Introduction
Charity and voluntary workers make significant contributions to the quality of life of many people both at the local communities level and also more broadly at the national and even the international levels. The effective management of Health and Safety can be a challenging area in any organisation, but the problems can be greater in the charity and voluntary sector as many of the workers are not paid employees working regularly for the organisation, but are often unpaid workers making small, but valuable, time contributions. The charity and voluntary sector also uses workers from a very wide age range and probably has a greater proportion of very elderly workers than any other sector, as many people find more time for voluntary work when they have retired from other work. All workers, including paid employees and voluntary (unpaid) workers, have a right to work in a safe workplace where appropriate actions have been taken to prevent accidents and ill health. Both paid and unpaid workers also have a duty to contribute to the general health and safety of their workplace, in the same way that employees do in other work areas.
Charity and voluntary work can cover a wide range of activities, almost as broad as other working areas, but generally without the industrial aspects. Such work can include: office work; handling patients; retail work; driving (either alone, with others or transporting people); visiting people in their homes; etc. Typical hazardous are similar to other workplaces (such as fire; electrical; slips, trips and falls; etc.) as well as lone working and the manual handling difficulties associated with lifting and moving people. There may also be issues associated with fund raising activities, such as money handling, and with lone working.
Charity and voluntary organisations and Health & Safety law
It should come as no surprise that charity and voluntary organisations are subject to the same health and safety laws as comparable non-charity and non-voluntary organisations. They have a duty to ensure the health and safety of their employees and also any non-employees who may be affected by the undertakings of the organisation. These duties arise from Sections 2(1) and 3(1) of the Health and Safety at Work Etc Act 1974. Also, they are subject to a requirement to undertake assessments of the risks to employees (and non-employees) arising from their undertakings under Regulations 3 of the Management of Health and Safety at Work Regulations 1999. The application of other health and safety legislation depends on the exact nature and undertakings of the organisation, just as it would in all other sectors.
In order to determine what health and safety legislation applies and how to comply with its variation provisions, charity and voluntary organisations must have access to competent health and safety advice. This may be provided from within the organisation or can be brought in from external sources, such as consultants.
As it is not uncommon to have elderly workers engaged in charity and voluntary work, the potential extra vulnerability of these people to injury needs to be accounted for in the risk assessments and in the control measures.
Training
Voluntary workers are not exempted from training and should be included in your training health and safety programmes. Due to the nature of voluntary work, consideration needs to be given to the most suitable way of doing this and the organisation will need to be flexible with the training times and the venues. Voluntary workers should be given suitable induction training, just like all other workers and this should include: Fire arrangements for the workplace; First aid arrangements for the workplace; Awareness of higher risk areas and operations; etc.
On the job (or tool box style) training may be provided to ensure that workers are aware of the risks to which they may be exposed and to ensure that they are aware of (and use) the appropriate control measures (such as those arising from the risk assessments) to avoid and control these risks.
In line with other work areas, records should be maintained of all of the training provided to workers.
Two examples of issues facing charity and voluntary workers
Dealing with donated goods
Charities often receive donations of goods for use or to be sold (such as in charity shops). Often, these goods are delivered in boxes or bags and are not sorted and are not packaged with the safety of the sorter in mind. The bags and boxes may be heavy and not substantial enough for the loads contained. After sorting, the goods may need to be cleaned before being displayed for sale.
