Pennsylvania SOPs, Process Control & Non-Certified Operators

Pennsylvania operator-certification rules allow water and wastewater systems to use Standard Operating Procedures, or SOPs, as one method for implementing process-control decisions. This can help a facility operate consistently when employees work different shifts or when the appropriately certified operator is not physically beside every treatment unit.

However, SOPs do not replace certified operators. They operate within a regulatory structure in which an available operator remains responsible for process-control decisions and an operator in responsible charge approves and oversees SOP use.

Process-Control Decisions Belong to the Available Operator

Under 25 Pa. Code Chapter 302, an available operator must make all process-control decisions.

Those decisions may be made:

• onsite;
• from a remote location;
• through approved Standard Operating Procedures;
• through qualifying PLC or SCADA arrangements under the applicable regulations.

The method can vary, but the requirement for appropriately certified operator authority remains.

What Is a Process-Control Decision?

A process-control decision is an operational decision that maintains or changes the quantity or quality of water being treated in a way that can affect public health or the environment.

Examples may include decisions involving:

• chemical feed rates;
• filter operation;
• disinfection settings;
• aeration adjustments;
• sludge wasting;
• flow distribution;
• pump operation that changes treatment conditions;
• responses to process alarms;
• other treatment adjustments affecting system performance.

Not every physical task performed at a plant is a process-control decision. The key question is whether the action involves operational judgment that maintains or changes treatment quantity or quality.

What Is a Standard Operating Procedure?

Chapter 302 defines Standard Operating Procedures as written documents describing the actions necessary to make process-control decisions when established quantitative or qualitative operating parameters occur.

An SOP therefore connects a defined condition with a predetermined operational response.

For example, an SOP might state what action should occur when:

• a tank level reaches a specified value;
• a chlorine residual moves outside a defined range;
• a dissolved oxygen reading reaches a trigger point;
• a filter reaches a specified head loss;
• a pump station reaches a defined operating condition;
• a treatment alarm occurs.

The procedure should not simply say, "adjust treatment as necessary." It should identify the condition and the action clearly enough for the authorized operator to implement the approved process-control response.

Required SOP Content

Pennsylvania regulations identify specific information that must be included in SOPs used for process-control decisions.

The SOP must:

• include the name of the operator in responsible charge;
• identify the operators who may use the SOP to make process-control decisions;
• identify the treatment processes covered by the SOP;
• identify the trigger parameters for those treatment processes;
• identify the appropriate action for each trigger condition.

If a treatment process is not covered by the SOP, the operator must be instructed to contact the operator in responsible charge for the necessary process-control decision.

Trigger Parameters

A useful SOP is built around defined trigger parameters.

A trigger parameter is an operating condition that tells the operator when the predetermined response applies.

Examples could include:

• water level;
• flow rate;
• pressure;
• chlorine residual;
• turbidity;
• pH;
• dissolved oxygen;
• sludge blanket depth;
• pump status;
• another measurable or clearly defined process condition.

The trigger must be specific enough that the employee can determine whether the procedure applies without inventing a new process-control decision.

Actions Must Also Be Defined

The SOP must identify the appropriate actions associated with the trigger conditions.

For example, a procedure could identify:

• which pump to start or stop;
• which preset chemical-feed adjustment to make;
• which valve position to use;
• when to place equipment in or out of service;
• when the operator in responsible charge must be contacted.

The SOP should define the permitted response rather than requiring an employee without appropriate authority to develop a new treatment strategy.

The Operator in Responsible Charge

The operator in responsible charge, or ORC, has a specific role when SOPs are used.

The ORC is an appropriately certified operator designated by the owner and is responsible for approving the SOPs used for process-control implementation.

The ORC must approve the SOPs:

• in writing;
• with a date.

The approved procedures must remain available at the system for review.

ORC Is Not Just a Job Title

The term operator in responsible charge has a regulatory meaning.

A plant supervisor, superintendent, senior employee, or shift leader does not automatically become the ORC simply because of a management title.

The person must be properly designated and appropriately certified for the responsibilities involved.

Use of SOPs Is Optional

Pennsylvania does not require every water or wastewater system to operate through process-control SOPs.

Chapter 302 describes SOP use as an optional method available to the operator in responsible charge.

