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Procedure Solutions Management: Video Training Series: Ask An Expert
James Bennett

Ask an Expert – Procedure Writer’s Challenges

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Procedure Solutions Management: Video Training Series: Ask An Expert - Procedure Writer Challenges

Procedure Solutions Management, LLC – Video Training Series – Ask An Expert – Procedure Writer’s Challenges

Ask An Expert – Episode 3 – “What are some common challenges faced by procedure writers?”

Procedure writers/technical writers have complex jobs.  Amongst other things, they are responsible for understanding and writing for the appropriate level of detail, avoiding the creation of human performance error-likely situations , formatting complicated documents, ensuring consistency, fostering collaboration, and sometimes even project managing.  These responsibilities present procedure writers plenty of opportunities for problem solving…

In this segment of “Ask An Expert,” Procedure Solutions Management’s Managing Member, Darlene McCord, answers the question, “What are some common challenges faced by procedure writers?”

 

For more information on Technical Writing, subscribe to our blog using the link to the right of this post.  Or, visit our services page for more information on our staffing, training, or consulting services.

Stephen McCord

Nuclear Promise – Procedure and Work Instruction’s Perfect Storm – Part 2

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Delivering the Nuclear Promise.  As the industry changes and old processes are streamlined, the level of detail and elimination of human performance errors in technical documents becomes even more critical.

Part 2 – Nuclear Promise – Procedure and Work Instruction’s Perfect Storm

In Part 1 – Nuclear Promise – Procedure and Work Instruction’s Perfect Storm, I raised a concern based on my observation of challenges with regards to procedure and work instruction quality. These quality challenges include (but are not limited to):  inconsistencies in level of detail resulting from staffing changes associated with the aging workforce and organizational and process changes resulting from executing efficiency bulletins associated with delivering the nuclear promise.

Procedures and Work Instructions are at a critical crossroads today. Impacts occurring from the aging workforce and implementation of efficiency bulletins supporting Delivery of the Nuclear Promise are impacting the availability of experienced/trained resources needed to keep thousands of procedures and work instructions up to date.

Preventing human performance errors in the field requires high quality “consistently developed” procedures and work instructions. For many years and in many cases today, the focus has been on technical adequacy and nuclear safety. As the industry has matured, it was identified that a technical and nuclear safety focus alone was not sufficient in preventing procedure and work instruction user human performance errors. Over time, it was discovered that the usability of a document can be even more of an error-likely situation than a stringent focus on technical adequacy. With support from the Electric Power Research Institute (EPRI), Institute of Nuclear Power Operations (INPO), Nuclear Energy Institute (NEI),and Procedure Professionals Association (PPA) standards have been developed to create a human factored focus in order to eliminate negative trends the industry has experienced.

Through my interactions while traveling (consulting training, advising), I have observed several challenges that are very concerning:

  • The average years of experience of operations and maintenance staff is rapidly lowering.
  • Work instructions and procedures used many times previously are now resulting in stopped work as a result of insufficient detail.
  • Experienced staff that once pushed for instructions written at the “what-to-do” level of detail (in an effort ensure maximum flexibility) are now being replaced at a rapid rate with qualified yet inexperienced staff that demand a greater level of “how-to-do” detail.
  • Even supervisors, although qualified, often do not have the experience to answer in-field questions without referencing documentation that is frequently vague and interpretive.

In addition, requests for new or changes to procedures and work instructions are being sent to smaller numbers of procedure writers and planners and in many cases the upkeep of these documents has been handed back to the line staff and process owners as a collateral duty, second only to their primary job function.

These individuals, although they are technically qualified in their specific work discipline, often do not have:

  • Adequate computer skills (MS-Word). For example planners experienced in Passport, Maximo or SAP are being requested to write Level One work instructions in MS-Word. In some cases the staff is provided training on a company MS-Word Work Instruction template although the template training was insufficient as it was assumed the planners were proficient in MS-Word and many are not.
  • Adequate training with regards to content an format requirements.  Little or no training has been provided on a stations procedure and work instruction content and format requirements or in many cases no content and format requirements exist.
  • Human performance focus. No training or guidance has been provided that focuses the procedure writers and planners on the elimination of human performance error-likely situations. Too often the staff finds what looks like a well written document and they make it look like that, creating issues where human performance errors are carried forward.

In conclusion, the writing of procedures and work instructions is a critical job, not one intended to be performed as a collateral duty. This is, perhaps, even more pertinent today than it has been in the past.  Eliminating human performance errors requires consistency in document development. When untrained staff is tasked with document development as a collateral duty or a reduced number of existing staff are taxed with more work than they can reasonably perform, document quality will suffer and human performance errors will occur.

As the industry is changing and old “bloated” processes need to be streamlined and the level of detail and elimination of human performance errors in technical documents becomes even more critical, we must recognize the need for consistency in document development. Achieving the level of consistency needed to prevent human performance errors requires the qualification and support of trained dedicated procedure writers and planners.