Typical hazards and harm from sorting donated goods
• Manual handling of boxes and bags (often many of each and of variable, unknown and often heavy weights), leading to:
o Back injuries
o Slips, trips and falls while handling the bags and boxes
• Poor housekeeping arising from the number of boxes and bags donated and the unpacking and sorting of the materials, leading to:
o Slips, trips and falls
o Manual handling injuries due to over reaching
• Sharp objects (such as knives, broken glass and china, etc)
o Cuts and puncture wounds
• Contamination (materials that have leaked or clothing that is soiled or has become mouldy, etc)
o Exposure to substances hazardous to health
o Infections
• Ergonomic issue ( from working on tables of poor height and working from boxes and bags of variable size and shape)
o Back injuries
• Work Equipment issues (such as washing machines, steaming equipment, ironing equipment, etc)
o Electrical
o Burns and scolds
Typical measures to control the risks associated with sorting donated goods
• Ensure that there are sufficient people to handle the number (and weight) of the bags and boxes that need to be sorted
• Where appropriate, provide trolleys, sack trucks or other manual handling aids
• Provide suitable instruction to workers on how to lift and carry boxes and bags
• Ensure that workers take breaks from the physical exertion of lifting carrying
• Ensure that the work areas (including the means of access to and egress from them) are kept clean and clear of obstructions
• Ensure that the lighting in the sorting area is satisfactory
• Provide an sufficient number of suitable bins for the safe disposal and, where appropriate, segregation of waste from the sorting operation
• Provide a clear, flat surface of sufficient size for bags and boxes to the emptied out onto before sorting the contents
• Ensure that the work surface is at a suitable height for the workers involved in the sorting operation
• Provide appropriate personal protective equipment, such as protective gloves for handling sharp objects and appropriate gloves for handling contaminated items
• Establish a policy for dealing with broken glass (hoe to deal with it and how and where to dispose of it)
• Provide suitable bag openers or bag holders for holding “rag bags” open when they are being filled with fabrics
• Restrict the use of work equipment (such as steaming equipment) to those who have been trained in the use of the equipment.
• Provide a suitable ironing board that adjusts to a suitable height for the working using it
• Arrange for all work equipment to be maintained in good condition and for electrical equipment to be tested and inspected by a competent person regularly
Working in a drug “drop in” centre
Voluntary workers often help to man the various drug “drop in” centres around the country, either providing administrative support or providing counselling skills. Such centres provide help and advice as well as counselling services to their clients, which include: drug users and to their friends and families. In these settings, the potential for unpredictable behaviour from drug users visiting the centre means that aggressive and even violent situations are not uncommon.
Typical hazards and harm from working in a drug “drop in” centre
• The unpredictable nature of some drug users and other clients, leading to aggressive and violent behaviour, resulting in:
o Verbal abuse from clients
o Property damage caused by clients
o Personal injury caused by assault by clients
Typical measures to control the risks associated with working in a drug “drop in” centre
• Ensure that all workers are aware of what might happen in the centre and are aware of the procedures to be followed
• Establish and practice effective emergency procedures, including the use of panic alarms (that summon aid from other areas of the premises and (maybe) also from the local police service)
• Establish, and publish details of, a “zero tolerance” approach to violence and aggression – display suitable posters and bring this policy to the attention of all users of the centre
• Provide workers with suitable and sufficient training and information. In particular this should address:
o the adoption of a non-confrontational and non-judgemental approach to clients and the avoidance of patronising behaviour
o workers should be trained to help to create an equal balance of power between workers and clients
o the various control measures that are in place throughout the centre to safeguard workers
o identifying challenging behaviour in clients and strategies for diffusing the situation
o instructing workers not to compromise their own safety
• Consideration to the layout and design of the premises, with consideration to the safety of workers and also to the privacy needs of the clients. This would include:
o Suitable access control to the premises
o Provision of light, spacious, airy and well-decorated public and working areas, designed to give a calming and welcoming effect
o Provision of a Reception desk designed to provide a central control point from which all client accessible areas can be supervised
o Ensuring that the counselling rooms provide privacy, but are also within hearing distance of the reception and that they have suitable panic alarms fitted
o Design of the workers’ office areas such that they are located out of client sight, but are open plan to allow workers to see each other
• Establish suitable work procedures to help to minimise the risks of conflict, including:
o a good, accurate appointment system
o avoiding keeping clients waiting (which may result in them becoming annoyed or frustrated)
o continuous staff of reception by trained workers
o procedures to respond to panic alarms in a prompt and appropriate manner
Summary
The challenges associated with the management of health and safety charity and voluntary workers are not that different from those facing other businesses. Many of them can be dealt with by the application of thought and common sense. In line with all other businesses, there is a requirement to consider the risks that workers may be exposed to and to establish controls to avoid and control these risks. The examples above demonstrate that the processes to control the risks are not difficult to identify or to implement. There are two particular problems that need to be considered carefully for the charity and voluntary sector: training of workers and the potential for elderly workers.
