I Don't Have A SOP For That Issue.

Author:Fisher & Philips LLP
Profession:Fisher Phillips LLP

I recently talked to a group of managers about misusing Standard Operating Procedures (SOPs) and the resulting safety and performance problems. Issues raised, included:

Employees justifying bad judgment by claiming that there was no SOP requiring them to perform a task in a safe fashion. Managers refusing to require employees to perform a task safely and in a common-sense way because there was no written SOP. Confusion about the roles of SOPs, work guidance, and policies. Conflict between unduly complicated SOPs and the actual steps to safely perform the task. Below are some observations and recommendations that we discussed over lunch:

Written guidance is not a substitute for using good judgment.

Employers must train employees to use their good judgment in determining how to safely perform a task. In highly regulated environments such as government labs, pharmaceutical manufacturers and nuclear power plants, employees may become scared to use their own judgment or have simply ceased to think that way. It is probably impossible to anticipate and list every conceivable detail about tasks, and if one did so, it would be so long that no one would consult it.

Managers should not try to excuse their failure to manage employees by claiming that they could not require employees to comply with safe practices because no written SOP existed. Was a practice understood and acknowledged? Did the employee's actions go against broad safety areas such as fall-protection, LOTO, or guarding?

Determine the role of the SOP.

Is the SOP a high-level reference to guide in the development of simple work steps? Is it the document to which you will train employees? Is it their day-to-day guidance?

If you determine to include in the SOP the applicable safety guidance, identification of hazards, and required PPE, ensure that all necessary elements are included.

Some employers incorporate the required information of a Job Safety Analysis (JSA) into SOPs, which makes...

To continue reading