Join us for an additional discussion of this issue in Part 3 – Nuclear Promise – Procedure and Work Instruction’s Perfect Storm. This final segment will focus on suggestions and creative ideas supported by existing industry guidance on how to eliminate the risk of human performance errors in procedures and work instructions in support of Delivering the Nuclear Promise.

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Eliminate human error likely situations and improve human performance.
Stephen McCord

Can Technically Correct Procedures and Work Instructions Fail?

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Over the last 58 years, the nuclear industry and its workers have grown and matured together. They have gained vast experience as the performance expectations improved significantly post Three Mile Island (TMI). Procedures and work instructions have evolved from simple “to-do” lists to detailed “step-by-step” instructions with specific usage requirements.

Over the last 58 years, the nuclear industry and its workers have gained vast experience as the performance expectations improved significantly post Three Mile Island (TMI). Procedures and work instructions have evolved from simple “to-do” lists to detailed “step-by-step” instructions with specific usage requirements.

Despite extensive regulatory and performance based focus, the nuclear industry continues to experience procedure and work instruction related events.  Unfortunately, many of these industry events trace back to documents that were evaluated through Quality Assurance Program controlled processes and deemed to be technically correct.

In an effort to improve human performance, industry leaders, such as the Electric Power Research Institute (EPRI), Nuclear Energy Institute (NEI), Institute of Nuclear Power Operations (INPO), and the Procedure Professionals Association (PPA) have responded to this challenge by creating or revising industry standards with a focus on eliminating human error likely situations while maintaining the standard requirements for technical adequecy.  Although these new/revised industry standards are available, nuclear power stations’ programmatic controls typically focus on compliance with Regulatory Guide 1.33, Quality Assurance Program Requirements, and ANSI N18.7-1976/ANS-3.2 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.  While it is true that procedures and work instructions evaluated under these controls may be technically “correct,” it is also true that focusing solely on adherence to these controls leads to missed opportunities in eliminating human error likely situations which leads to human errors and plant events.

At this point, the question routinely asked is…

“How after over 30 years of safe operation could we be in a position today where our procedures and work instructions, as identified by the staff, are lacking sufficient detail, are poor in quality, and, in some cases, do not meet industry standards while also containing numerous human performance challenges?”

To answer that, lets consider the following…

Shippingport Atomic Power Station was commissioned in 1958.  Over the last 58 years, the commercial nuclear industry and its workers have grown and matured together. They have gained vast experience as the performance expectations improved significantly post Three Mile Island (TMI). Procedures and work instructions have evolved from simple “to-do” lists to detailed “step-by-step” instructions with specific usage requirements. Today, we must recognize we are at a crossroads.

As these highly experienced nuclear workers retire, they are replaced by workers from other industries or workers just entering the workforce. These workers have not grown with the industry as it has developed, nor been privy to the the same experiences and growing pains. Thus, the modern nuclear worker requires a different type of tool that is not only focused on its technical adequacy, but is also developed to specifically address potential human error likely situations that the original workforce learned as the industry has evolved.

The original nuclear workers did not grow-up with computers as their primary tool to support their success as compared to the modern nuclear workforce today. As such, how the modern nuclear worker receives and comprehends information is not the same as what was envisioned with the release of Regulatory Guide 1.33 and ANSI N18.7-1976. Therefore, today the emphasis on human factoring during the development of procedures is essential versus a focus on ensuring only technical adequacy.

Today’s workers have grown up receiving, assimilating, and comprehending information differently. For example, a study conducted by the American Press Institute in 2015 revealed that Facebook was the number one news source for millennials on thirteen of twenty-four topics that were surveyed and number two on seven others.   According to the same study, when these individuals want to delve deeply into a subject, the majority don’t turn to newspapers, radio, or television.  Instead 57% go straight to a search engine. Social interactions are evolving as well thanks to the introduction of SMS, Twitter, Instagram, Snap-chat, etc. where all of this communication is performed in short bursts of information. Basically, these workers expect to communicate and receive information in this manner. When handed a 100 page technical document where it is common to find multiple thoughts per step and vague interpretive guidance, the gap from their norm introduces a significant human error likely situation.

Conclusion

Technically Correct Procedures and Work Instructions can still fail, especially when you take into account the aging workforce, the experience levels of those entering the workforce, and changes in technology and information consumption.  In order to prepare procedures and work instructions for the new nuclear workforce, a new paradigm is needed with the following considerations:

  • The nuclear industry must recognize that the quality assurance standards content as it relates to procedures and work instructions has not been revised since the mid 1970’s with regards to procedures and work instructions. The requirements do not support the modern nuclear work force as it is evolving today. Quality assurance standards should be evaluated with a specific focus on human performance versus a technical only approach.
  • The industry standards created by EPRI, INPO, NEI, and the PPA are essential tools that should be considered for placing a greater emphasis on the human factors associated with technical writing versus a focus on technical writing alone.
  • Nuclear Power Reactor Operators must recognize that the tools designed to improve human performance require a trained “human factored” technical writing staff that is available to continually create or revise procedures to the newer industry standards.

For more information on Human-Factored Writing and other Procedure Writing Tips, subscribe to our blog using the link to the right of this post.  Or, visit our services page for more information on our staffing, training, or consulting services.