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Thursday 18 March 2010
Safe isolation of plant and equipment – Part 2: Key Stages
Introduction
In order to allow various processes such as: cleaning, maintenance, plant repair and modification to take place, safe isolation of plant and equipment is essential. This is not specifically covered by any health and safety legislation, although there are the usual, general legal drivers, such as: the Health and Safety at Work Etc Act 1974 (Section 2: duty to ensure the health, safety and welfare of employees, Section 3: duty to ensure the health and safety of non-employees), the Management of Health and Safety at Work Regulations 1999 (Regulation 3: duty to carry out risk assessments) as well as the Control of Substances Hazardous to Health Regulations 2002 (COSHH) and the Dangerous Substances and Explosive Atmospheres Regulations 2005 (DSEAR), etc.
Failures during the isolation and re-instatement of plant and equipment are a significant cause of loss of containment incidents and can lead to major accidents. There are eight key stages that should be considered in the isolation, and subsequent return to service, of plant and equipment:
• Hazard identification
• Risk assessment and selection of isolation scheme
• Planning and preparation of equipment
• Installation of isolation
• Draining, venting, purging and flushing
• Testing and monitoring effectiveness of the isolation
• Carrying out the intrusive activity
• Reinstatement of plant
Hazard Identification
Hazards may exist from either substances within the plant and equipment or from the nature of the work to be carried out. All (potential) hazards must be identified so that appropriate control measures can be introduced for the isolation of the plant and equipment. Particular hazards will exist if the substance is:
• toxic
• flammable
• pyrophoric
• under (high) pressure
• at high or low temperature
• reactive
• an asphyxiant (such as nitrogen)
• capable of forming an explosive atmosphere (including dusts)
• remaining in equipment as a sludge or hard deposit
In the event of a loss of containment leading to a release, the potential for a major accident will depend on a range of factors including
• the nature and properties of the substance
• the amount of the substance released
• the potential for escalation (such as: the presence of other plant, including confining structures, and other hazardous substances)
• the people at risk, their proximity to the plant and the speed with which they may be affected
Hazards associated with the task to be undertaken include:
• Entry into confined spaces
• Issues associated with access (such as working at height, etc.)
• Hot work (such as welding, cutting, grinding, drilling, electrical work, etc.)
Risk Assessment and the selection of isolation scheme for the plant and equipment
It should form a part of the company’s policies and procedures that intrusive work is not carried out on live plant and equipment unless there is no reasonably practicable alternative. A risk assessment should be carried out for the isolation process to identify the safest isolation scheme and should consider:
• all preparatory work for the isolation (such as depressurisation and release of stored energy, draining and venting, purging and washing out)
• installation/removal and proving of the isolation the integrity of the isolation during intrusive work, and the compatibility of any nearby work or operations on shared systems
• the requirements for testing and reinstatement of plant (such as: pressure leak testing, purging, controlled repressurisation and refilling
The risk assessment should also consider the potential for loss of containment and the potential harm (to people and to the environment) that may result from this.
Planning and preparation of equipment
As with many areas, planning is an essential stage in the isolation of plant and equipment. Appropriate preparation and planning:
• helps to identify any task-specific risk assessments that may be required
• identifies whether larger sections of the plant need to be shut down
• identifies interaction with other sections of plant subject to temporary isolation
• involves sequencing and co-ordination of any intrusive work with other plant operations
• includes a 'walk-the-plant' step, to check that the installation matches the piping and instrumentation diagrams (P&ID) and
• allows a check that all isolation points have been identified and are accessible and can be operated
• ensures preparation and co-ordination of job documentation, including:
o risk assessments
o method statements
o permit to work certificates
o isolation certificates
o etc
• ensures cross-referencing of relevant permits; and
• enables that all necessary and appropriate tools, equipment, PPE, materials, etc., are available
Installation of isolation
The process of installation of the necessary isolations can be considered in two parts: the initial isolation and the final (or full) isolation. The initial isolation (which is usually valved) is generally of a short duration. It allows the insertion of a positive isolation after the plant that is downstream of the initial isolation has been depressurised and purged. The final isolation protects the workers that are carrying out the intrusive work, and others who might be affected, such as from a release of substance from the plant during the intrusive activity.
