Over my career I have reviewed operations and maintenance (O&M) manuals for over 150 operators. Some of the features of the best O&M manuals include:
- Specifying what department or job title will handle the particular code requirement.
- When the work will be done.
- Where the work will be done and where the records will be stored.
- How the work will be done.
- What forms will be used to log the results.
- Specifying PHMSA code section references for each procedures to indicate what the procedure is intended to cover.
- Cross reference index between procedure numbers and code section numbers covered included.
The major don’t in writing or rewriting O&M procedures is to parrot the PHMSA code. PHMSA is expecting the operator to specify the details of the implementation of each code section not just feedback the code.
The PHMSA Part 192 Operations & Maintenance Enforcement Guidance Manual has the following guidance for writing O&M procedures:
- The operator must have written procedures addressing each requirement of §192.605. At a minimum, the procedures must include coverage of maintenance, normal operations, abnormal operations, safety-related conditions, and emergency conditions.
- An operator’s operations and maintenance procedures manual may vary in length and complexity depending on the specific equipment in service, the variety of facilities, the locations, and referenced versus incorporated material. The procedures must have adequate detail to clearly describe the manner in which each requirement will be met.
- The structure of the operations and maintenance procedures manual is not prescribed and may consist of a single comprehensive manual or multiple cross-reference volumes with referenced documents. The manuals can be made available to operations personnel as hard-copy or computer-based documents but must be accessible at locations where operations and maintenance activities are conducted. If the operations and procedures manual(s) are computer based, the operator must provide a means to access the procedures in the event of computer failure.
- Procedures that are unique to a particular facility must be accessible at that facility.
- Purchased or off-the-shelf O&M procedures must be fully customized to the operator to cover their specific operating requirements.
- In addition to operations and maintenance functions performed by field personnel, tasks performed by operations control, engineering, integrity
I recommend that during your next annual O&M procedure review you look to eliminate parroting of code and address the 6 guidance points above. I would be happy to help you re-write procedures.