What Makes a Good Commissioning Procedure (and What Makes a Dangerous One)

Commissioning procedures occupy an awkward space in the capital project lifecycle. They're needed before the facility operates, but they can only be written once the design is substantially complete. The result is that they're almost always written under schedule pressure, often by engineers who haven't written procedures before, for operations that have never happened.

The stakes are high. Commissioning is when most first-time operation incidents occur. The equipment is new, the personnel are unfamiliar with it, and every step is being performed for the first time. A procedure that assumes knowledge the operator doesn't have, or that leaves out a critical verification step, creates conditions for error at exactly the moment when error is most consequential.

The Warning Signs of a Dangerous Procedure

The deficiencies in poor commissioning procedures are consistent enough to predict. If you're reviewing a procedure and see these, the procedure isn't ready:

Passive voice for safety-critical steps. "Valve should be open" is not an instruction. It's a description of a desired state with no clear actor, no clear sequence, and no verification. "Operator opens XV-101" is an instruction. The distinction matters when something goes wrong and someone is trying to reconstruct what happened.

Missing acceptance criteria. "Verify pump is running normally" tells the operator nothing. Running at what flow? What discharge pressure? What amperage draw? What constitutes "not normal" and what is the operator supposed to do about it? Acceptance criteria make the difference between a procedure that can be followed and a procedure that requires the operator to already know the answer.

Steps that skip prerequisites. Step 7 says "open isolation valve to heat exchanger." Does the heat exchanger have cooling water established? Is the instrument air connected and at pressure? Are the drain valves closed? Implied prerequisites are the single most common cause of commissioning procedure-related incidents — the operator follows the procedure exactly as written and something goes wrong because the procedure assumed a condition that didn't exist.

No concurrent operation coordination. Commissioning a new unit adjacent to an operating unit — or commissioning multiple systems within the same facility simultaneously — creates interference between procedures. If procedure A and procedure C both require the same utility header, and that header can't support both simultaneously, that conflict needs to be explicit in both procedures, not discovered during execution.

Action and verification steps not separated. "Open valve and confirm flow" buries verification inside an action. If the operator opens the valve and there's no flow, what happens next? Separation of action steps and verification steps makes the decision tree explicit.

The Structure of a Procedure That Works

Header and Purpose

Every commissioning procedure needs: the procedure number and revision, the system it covers, what state the system should be in before the procedure starts, what state it will be in when complete, the estimated duration, and the personnel required. Not some of these — all of them.

Prerequisites Section

Before Step 1, a standalone section confirms: related systems are in the required state, required utilities are available and at specification, required test equipment is on hand and calibrated, all hold points from earlier phases are cleared, and personnel have been briefed. This section is signed, not just acknowledged.

Step Structure

Each action step follows a consistent format:

• Actor: who performs this step (Operator, Lead Operator, Instrument Technician)
• Action: what they do, with equipment identified by tag number
• Expected result: what should happen (with quantified acceptance criteria where applicable)
• Deviation response: what to do if the expected result isn't observed — stop, notify supervision, go to step X
• Initials box: confirmation that the step was completed

Hold Points

Hold points are mandatory stops where a designated authority — typically the PSM lead or facility manager — must verify and authorize continuation. They should appear at: introduction of energy or fluid to a system for the first time, transition from cold commissioning to hot commissioning, achievement of operating temperature or pressure for the first time, and before chemical introduction.

The Emergency Response Gap

Most commissioning procedures have excellent coverage of normal operations and expected deviations. They rarely have adequate coverage of emergency response during commissioning.

Emergency response during commissioning is different from normal operations emergency response. The systems that are commissioned are at various stages of readiness. Emergency isolation may not be fully functional. The operating crew is small — often insufficient for a full emergency response. Contractors are on-site with different safety protocols and communication channels.

Each commissioning procedure should include, or reference, specific emergency actions for the credible emergencies during that system's commissioning: loss of containment, fire, loss of utilities, or equipment failure. These should be specific to the stage of commissioning — not a reference to the general site emergency response plan.