Suitable blank flanges, plugs, etc (appropriately rated and installed properly, with the correct gaskets and securing bolts) should be used to close off any open pipe work. Appropriate engineering practices should be adhered when securing flanges, etc. Isolations must remain secure throughout the duration of work: locking arrangements or barriers, to prevent accidental or unauthorised removal of the isolation, should be used where practicable.
Draining, venting, purging and flushing
Draining, venting, purging and flushing may be required in situation where the plant or equipment contains hazardous substances, etc.
Testing and monitoring effectiveness of the isolation
In most cases, it is necessary to prove the integrity of all of the isolation points of an isolation scheme before proceeding with intrusive work, unless the risk assessment indicates otherwise.
• each part of the isolation should be proved separately
• each part should be proved to the highest pressure which can be expected within the system during the work activity
• where possible, each part of the isolation should be proved in the direction of the expected pressure differential
Carrying out the intrusive activity
It is important to ensure that the integrity of all isolations is maintained while the intrusive work is carried out.
Reinstatement of plant
Reinstatement or recommissioning of the plant requires equivalent controls to those used during installation of isolation. Where work has been controlled under multiple permits and dependent on common isolation points, it is important to define and control the sequence of plant reinstatement. This should include a review of all (cross-referenced) permits in force and their related isolations and checking that any plant control and protection systems functions that were overridden for the purposes of the isolations are restored to their normal condition. Care must be taken when removing positive isolations as, for example, hazardous substances may have built up behind the blank or spade if a valve leaks. Use appropriate documentation, such as isolation certificates, to log all disturbed items on a plant and to control their reinstatement.
Summary
Safe isolation of plant and equipment is an important part of the management of health and safety at work and, as such, should form part of the documented policies and procedures of the company (including the Health and Safety Policy). The key stages in the process of plant isolation (and re-instatement) must be planned and controlled. Risk assessments must be carried out to determine the range of control measures required and the order of work and the need for administrative controls, such as permit to work systems, etc. Plant and equipment should be isolated in accordance with a planned system, devised and controlled by a competent person (or persons). Isolations should be made and checked and should remain in place until removed in accordance with a planned schedule for the reinstatement or recommissioning of the plant.
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In order to allow various processes such as: cleaning, maintenance, plant repair and modification to take place, safe isolation of plant and equipment is essential. This is not specifically covered by any health and safety legislation, although there are the usual, general legal drivers, such as: the Health and Safety at Work Etc Act 1974 (Section 2: duty to ensure the health, safety and welfare of employees, Section 3: duty to ensure the health and safety of non-employees), the Management of Health and Safety at Work Regulations 1999 (Regulation 3: duty to carry out risk assessments) as well as the Control of Substances Hazardous to Health Regulations 2002 (COSHH) and the Dangerous Substances and Explosive Atmospheres Regulations 2005 (DSEAR), etc.
Failures during the isolation and re-instatement of plant and equipment are a significant cause of loss of containment incidents and can lead to major accidents. There are eight key stages that should be considered in the isolation, and subsequent return to service, of plant and equipment:
• Hazard identification
• Risk assessment and selection of isolation scheme
• Planning and preparation of equipment
• Installation of isolation
• Draining, venting, purging and flushing
• Testing and monitoring effectiveness of the isolation
• Carrying out the intrusive activity
• Reinstatement of plant
Hazard Identification
Hazards may exist from either substances within the plant and equipment or from the nature of the work to be carried out. All (potential) hazards must be identified so that appropriate control measures can be introduced for the isolation of the plant and equipment. Particular hazards will exist if the substance is:
• toxic
• flammable
• pyrophoric
• under (high) pressure
• at high or low temperature
• reactive
• an asphyxiant (such as nitrogen)
• capable of forming an explosive atmosphere (including dusts)
• remaining in equipment as a sludge or hard deposit
In the event of a loss of containment leading to a release, the potential for a major accident will depend on a range of factors including
• the nature and properties of the substance
• the amount of the substance released
• the potential for escalation (such as: the presence of other plant, including confining structures, and other hazardous substances)
• the people at risk, their proximity to the plant and the speed with which they may be affected
Hazards associated with the task to be undertaken include:
• Entry into confined spaces
• Issues associated with access (such as working at height, etc.)
