In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17.
Although I have used guideline for a very long time, it was really just out of habit – it’s not an accurate reflection of the intent of those documents.
First: Where did this Guideline idea come from?
Well, it all started back in the Employee Participation element which requires you to have a document that explains how you intend to comply with certain requirements.
1910.119(c)(1) – Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.
Over time we realized that these written plans of action were very useful and wrote them for every single PSM/RMP element. For whatever reason, the very first program I ever worked on called this the “Guideline for Employee Participation” and I just stuck with that wording for well over a decade.
Ok, so why call it a Written Plan rather than a Guideline?
Well, let’s look at definitions:
A dictionary definition of guideline is:
“General rule, or piece of advice”
The word plan defined in that same dictionary:
“a detailed proposal for doing or achieving something;”
“an intention or decision about what one is going to do.”
The word plan is really what we are going for: A decision about what the facility is going to do. The intent of these documents, whether they are called Written Plan or Guidelines, was always to document the detailed plan that the facility intended to follow in achieving compliance.
Anything else?
Actually, yes. Over the years we had to explain the above to several different inspectors: our Guidelines were actually our written plans. Frankly, it just got annoying explaining the same concept over and over again – especially when they had a point: Rightly understood the documents really are the written plan and general guidance usually used the guidelines terminology such as the IIAR Compliance Guidelines and the CCPS Guidelines for Safe Process Operations and Maintenance.
Do I have to change my documents if I use the templates?
Well, no you never really have to update your program to reflect our changes. That said, Should you? Yes, you should make the change whenever you update your program to the latest templates.
