example, "What equipment will be used?" You may want to add supporting resources for example a flowchart, photos, audio and video to improve understanding and communication of the work procedure.|
|Glossary||If you use special terms or jargon, each should be explained in full within the procedure or in a supporting document that is linked to the procedure and displayed in all locations where the parent procedure is displayed.|
|SOP Checklist||Some SOP'S rely on a checklist for the worker to record that certain actions or process critical parameters were met for quality reasons. This is not common for simple and high frequency tasks. Checklists can be helpful when it is necessary to log actions for quality reasons or where the tolerance for human error is very low due to the risks that my result from it.|
Quality, productivity and safety are the main drivers behind development of SOPs for your business.
Quality and productivity motivation occurs naturally as it directly linked to the primary objectives of the business i.e., to make money.
Safety (or the absence of it) does not always show up in the decision making of a business. For this reason there is safety law in the UK and most other countries around the world, that require it be properly considered. Surveillance and enforcement is provided in the UK by the HSE and other agencies to ensure that employers are taking their safety duties seriously.
Unfortunately, many interventions are post-incident where lives have already been lost or permanently damaged often in a manner that could easily have been avoided by the proper arrangements.
As documented by the HSE, there have been many recorded incidents where failings by operators have been the main contributing cause of major accidents;
"Provision of clear, concise and accurate operating procedures is the most effective measure to prevent, control and mitigate such events"
Process operatives should be provided with guidance concerning the required operating philosophy to ensure that they comply with procedural requirements to keep themselves and others safe.
Post accident, the SOP is the most basic requirement your business and its senior managers need to evidence a safe system of work and mitigate the impact on the business in terms of investigation time and production interruption e.g., prohibition notices issued by the HSE. The absence of an SOP where there should have been one will leave the senior managers and owners open to accusations of profit before safety.
A business may choose where a formal SOP is required. The criteria and their trigger points for this will vary for each application but broadly can be split into:
The risks should be identified at the planning phase where discrete work activities are logged, and risks classified to inform decision-making for where a more detailed risk assessment is required e.g., a managed risk assessment (MRA), training, levels of supervision and in extreme cases, whether work activities should be stopped until corrective actions are taken.
Business risk is where human error can result in loss to the business e.g., time, material, or reputation or accreditation. Business risk concerns are normally addressed through the quality assurance systems and can result in an SOP even where no personal risk is identified. Personal risk is where workers (or other relevant persons) related to the business activities may be harmed as a result on human error including working without the appropriate controls in place.
There is a threshold in some safety legislation where if personal risk is significant (i.e. can cause major injury) then it becomes a duty that it be addressed formally and the failure to do so will result in a business risk. In certain cases, this can also expose senior managers and owners to risk of prosecution individually.
For this reason, where the initial risk assessment identifies a significant risk (i.e. one that can reasonably foreseeably result in a major injury) then, organisations have a duty to investigate further to determine what part of that risk is avoidable taking account of the appropriate duty level.
There are many work activities that occur without them needing to be formally defined for business need whether that be quality, productivity or safety.
Safety law permits this to ensure that the workplace does not become unduly restricted by bureaucratic dogma, specifically, the idea that no work activity is safe unless it has been risk assessed in detail. All work activities must be safe (so far as reasonably practicable) but not necessarily defined in detail within combination with a detailed risk assessment.
Under Section 2(a) of The Health and Safety at Work etc Act 1974 ( HSAW) employers must, ‘so far as is reasonably practicable’, provide and maintain systems of work that are practical, safe and without risks to health.
A Safe System of Work (SSoW) is a set of arrangements including standard operating procedures (SOPs) with underpinning risk assessment, with the objective to recognise hazards and their controls to remove or reduce the risks to employees and other persons in the workplace. This applies to all industries, especially those where safety depends on working in defined ways or with certain behaviours with awareness of relevant hazards and controls.
The SSoW is needed to standardise practices for tasks where the risk managed by behaviour or the method of working is significant to the health and/or safety of relevant persons.