Whether SOPs are useful depends on factors such as:

• system complexity;
• staffing;
• shift coverage;
• degree of automation;
• frequency of routine process adjustments.

A system can instead rely on direct process-control decisions made onsite or remotely by an available operator.

Who May Use the SOP?

The SOP itself must identify the operators authorized to use it.

An employee should not assume that because an SOP exists, every worker at the facility may use it to make treatment adjustments.

The approved procedure defines who may implement the specified actions.

Non-Certified Operators

Pennsylvania allows non-certified operators to work at water and wastewater systems and to gain experience toward future certification.

They may perform many operational duties, including tasks involving:

• equipment operation;
• inspection;
• sampling;
• laboratory work;
• maintenance;
• recordkeeping;
• implementation of appropriately approved SOP actions.

However, a non-certified employee cannot independently make a process-control decision outside the authority provided through the certified-operator framework.

Implementing a Decision Is Different from Creating One

This distinction is central to understanding SOP use.

An appropriately certified operator may decide in advance that when a specific measurable condition occurs, a particular action should be taken. That decision is documented in the approved SOP.

A properly authorized employee can then implement the prescribed action when the stated trigger occurs.

The employee is not independently developing a new treatment decision. The employee is implementing the process-control decision already established through the approved SOP.

When the Employee Must Call the ORC

The employee must contact the operator in responsible charge when the operating condition falls outside the scope of the approved SOP.

Examples include:

• a parameter exceeds the ranges covered by the procedure;
• two conflicting alarms occur;
• equipment required by the SOP is unavailable;
• the prescribed action fails to correct the condition;
• an unexpected treatment condition develops;
• the process involved is not covered by the SOP;
• a new process-control judgment is necessary.

At that point, the employee should not improvise a new treatment decision unless appropriately certified and authorized to do so.

Example: Chlorine Feed Adjustment

Suppose an approved SOP states that when a specified residual reaches a defined lower trigger, the operator may increase a chemical-feed setting by a predetermined amount and then perform specified follow-up monitoring.

An operator identified in the SOP can carry out that action when the exact trigger condition occurs.

If the residual continues falling after the approved adjustment or another abnormal condition develops, the employee must follow the SOP escalation requirements and contact the ORC for a new decision.

Example: Pump Operation

An SOP might state that when a wet-well level reaches a defined elevation, a particular standby pump is placed in service.

If the level trigger occurs and the pump is available, the authorized employee can implement the procedure.

If the standby pump fails, the employee should not create a different pumping strategy unless that response is also covered by the SOP or the employee is appropriately certified to make that decision.

Direct Supervision

Chapter 302 describes SOP use as a method allowing operators under the ORC's direct supervision to implement process-control decisions.

Direct supervision does not necessarily mean that the ORC must stand beside the employee during every SOP action.

It means the SOP system must remain under the responsible certified operator's oversight, with clear authority, communication, procedures, and escalation paths.

The ORC Must Notify the Owner

When the ORC uses SOPs for process-control implementation, the ORC must notify the system owner that the SOPs are being used.

This ensures that the owner understands how process-control authority is being implemented at the facility.

SOPs Must Remain Available for Review

The signed and dated SOPs must be available at the system for review.

DEP may request copies to evaluate:

• how operators use the SOPs;
• whether the procedures are effective;
• whether they support compliance with applicable laws, regulations, and permit requirements.

Electronic SOPs

Pennsylvania permits SOPs to be maintained electronically to make information easier to search and retrieve.

When electronic SOPs are used, the electronic version must be protected so changes cannot be made without evidence of tampering.

The electronic SOP must also indicate where the original signed paper copy is maintained and identify the ORC who approved it.

The electronic content must be identical to the current signed paper version.

If the two versions differ, the original signed paper SOP is considered the official version.

Update SOPs When Conditions Change

An SOP should reflect the actual treatment system and current operating strategy.

Review may be necessary when:

• treatment equipment changes;
• chemical feed systems are modified;
• alarm setpoints change;
• permit requirements change;
• new treatment technology is installed;
• operating experience shows the existing procedure is ineffective;
• staffing or operator responsibilities change.

An outdated SOP can direct operators to take actions that are no longer appropriate.

