225: Company Standards, Policies and Administrative Controls (SPAC) Issue
Definition/Typical Issues
Was there a failure to develop standards, policies, or administrative controls (SPACs) that apply to the task? Are they inadequate or inadequately implemented? Were the SPACs inaccurate, confusing, incomplete, unclear, ambiguous, not strict enough, or otherwise inadequate?
Note 1: SPACs provide guidance on how an activity should be accomplished, whereas procedures provide a detailed, step-by-step method for performing a specific task. For example, there are SPACs that describe the policies governing scheduling of workers. There is also a procedure that provides a detailed, step-by-step process for performing the task, including the forms to complete and data to enter into the computer system.
Examples
Example 1
- A mechanic installing a cable tray drilled into a live wire within a wall because the facility drawings he was using were not up to date. A management system for control of electrical drawings may have prevented this occurrence by ensuring that the mechanic had up-to-date documentation. A management policy/procedure would also be required to ensure that such drawings are obtained/reviewed as part of the work permit system for penetrations into any wall.
Example 2
- An operator was unable to read at the level needed to understand facility procedures because employee screening policies did not include a requirement for performance testing (including having the prospective employee read and explain a portion of a procedure). As a result, he made a serious mistake in operating a key piece of equipment.
Typical Recommendations
- Provide written documentation of SPACs.
- Ensure that all levels of affected employees are aware of SPAC changes.
- When errors are found, modify SPACs accordingly.
- Ensure that policies regarding production, material control, procurement, security, etc., do not contradict safety policies.
Cross-References
| Version 10 Element(s) | |
|---|---|
| Node ID | Node Name |
| 55 | Administrative/Management Systems |
| 57 | Standards, Policies, or Administrative Controls (SPACs) LTA |
| RBPS Element(s) |
|---|
| Process Safety Culture |
| Maritime Element(s) | |
|---|---|
| Node ID | Node Name |
| 256 | Company Standards, Policies, or Administrative Controls (SPACs) Issue |