A procedure, instruction and permit are not the same
A procedure may cover an entire activity, such as maintaining an installation, and assign functions to several people. An instruction specifies how to perform a task, what to check beforehand and what to do if an abnormality occurs. Its length should reflect actual complexity.
A permit to work authorises an intervention under specified conditions; it does not replace the execution method. Nor does the manufacturer’s manual always describe integration of the equipment at that site, its interference with other operations or coordination with other tasks.
When a task should be documented
Prioritise activities with significant consequences if performed incorrectly, infrequent operations, tasks involving several people or interfaces, and work dependent on a critical sequence. Job safety analysis helps break down the activity and identify points needing control.
There is no general obligation to create the same form for every task. Specific requirements depend on the risk. For work equipment, Article 5 of Royal Decree 1215/1997 requires understandable information, preferably written, about correct use and foreseeable abnormal situations.
Minimum content for a usable document
- Scope: task, equipment, locations and situations covered.
- Responsibilities: who prepares, performs, supervises and authorises where appropriate.
- Prerequisites: competence, equipment condition, necessary resources and checks.
- Sequence: clear steps connecting each significant risk with its measure.
- Limits: conditions preventing work from starting or requiring it to stop.
- Response: reporting abnormalities and planned action for incidents or emergencies.
- Closure: restoration of safe conditions, equipment handover and necessary records.
Identify the version and who validates its content. Photographs or diagrams help only when they match the equipment and situation described.
Write it with those who perform the work
Writing begins by observing the task and checking the assessment, manufacturer instructions and workforce experience. Distinguish the usual sequence from cleaning, adjustment, clearing jams and maintenance: a description of normal production may not cover those interventions.
The draft is reviewed with personnel familiar with the process and prevention specialists. Check that tools, time and access allow compliance. If it requires a manoeuvre nobody can perform safely, the solution is to change conditions or the method, rather than request another signature.
Training, availability and versions
Articles 15 and 19 of the Occupational Risk Prevention Act connect instructions with adequate training. For tasks requiring skill, practical execution and understanding must be checked, not only receipt of the document.
The current version must be accessible where needed. Document control prevents outdated instructions from remaining an operational reference. A change in equipment, product or exposed personnel, or an incident, may require review and renewed communication. The record should show what changed and who was informed.
Check effectiveness without adding bureaucracy
A planned observation checks whether the sequence is followed, safeguards work and unforeseen deviations arise. Articles 8 and 9 of Royal Decree 39/1997 require planning measures and their follow-up; the document supports that work rather than being its final outcome.
Review should remove unnecessary steps and clarify those causing uncertainty. Expressions such as “take extra care” are insufficient unless they explain the expected action or condition requiring a stop.
Hypothetical example: a packaging-line changeover
A factory prepares an instruction for changing the format of a packaging line. It defines who intervenes, when the line must be taken out of service, which checks are performed and who authorises return to production under the equipment-specific procedure.
Testing reveals that access forces an awkward posture. The tool is adapted before the version is approved. The final document incorporates that solution and the changeover is practised with personnel; it is not intended to serve every machine.