SOPs Do Not Override Permits or Regulations

An approved SOP cannot authorize an action that violates Federal or Pennsylvania law, DEP regulations, or permit requirements.

The ORC must develop and approve procedures that support compliant operation.

If a conflict exists between an internal SOP and a legal or permit requirement, the regulatory requirement controls.

Responsibility for SOP Decisions

The operator in responsible charge has accountability for SOPs that the ORC approves.

Chapter 302 provides that the ORC can be accountable for violations resulting directly from a provision of an approved SOP.

This is one reason SOP approval should not be treated as a routine signature exercise.

The ORC should understand the procedure, operating limits, trigger conditions, and consequences before approving it.

Available Operator Responsibility

Available operators making process-control decisions are responsible for those decisions and their consequences, subject to the specific exceptions described in Chapter 302.

Certified-operator authority therefore carries professional responsibility in addition to operational authority.

Training Employees on SOPs

An SOP is useful only if the operators expected to use it understand it.

Employees should know:

• which SOPs they are authorized to use;
• what each trigger means;
• what action is permitted;
• what action is prohibited;
• when to stop and call the ORC;
• how to document the action taken.

Operators should not be expected to interpret complex procedures for the first time during an emergency.

Document Process Actions

When an SOP directs a process adjustment, appropriate operational records should document the action.

Useful records may include:

• date and time;
• trigger condition;
• action taken;
• operator performing the action;
• follow-up readings;
• ORC contact when required.

Good documentation helps demonstrate what occurred and allows operators to evaluate whether the SOP produced the intended result.

SOPs and Automation

SOPs and automation are separate methods recognized under Chapter 302.

A PLC or SCADA system may automatically implement certain process actions when the regulatory requirements for those systems are met.

A written SOP may instead guide an operator to implement a predetermined response.

Neither arrangement removes the need for appropriate certified-operator oversight.

Common SOP and Process-Control Mistakes

• Allowing a non-certified employee to invent a new treatment adjustment.
• Using an SOP that does not identify the ORC.
• Failing to identify which operators may use the SOP.
• Writing vague procedures without measurable trigger parameters.
• Failing to specify the action associated with each trigger.
• Using an SOP for a treatment process not covered by the document.
• Failing to instruct operators to contact the ORC when the procedure does not apply.
• Using unsigned or undated SOPs.
• Assuming SOP use is mandatory at every facility.
• Assuming an SOP eliminates the need for an available certified operator.
• Allowing an outdated electronic version to differ from the signed official procedure.
• Failing to revise SOPs after major process or equipment changes.

A Practical SOP Structure

1. Identify the operator in responsible charge.
2. Identify the operators authorized to use the procedure.
3. Identify the treatment process covered.
4. Define measurable qualitative or quantitative trigger conditions.
5. Define the exact action authorized for each trigger.
6. Define limits beyond which the SOP no longer applies.
7. State when the ORC must be contacted.
8. Include appropriate follow-up monitoring or verification.
9. Approve the procedure in writing and date it.
10. Keep the current approved procedure available at the system.
11. Train the operators who will use it.
12. Review and revise the SOP when treatment conditions change.

What to Remember for the Exam

• An available operator must make all process-control decisions.
• Process-control decisions may be made onsite, remotely, through approved SOPs, or through qualifying PLC systems.
• An SOP is a written procedure connecting established operating parameters with predetermined process-control actions.
• SOPs must identify the operator in responsible charge.
• SOPs must identify which operators may use them.
• SOPs must identify the treatment processes they cover.
• SOPs must identify trigger parameters and the actions associated with those triggers.
• If the SOP does not cover a process or condition, the operator must contact the ORC for the necessary decision.
• The ORC must approve SOPs in writing and date them.
• SOP use is optional, not mandatory for every system.
• SOPs allow operators under the ORC's supervision to implement approved process-control decisions.
• Non-certified operators may perform many plant duties but cannot independently create process-control decisions requiring certified-operator authority.
• Implementing a predetermined SOP action is different from independently developing a new process-control decision.
• The ORC must notify the owner when SOPs are being used.
• SOPs must remain available at the system for review.
• Electronic SOPs are permitted but must match the signed official paper version and be protected from undetectable alteration.
• SOPs do not override permits, regulations, or certified-operator responsibilities.