The RBPS element that helps control hazards associated with maintenance and other nonroutine work is one of nine elements in the RBPS pillar of managing risk. Section 11.2 describes the key principles and essential features of a management system for this element. Section 11.3 lists work activities that support these essential features and presents a range of approaches that might be appropriate for each work activity, depending on perceived risk, resources, and organizational culture. Sections 11.4 through 11.6 include (1) ideas to improve the effectiveness of management systems and specific programs that support this element, (2) metrics that could be used to monitor this element, and (3) issues that may be appropriate for management review.
What Is It?
Procedures are generally divided into three categories. Operating procedures, as described in Chapter 10, govern activities that generally involve producing a product. Maintenance procedures, as described in Chapter 12, generally involve testing, inspecting, calibrating, maintaining, or repairing equipment. Safe work procedures, which are often supplemented with permits (i.e., a checklist that includes an authorization step), fill the gap between the other two sets of procedures. Safe work practices help control hazards and manage risk associated with nonroutine work. In this context, a nonroutine activity is any activity that is not fully described in an operating procedure. Nonroutine does not refer to the frequency at which the activity occurs; rather, it refers to whether the activity is part of the normal sequence of converting raw materials to finished products. Making and breaking connections to unload a railcar would likely be covered by an operating procedure, whereas breaking a connection to remove and calibrate a pressure transmitter would be considered a nonroutine work activity and included in the scope of the safe work practices (safe work) element. Consider a typical work order to calibrate a pressure transmitter with the process in operation. An integrated set of operating, maintenance, and safe work procedures helps prevent accidents and process upsets.
- An operating procedure instructs the operator to place the pressure control loop associated with the transmitter in manual control and return the loop to automatic control when the work is complete. Depending on the hazards present, the operating procedure may also provide instructions on how to clear, drain, and decontaminate the space between the manual valve closest to the transmitter and the transmitter.
- Safe work procedures and permits help ensure communication between the instrument technician assigned to perform the job and production personnel. The procedure or permit should also help ensure that the instrument technician removes the intended transmitter, and that appropriate valves are locked closed (or in the case of a vent line, locked open) prior to removing the transmitter. Safe work procedures may also include steps to help protect against a fire if an enclosure must be opened in an electrically classified area.
- Maintenance procedures help ensure that the calibration work is performed properly and also help protect the instrument technician from a variety of hazards.
Safe work procedures typically control hot work, stored energy (lockout/tagout), opening process vessels or lines, confined space entry, and similar operations. A more comprehensive list of safe work practices is provided in Section 11.2.1. Some facilities also include procedures or practices that protect against standard industrial hazards, such as falling, in the scope of this element. Safe work practices are often required by regulation, regardless of the magnitude of chemical or other hazards present at a facility. Safe work procedures may be applied to construction work, and should be if the work might affect other operations at a facility. Safe work procedures can also help protect equipment from damage resulting from maintenance, construction, or other nonroutine activities (e.g., excavation near underground lines, lifting over process equipment).
Why Is It Important?
Nonroutine work, such as the simple removal of a pressure safety valve on the Piper Alpha platform for recertification, increases risk and can directly lead to conditions that make a catastrophic accident much more likely. Safe work practices are a critical element in the management of industrial safety. For example, from 1992 to 2002, nitrogen asphyxiation during confined space entry resulted in 80 fatalities in the U.S. (Ref. 11.2). This rate of about 8 fatalities per year caused by exposure to a single inert gas is not significantly different from the rate of 6.5 fatalities per year (or 33 fatalities over a 5-year period) caused by releases of one of 130 highly toxic and flammable materials regulated under the U.S. EPA’s risk management program rule (Ref. 11.3). Although this is not a valid method to directly compare risk nor is it proof that inert gases are more dangerous than other hazardous materials, it does demonstrate that safe work procedures are an important safeguard for worker safety as well as for catastrophic accidents such as Piper Alpha.
Where/When Is It Done?
In general, policies related to safe work practices are developed at the corporate level. Procedures and permits that specify how work is to be performed are typically developed by facilities. These procedures and permits are used by operating facilities on a day-to-day basis to control nonroutine work.
Who Does It?
Safety policies are typically issued by a corporate or division safety group. The development of specific procedures and practices is normally assigned to the safety group at each facility, although some companies develop a common set of procedures that is modified/adapted for use at the facility level. Permits are normally issued/authorized by trained operators, supervisors, or safety specialists. Use of safe work procedures and proper execution of nonroutine work is often a shared responsibility between operators, maintenance personnel, and contractors who perform the work.
What Is the Anticipated Work Product?
The main work product of the safe work element is an integrated system of procedures and permits that help protect workers from hazards and prevent the sudden release of process materials or energy during nonroutine work activities. This system is often described in a facility-wide policy that addresses management system issues such as (1) the scope of the safe work element, (2) roles and responsibilities, and (3) the relationship between safe work procedures/permits and procedures developed for other RBPS elements. Policies typically state which activities are permitted with no special controls, which activities require special permits, and which activities are prohibited. Procedures provide details on how the work is to be executed. Permits describe job-specific hazards and specify safeguards. Procedures and permits help ensure that workers understand the hazards and take appropriate actions to manage risk when performing nonroutine work activities. Safe work procedures complement operating and maintenance procedures, and also provide objective standards of performance required to effectively implement the safe work element.
How Is It Done?
Nonroutine work is controlled through a system of procedures and permits. In many cases, permits are required for each nonroutine job, and permits are updated or reauthorized at the start of each shift.