• Hot work (such as welding, cutting, grinding, drilling, electrical work, etc.)
Risk Assessment and the selection of isolation scheme for the plant and equipment
It should form a part of the company’s policies and procedures that intrusive work is not carried out on live plant and equipment unless there is no reasonably practicable alternative. A risk assessment should be carried out for the isolation process to identify the safest isolation scheme and should consider:
• all preparatory work for the isolation (such as depressurisation and release of stored energy, draining and venting, purging and washing out)
• installation/removal and proving of the isolation the integrity of the isolation during intrusive work, and the compatibility of any nearby work or operations on shared systems
• the requirements for testing and reinstatement of plant (such as: pressure leak testing, purging, controlled repressurisation and refilling
The risk assessment should also consider the potential for loss of containment and the potential harm (to people and to the environment) that may result from this.
Planning and preparation of equipment
As with many areas, planning is an essential stage in the isolation of plant and equipment. Appropriate preparation and planning:
• helps to identify any task-specific risk assessments that may be required
• identifies whether larger sections of the plant need to be shut down
• identifies interaction with other sections of plant subject to temporary isolation
• involves sequencing and co-ordination of any intrusive work with other plant operations
• includes a 'walk-the-plant' step, to check that the installation matches the piping and instrumentation diagrams (P&ID) and
• allows a check that all isolation points have been identified and are accessible and can be operated
• ensures preparation and co-ordination of job documentation, including:
o risk assessments
o method statements
o permit to work certificates
o isolation certificates
o etc
• ensures cross-referencing of relevant permits; and
• enables that all necessary and appropriate tools, equipment, PPE, materials, etc., are available
Installation of isolation
The process of installation of the necessary isolations can be considered in two parts: the initial isolation and the final (or full) isolation. The initial isolation (which is usually valved) is generally of a short duration. It allows the insertion of a positive isolation after the plant that is downstream of the initial isolation has been depressurised and purged. The final isolation protects the workers that are carrying out the intrusive work, and others who might be affected, such as from a release of substance from the plant during the intrusive activity.
Suitable blank flanges, plugs, etc (appropriately rated and installed properly, with the correct gaskets and securing bolts) should be used to close off any open pipe work. Appropriate engineering practices should be adhered when securing flanges, etc. Isolations must remain secure throughout the duration of work: locking arrangements or barriers, to prevent accidental or unauthorised removal of the isolation, should be used where practicable.
Draining, venting, purging and flushing
Draining, venting, purging and flushing may be required in situation where the plant or equipment contains hazardous substances, etc.
Testing and monitoring effectiveness of the isolation
In most cases, it is necessary to prove the integrity of all of the isolation points of an isolation scheme before proceeding with intrusive work, unless the risk assessment indicates otherwise.
• each part of the isolation should be proved separately
• each part should be proved to the highest pressure which can be expected within the system during the work activity
• where possible, each part of the isolation should be proved in the direction of the expected pressure differential
Carrying out the intrusive activity
It is important to ensure that the integrity of all isolations is maintained while the intrusive work is carried out.
Reinstatement of plant
Reinstatement or recommissioning of the plant requires equivalent controls to those used during installation of isolation. Where work has been controlled under multiple permits and dependent on common isolation points, it is important to define and control the sequence of plant reinstatement. This should include a review of all (cross-referenced) permits in force and their related isolations and checking that any plant control and protection systems functions that were overridden for the purposes of the isolations are restored to their normal condition. Care must be taken when removing positive isolations as, for example, hazardous substances may have built up behind the blank or spade if a valve leaks. Use appropriate documentation, such as isolation certificates, to log all disturbed items on a plant and to control their reinstatement.
