Guidance Development is Final
That guidance document was issued after participation by industry, labor, and others with technical expertise in process safety, risk management, and human factors. The written program must now be developed by the affected sites and submitted to the County Health Department by January 2001.

Jo Haegert, an engineer with the County told AcuSafe News, "Because this is a guidance, it can be modified based on feedback from sites as they develop their programs." There is also a lot of flexibility allowed in how the written program can be developed. No cost estimates for compliance have been done, but one industry source indicated that just documenting the existing programs already in place would cost several thousand dollars. Development of some of the "new" programs would be additional costs.

The guidance document draws heavily on previously published guidance documents from the Chemical Manufacturer's Association and the AIChE's Center for Chemical Process Safety. The Contra Costa Guidance is now available as a 460K PDF file in its entirety at acusafe.com.

Some Areas will be New to Some Facilities
The Human Factors Program will be addressing some areas that may be new to some facilities. These include the consideration of human systems as causal factors in the incident investigation process for major chemical accidents as well as near misses. Another area that many sites will have to formalize is the requirement to conduct Management of Change prior to staffing changes for changes in permanent staffing levels/reorganization in operations or emergency response. Also, employees and their representatives must be consulted in the Management of Change.

PHA Human Factor Considerations
OSHA has required Process Hazard Analysis (PHA) for facilities and modifications to facilities since 1992. The County guidance document suggests that facilities should consider conducting procedural PHA's for two distinct situations. First, there are certain processes or activities for which a procedural PHA can provide a more thorough and efficient review than a traditional PHA (e.g., unloading/loading, complex valve configurations). Second, there are certain activities or procedures within a process that the source can identify as having "high active failure likelihood and high hazard potential." For these activities, the stationary source should conduct a traditional PHA on the process, but may also elect to conduct procedural PHA's on specific procedures conducted within the process (e.g., sampling).

Procedure Development Formalized
The suggestion is made in Chapter 6 of the guidance document that facilities must determine which operating procedures to write or to verify that they have written procedures for every task of the operation deemed necessary. The procedures must be written to avoid the latent conditions that could cause active failures (i.e., format, conciseness of statements, written for the user). This chapter applies to all operating procedures. Maintenance procedures and safe work procedures (e.g. hot work permits) were not explicitly included in the human factors element of County Ordinance; however, stationary sources should consider applying the basic principles of this chapter to all procedures.

Jo Haegert reported that actual development of procedures or revision of existing procedures could take longer than the January 2001deadline for submitting the plan. She said, "a reasonable time line could be submitted in the plan and then the County would track progress against that plan."

Some New Requirements for Task Analysis
Stationary sources must develop a process for procedure development that includes identifying the hazards associated with the tasks and incorporating input from personnel with expertise in the process. One method for developing comprehensive task descriptions and procedures is to conduct task analyses. Task analysis techniques may be applied during the design mode, audit mode, or retrospective mode. Task analysis can help to ensure that the most efficient method is identified and that discrepancies between individuals and shifts are eliminated. Task analysis results may be used as input to the content of operating procedures, training, and operating manuals. Task analysis results may also be used during incident investigations to explicitly identify differences in the prescribed way of performing a task and the actual way it was performed. Several acceptable task analysis techniques exist, such as Hierarchical Task Analysis, Tabular Task Analysis, and Timeline Analysis.

Human Factors Considered in Management of Organizational Changes
The CMA's Management of Safety and Health During Organizational Change is drawn upon heavily in the section that applies to managing organizational changes. It requires that each facility develop criteria or guidance to assist appropriate personnel in determining when an MOC for an organizational change should be initiated.

One such requirement is for a "reduction in the number of positions, or number of personnel within those positions in operations, including engineers and supervisors with direct responsibilities in operations; positions with emergency response duties; and positions with safety responsibilities."

Still another is "substantive increase in the duties in operations for those positions."

Some facilities in Contra Costa have already developed their internal procedures and started using these techniques in optimizing staffing levels on processing units.

The CMA publication advocates the use of a team to scrutinize staffing changes and the County guidance advises that this will satisfy the requirement that employees and their representatives be consulted in the Management of Change of organizations. The team should include employees and their representatives, as appropriate, from engineering, maintenance, and operations as well as safety and health. If you have further questions on the regulation or how to comply, contact AcuSafe for assistance.