230: Company Standards, Policies, and Administrative Controls (SPAC) Not Used

Node Company Standards, Policies, and Administrative Controls (SPAC) Not Used

Definition/Typical Issues

Were SPACs or directives not used, not adhered to, or not followed? Was communication or enforcement of SPACs inadequate? Were the SPACs recently revised or difficult to implement? Was there a failure to enforce the SPACs?

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.

Note 2: In addition to the node number, the company- or facility-specific SPAC may also be coded in the trending database to aid in trending of causes. For example:

  • If the root cause is the No SPAC or Issue Not Addressed in SPAC (#226) node; and
  • The issue is that the facility's procedure guidelines (say it's plant policy AD-01.7) only requires field validation of safety-related procedures, but not quality-related procedures; and
  • As a result of a procedure error that could have been corrected during field validation, unacceptable product was sent to a customer.

In addition to coding the root cause of No SPAC or Issue Not Addressed in SPAC (#226), AD-01.7 should also be entered into the trending database. This will allow the facility to specifically identify the SPAC that is associated with each root cause.

Examples

Example 1

  • A mechanic bypassed an important step in calibrating a key safety instrument because he did not take a printout of the procedure with him, as required. This was found to be common practice in the facility.

Example 2

  • A requirement was in place to have the operators check instruments in the field once per shift. The operators never performed the checks. Supervision was aware of the situation and never enforced the requirement.

Example 3

  • The surveillance testing for the fire protection system had not been conducted for the past 2 years. The requirements for performing the tests were not enforced.

Example 4

  • A corporate HSE standard addressed how materials were charged to reactors. However, the standard practices were not implemented at some facilities. As a result, an explosion occurred during a charging operation.

Typical Recommendations

  • Ensure that all levels of affected employees are aware of SPACs changes.
  • Take appropriate actions concerning those employees who choose not to use the SPACs.

Cross-References

Version 10 Element(s)
Node ID Node Name
67 Standards, Policies, or Administrative Controls (SPACs) Not Used

 

RBPS Element(s)
Process Safety Culture

 

Maritime Element(s)
Node ID Node Name
261 Company Standards, Policies, or Administrative Controls (SPACs) Not Used
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