Summary
Safe isolation of plant and equipment is an important part of the management of health and safety at work and, as such, should form part of the documented policies and procedures of the company (including the Health and Safety Policy). The key stages in the process of plant isolation (and re-instatement) must be planned and controlled. Risk assessments must be carried out to determine the range of control measures required and the order of work and the need for administrative controls, such as permit to work systems, etc. Plant and equipment should be isolated in accordance with a planned system, devised and controlled by a competent person (or persons). Isolations should be made and checked and should remain in place until removed in accordance with a planned schedule for the reinstatement or recommissioning of the plant.
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Safe isolation of plant and equipment – Part 1
Introduction
The safe isolation of plant and equipment is essential to allow various processes to take place, such as: cleaning, maintenance, repair and modification. Although no health and safety legislation covers this area specifically, there are several general legal drivers, such as the Health and Safety at Work Etc Act 1974 (Section 2: duty to ensure the health, safety and welfare of employees, Section 3: duty to ensure the health and safety of non-employees), the Management of Health and Safety at Work Regulations 1999 (Regulation 3: duty to carry out risk assessments) as well as the Control of Substances Hazardous to Health Regulations 2002 (COSHH) and the Dangerous Substances and Explosive Atmospheres Regulations 2005 (DSEAR), etc. Failures during the isolation and re-instatement of plant and equipment are a significant cause of loss of containment incidents and can lead to major accidents. In some cases, the isolation may take place a long way from where the work is being carried out. Suitable procedures need to be implemented, managed, monitored, reviewed and revised. The effectiveness of an isolation system depends on the adequacy of other arrangements, including work control systems (especially permit-to-work), operating procedures, training and competence, management of change and contingency plans.
The safe isolation of plant and equipment can be considered in three sections:
• The management of isolation of plant and equipment
• The safe systems of work for the isolation of plant and equipment
• The key stages for the safe isolation of plant and equipment
The management of isolation of plant and equipment is considered in outline in this article, while the other items will be considered in a future article.
The management of isolation of plant and equipment
As with nearly all aspects of modern health and safety management, risk assessment is central to the safe isolation of plant and equipment. Although the actual mechanics of isolating plant and equipment may be carried out a range of people, it must be managed effectively, and several points should be considered:
• The safe isolation of plant and equipment should form part of the organisation’s Health and Safety Policy
• Suitable and sufficient assessments of the risks arising from (operations requiring) the isolation of plant and equipment must be carried out (by a competent person) and suitable measures implemented
• Suitable policies and procedures must be established and implemented to either avoid the risk entirely or, where this is not reasonably practicable, to reduce the risk to as low a level as is reasonably practicable
• Consideration must be given to the isolation procedures under both normal operating conditions and other foreseeable conditions
• A process for assessing and implementing any variations from existing procedures should be established
• Procedures to monitor and, where appropriate, improve the effectiveness of isolation procedures should be introduced
In order to manage the isolation of plant and equipment in a safe and effective manner, consideration should be given to:
• The design (of plant and equipment)
• Human factors
• Roles and responsibilities
• Training and competence
• Monitoring, auditing and reviewing
Design
Good initial design of plant and equipment is the most effective way to maximise the inherent safety and, as such, is fundamental to achieving safe and effective isolation of the plant and equipment without creating unnecessary constraints on plant operation. Intrusive repair and maintenance work or internal inspection tasks will require the plant or equipment to be shutdown (or at least certain sections of it). Where isolation is required to enable such tasks, suitable isolation arrangements on the plant should be identified and specified at the design stage. Similarly, consideration of plant isolations should be considered if the plant or equipment is to be modified. Design considerations should include:
• Positive isolation requirements (where vessel entry may be required, where isolation of toxic or dangerous substances is requires and to control segregation of parts of plant and equipment)
• Plant identification (A scheme to identify all process plant, piping, and valves should be drawn up. All items should be readily identifiable on the plant and referenced on the piping and instrumentation diagrams. Additionally, key items of equipment labelled permanently)
• Pipework
• Valves
• Pressure safety valves
• Spared equipment (Isolation arrangements should allow complete segregation from on-line plant and equipment for operational and/or maintenance reasons)
• Location of isolation and testing facilities (Unless contraindicated by risk assessment, isolation and bleed points should be as close as possible to the plant item. Concentration of maintenance work in one place aids control of the isolation arrangements and minimises the inventory of fluid to be depressurised and drained)
• Access and lighting (the design should allow safe access and adequate lighting to allow isolations to be made safely)
Human factors
A review and accidents and incidents involving failures to isolate plant and equipment show that human failure is an important consideration. The performance of isolations depends not only on the integrity of the isolation hardware, but also on the adequacy of the arrangements for identifying each isolation point, securing the isolation, proving/monitoring and maintaining overall control of work. Human failures can be divided into two groups:
• Errors, and
• Violations.
