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HUMAN FACTORS CONSULTANCY

Procedure & Operating Manual Reviews

We review operating procedures and maintenance manuals against human factors criteria — readability, task alignment, usability under pressure — so that the people who depend on them in safety-critical situations can actually use them when it matters.

Every procedure review engagement is led by Dr. Chizaram Dagogo-Nwankwo, Chartered Ergonomist (C.ErgHF, CIEHF), with published peer-reviewed research in human factors and process safety and direct experience in high-hazard operational environments.

Why procedures fail in practice

A procedure that is technically correct but practically unusable is not a safe procedure. It is a document that people have learned to work around.

In high-hazard industries, the gap between the written procedure and the task as it is actually performed is one of the most consistent findings in incident investigation. Procedures that are too long to read under time pressure. Steps written in passive voice with ambiguous subjects — who does what, in what sequence, using which equipment — left unclear. Warning notes buried mid-paragraph rather than positioned before the step they apply to. Version control so poor that operators aren't certain which copy is current.

The problem rarely starts with the operators. It starts with procedures that were written by engineers for engineers, reviewed for technical accuracy but never tested against the conditions under which they would actually be used.

HSE research into major accident investigations consistently identifies poor procedure quality as a contributing factor. HPOG (Human Performance Operations Guidance) sets out the human factors standards that UK high-hazard operators are expected to meet in their procedural controls. Most procedure libraries fall short.

Who needs this service

  1. Oil and gas operators and their contractors
    Operating and maintenance procedures on offshore platforms, onshore terminals, and pipeline systems where a procedural failure can initiate or escalate a major accident event. HPOG compliance is expected by the HSE and forms part of safety case submissions.
  2. COMAH-regulated chemical and process sites
    Facilities where procedures govern access to high-hazard plant, chemical handling, permit-to-work compliance, and emergency response. The quality of those procedures is a direct variable in the human error probability of the tasks they govern.
  3. Energy and utilities operators
    Power generation, transmission, and water treatment facilities where operations and maintenance are carried out under shift conditions, time pressure, and with plant that may be decades old. Procedures written when the plant was commissioned frequently no longer reflect how the work is done.
  4. Organisations following a procedure-related incident
    Where an investigation has identified procedural non-compliance or procedure quality as a contributing factor, a structured review and rewrite programme addresses the root cause rather than attributing blame to the operator.
  5. Project teams developing new facilities
    New operating and maintenance procedures developed during FEED or detailed design, reviewed against human factors criteria before they are embedded in training and pre-startup qualification.

What our procedure review includes

  1. Procedure library audit
    An assessment of the overall procedure management system before individual document review begins. Covers version control, document hierarchy, storage and access, update frequency, and whether the procedure library reflects the tasks operators actually perform. Problems at the library level affect every document in it.
  2. Human factors review against HPOG criteria
    Document-by-document review of selected procedures against the HPOG human factors standards. Assessment covers: document structure and navigation, step sequencing and task alignment, language and readability, positioning of warnings and cautions, use of tables, diagrams, and checklists, and consistency across related procedures.
  3. Task walkthrough verification
    Where access to the operational environment allows, procedures reviewed against the task as performed by the operators who use them. Task walkthrough identifies gaps between the written procedure and the physical reality of the task — missing steps, incorrect sequence, references to equipment that no longer exists, steps that require two people where the procedure implies one.
  4. Usability testing under simulated conditions
    For critical procedures, structured usability testing with representative users under conditions that approximate the time pressure, distraction, and fatigue typical of the operational context. Identifies failure modes that desk review misses.
  5. Rewrite and redevelopment
    Where review identifies procedures that require more than correction, we rewrite them to meet HPOG standards. Clear step-action format, active voice, unambiguous subjects, warnings positioned before the steps they apply to, appropriate use of hold points and verification steps.
  6. Writer's guide and style standards
    For organisations managing large procedure libraries, a writer's guide setting out the human factors standards and house style for procedure development. Transfers the knowledge so that future procedures are written to the same standard without repeated external review.

What good procedures actually look like

A procedure that meets HPOG human factors standards has specific, identifiable characteristics.

Steps are written in active voice with an unambiguous subject. "Open the isolation valve" rather than "the isolation valve should be opened." The operator knows what to do and what to do it with.

Warnings and cautions appear before the step they apply to, not after it. A warning that appears in step 7 about a hazard introduced in step 6 is a procedure that has already failed.

The reading level is appropriate for use under the conditions in which the task is performed. A procedure that requires careful reading to parse is a procedure that won't be read under time pressure.

Steps are sequenced in task order, not in the order the engineer thought of them. Steps that require verification or hold points have them explicitly marked, not implied.

The document is physically usable in the environment where the task takes place. A 40-page procedure for a task performed in a confined space with one hand occupied is not a usable procedure.

None of these are aspirational standards. They are the baseline that HPOG sets and that the HSE expects to find when it looks at procedural controls in high-hazard environments.

Frequently asked questions

How do you prioritise which procedures to review first?
We start with the procedures governing the tasks identified as safety-critical in the SCTA or risk assessment process. The highest-consequence, highest-probability error scenarios get reviewed first. After that, procedures for abnormal and emergency operations, which are typically used infrequently, under the most stress, and which tend to be the least well maintained.

Do you rewrite procedures or only review them?
Both. The engagement scope is agreed at the outset. Some organisations want an independent review with findings and recommendations that their own technical authors then action. Others want Nancheez to carry out the review and rewrite. Either model works; what matters is that the output meets the HPOG standard and that there is a process for keeping it current.

How long does a procedure review programme take?
It depends on the size of the procedure library and the depth of review required. A focused review of 20 to 30 critical procedures with a full task walkthrough typically takes six to ten weeks. A full library audit followed by priority rewrite of critical procedures in a large facility is a multi-month programme. We scope each engagement individually.

We've just had a procedure-related incident. Where do we start?
With the incident investigation first. A procedure review programme designed before the investigation has concluded risks solving the wrong problem. Once the investigation has identified where the procedural failure occurred and what contributed to it, the review scope becomes specific rather than speculative. We can support the investigation process and design the review programme in parallel.

Are you able to work on procedures in languages other than English?
Our primary working language is English. For operations where procedures are in use in other languages, we can review the English source documents and work with the client's translation and localisation team to apply the same criteria to translated versions.

Discuss a project

Procedure review programmes are scoped individually. Tell us about your operation, the driver for the review, and the size of the procedure library in scope, and we will come back within two working days with a proposed approach.

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