SOPs must involve a holistic approach and not one that deals with each factor in isolation. This approach should involve:
1) Identify ALL work activities by type
2) Risk classify the work activity types
3) Where there is significant risk set the requirement for an SOP to be defined. Consider setting time-based targets in proportion to the risk. E.g. where risk is significant within 1 month, where risk is high then within 1 week. Note, where a work activity does not represent a significant risk a judgement should still be made as to whether it is a safe work procedure but there is no requirement to formalise that safe work procedure.
4) Instruct the relevant departmental managers and supervisors continue the process below
5) List specific work activities of the types identified above. You may group similar activities where it benefits understanding to do so.
6) Define each work activity in sufficient detail and ensure that steps recorded are those commonly done by operators or workers rather than those that you might want them to do. This is necessary to ensure the process is meaningful. If you want to change the working procedure to make it safe (or safer) then, this can be done once the entire working procedure has been considered.
7) Identify hazards, estimate risk (without controls or as if they have failed)
8) Identify existing controls that are in place to reduce the likelihood of occurrence or the severity of consequence for the hazards identified as relevant to work procedure
9) Estimate the risk assuming these controls are effective. Note, controls that rely on behaviour will never eliminate risk.
10) Evaluate the risk after application of the existing controls to decide whether this can be issued as a safe working procedure i.e. whether adequate risk reduction has been achieved.
11) If adequate risk reduction is achieved, then issue the work procedure for use. If not then, add new controls and re-evaluate.
Communication is a central part of any safety initiative in the workplace. It will include a flow of information and views between all relevant stakeholders. With regards SOPs, communication started during the early drafting stages and culminates with the release of an approved formal record ready for implementation.
Comprehensibility is key to communicating an SOP. The content of the SOP must be presented in such a way that it is easier to comprehend relative to those that are expected to be competent in it. This can be achieved by:
As a continuation of communication, the issued SOPs are deployed through various forms of training e.g. tool box talks, on the job training, video/online learning etc. These are made readily available to the workforce including the supervisors.
Employees work under an appropriate degree of supervision. A part of the role of the supervisor is to ensure that employees and workers are operating in line with the relevant SOP. Where this is found not to be the case then, the supervisor is expected to correct the behaviour and/or trigger a review of the SOP where improvements can be made.
It is necessary to review SOPs on a regular basis e.g. once per year. There should also be mechanisms that encourage employees, through their supervisors, to trigger a review of the SOPs where opportunities for improvement are identified.
When judging the suitability of the detail captured, keep in mind the purpose of the information being to:
1) Facilitate training of new starters (greater detail required with a low level of prior knowledge assumed)
2) Facilitate refresher training of existing employees
3) Communicate hazards and controls in context to the discrete steps within it
If the SOP is too general, vague or assuming then it will not be sufficient to instruct workers and may result in poor quality work or unsafe practices.
Employers will identify work activities, sometime by type, early on in their approach towards compliant SOPs. When doing so a risk profile is given to that work activity and this determines whether a more detailed work instruction is needed. The compliance objective is to ensure that a detailed SOP and risk assessment are completed for all work activities that involve a significant risk. The work procedure planning risk profile should be based on what could foreseeably go wrong. Where controls depend on competent behaviours there will always be a likelihood of occurrence that is not zero. The absence of accident history shall not be grounds to disregard a risk relevant to an SOP in that case. The reasonably foreseeable worst-case consequence/severity assuming the absence or failure of the appropriate controls shall be used.
Armed with a list of work activities and their risk scores you can now draw a line to separate those that are significant from those that are not. Those work activities that are above the line require a SSoW to be defined that shall include an SOP and the underpinning risk assessment of that work activity.
It is important that the SOP is communicated to employees. This is typically done by training (and training records). Good practice requires a record not only of delivery but of understanding so training records should include a record of assessment e.g. observed on the job, questions to check knowledge etc. This means you can be sure the employee has the best chance to avoid hurting themselves or another person. Training should be repeated at intervals and when significant changes occur.
Authorisation is where the relevant supervisor/manager reviews the training record to determine, taking all factors in to account including the individual’s circumstances, whether the person shall be permitted to work. Authorisation is necessary to give line managers control over who has been deemed competent and is their opportunity to account for the employees attitude and approach to work as well as specific characteristics that may increase the risk for that worker or other relevant persons during that work activity.