Roles and responsibilities
It is important to ensure that key staff are given (and understand) clearly defined roles and responsibilities for drawing up, maintaining, monitoring and improving the policies, procedures and systems for the safe isolation of plant and equipment.
Training and competence
All personnel involved in the isolation of plant and equipment must be competent to carry out their designated tasks and to discharge their responsibilities. They should:
• Understand the purpose, principles and practices of the organisation’s isolation procedures and safety rules
• Have an understanding of the consequences of any release of hazardous substances
Consideration should be given to the training and competence of staff who:
• Plan the isolations
• Authorise the isolations
• Authorise variations (or any other non-standard isolations)
• Install and remove isolations
• Check and test the isolations
• Work on the plant and equipment
Monitoring, auditing and Reviewing
The processes of monitoring, audit and review enable an organisation to confirm that it actually does what its policies and procedures say that it does, and helps to ensure that this is what it should do. Effective monitoring, audit and review systems:
• Help to identify any deficiencies in the policies and procedures for the isolation of plant and equipment
• Identify and implement any necessary corrective action before these lead to incidents
• Identify of how well the isolation of plant and equipment is are controlled within the organisation
Summary
Safe isolation of plant and equipment is an important part of the management of health and safety at work and, as such, should form part of the documented policies and procedures of the company (including the Health and Safety Policy). Risk assessments must be carried out to determine the range of control measures required. These control measures may include items such as Permit to Work Systems, etc. All policies, procedures and risk assessments must be kept up to date and should be monitored and reviewed regularly and should be revised as necessary.
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The safe isolation of plant and equipment is essential to allow various processes to take place, such as: cleaning, maintenance, repair and modification. Although no health and safety legislation covers this area specifically, there are several general legal drivers, such as the Health and Safety at Work Etc Act 1974 (Section 2: duty to ensure the health, safety and welfare of employees, Section 3: duty to ensure the health and safety of non-employees), the Management of Health and Safety at Work Regulations 1999 (Regulation 3: duty to carry out risk assessments) as well as the Control of Substances Hazardous to Health Regulations 2002 (COSHH) and the Dangerous Substances and Explosive Atmospheres Regulations 2005 (DSEAR), etc. Failures during the isolation and re-instatement of plant and equipment are a significant cause of loss of containment incidents and can lead to major accidents. In some cases, the isolation may take place a long way from where the work is being carried out. Suitable procedures need to be implemented, managed, monitored, reviewed and revised. The effectiveness of an isolation system depends on the adequacy of other arrangements, including work control systems (especially permit-to-work), operating procedures, training and competence, management of change and contingency plans.
The safe isolation of plant and equipment can be considered in three sections:
• The management of isolation of plant and equipment
• The safe systems of work for the isolation of plant and equipment
• The key stages for the safe isolation of plant and equipment
The management of isolation of plant and equipment is considered in outline in this article, while the other items will be considered in a future article.
The management of isolation of plant and equipment
As with nearly all aspects of modern health and safety management, risk assessment is central to the safe isolation of plant and equipment. Although the actual mechanics of isolating plant and equipment may be carried out a range of people, it must be managed effectively, and several points should be considered:
• The safe isolation of plant and equipment should form part of the organisation’s Health and Safety Policy
• Suitable and sufficient assessments of the risks arising from (operations requiring) the isolation of plant and equipment must be carried out (by a competent person) and suitable measures implemented
• Suitable policies and procedures must be established and implemented to either avoid the risk entirely or, where this is not reasonably practicable, to reduce the risk to as low a level as is reasonably practicable
• Consideration must be given to the isolation procedures under both normal operating conditions and other foreseeable conditions
• A process for assessing and implementing any variations from existing procedures should be established
• Procedures to monitor and, where appropriate, improve the effectiveness of isolation procedures should be introduced
In order to manage the isolation of plant and equipment in a safe and effective manner, consideration should be given to:
• The design (of plant and equipment)
• Human factors
• Roles and responsibilities
• Training and competence
• Monitoring, auditing and reviewing
Design
Good initial design of plant and equipment is the most effective way to maximise the inherent safety and, as such, is fundamental to achieving safe and effective isolation of the plant and equipment without creating unnecessary constraints on plant operation. Intrusive repair and maintenance work or internal inspection tasks will require the plant or equipment to be shutdown (or at least certain sections of it). Where isolation is required to enable such tasks, suitable isolation arrangements on the plant should be identified and specified at the design stage. Similarly, consideration of plant isolations should be considered if the plant or equipment is to be modified. Design considerations should include:
• Positive isolation requirements (where vessel entry may be required, where isolation of toxic or dangerous substances is requires and to control segregation of parts of plant and equipment)
• Plant identification (A scheme to identify all process plant, piping, and valves should be drawn up. All items should be readily identifiable on the plant and referenced on the piping and instrumentation diagrams. Additionally, key items of equipment labelled permanently)
• Pipework
• Valves
• Pressure safety valves
• Spared equipment (Isolation arrangements should allow complete segregation from on-line plant and equipment for operational and/or maintenance reasons)
• Location of isolation and testing facilities (Unless contraindicated by risk assessment, isolation and bleed points should be as close as possible to the plant item. Concentration of maintenance work in one place aids control of the isolation arrangements and minimises the inventory of fluid to be depressurised and drained)
• Access and lighting (the design should allow safe access and adequate lighting to allow isolations to be made safely)
Human factors
A review and accidents and incidents involving failures to isolate plant and equipment show that human failure is an important consideration. The performance of isolations depends not only on the integrity of the isolation hardware, but also on the adequacy of the arrangements for identifying each isolation point, securing the isolation, proving/monitoring and maintaining overall control of work. Human failures can be divided into two groups:
• Errors, and
• Violations.
Roles and responsibilities
It is important to ensure that key staff are given (and understand) clearly defined roles and responsibilities for drawing up, maintaining, monitoring and improving the policies, procedures and systems for the safe isolation of plant and equipment.
Training and competence
All personnel involved in the isolation of plant and equipment must be competent to carry out their designated tasks and to discharge their responsibilities. They should:
• Understand the purpose, principles and practices of the organisation’s isolation procedures and safety rules
• Have an understanding of the consequences of any release of hazardous substances
Consideration should be given to the training and competence of staff who:
• Plan the isolations
• Authorise the isolations
• Authorise variations (or any other non-standard isolations)
• Install and remove isolations
• Check and test the isolations
• Work on the plant and equipment
Monitoring, auditing and Reviewing
The processes of monitoring, audit and review enable an organisation to confirm that it actually does what its policies and procedures say that it does, and helps to ensure that this is what it should do. Effective monitoring, audit and review systems:
• Help to identify any deficiencies in the policies and procedures for the isolation of plant and equipment
• Identify and implement any necessary corrective action before these lead to incidents
• Identify of how well the isolation of plant and equipment is are controlled within the organisation
Summary
Safe isolation of plant and equipment is an important part of the management of health and safety at work and, as such, should form part of the documented policies and procedures of the company (including the Health and Safety Policy). Risk assessments must be carried out to determine the range of control measures required. These control measures may include items such as Permit to Work Systems, etc. All policies, procedures and risk assessments must be kept up to date and should be monitored and reviewed regularly and should be revised as necessary.
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