Cold Work Safety Manual Page 1 of 13
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BP U.S. Pipelines and Logistics (USPL) Cold Work Safety Manual Page 1 of 13 Cold Work 1. Purpose The purpose of this policy is to establish the US Pipelines and Logistics (USPL) requirements for controlling and managing a wide range of risks associated with the performance of “cold work” as defined herein. 2. Scope This policy applies to all employees and contractors while performing cold work on behalf of USPL. The following policies and procedures are either referenced or are applicable to this policy and should be consulted for specific related requirements and guidance: • Authorization to Work • Radiation Safety • Diving Procedures • Respiratory Protection Policy • Electrical Safety • Shift Handover Procedure • Lessons Learned Procedure • Stop Work Procedure • Level 2 Hazards Identification and • Working at Heights Task Risk Assessments (HITRA) Procedure • Lockout Program 3. Minimum Requirements Supporting Minimum Requirements Documentation 1. A Cold Work Permit shall be completed and issued prior to conducting any permitted cold Section 6 & work as defined in this policy. Appendix II 2. All Cold Work Permits shall be issued by an Asset Operator (or Asset Operator Designee) Section 5 & 6 and shall be received by a Performing Authority. Self-permitting is prohibited. 3. A Level 2 HITRA shall be conducted prior to issuance of Cold Work Permits specified in Section 6 Section 6. 4. Individuals performing cold work roles shall be trained and competent to execute their Section 7 responsibilities as defined in this policy. 5. All personnel performing work on behalf of USPL have the responsibility and authority to Section 5 stop any work they consider to be unsafe. 4. Definitions Asset Operator (AO)—A BP employee who is responsible for the operation of the asset where work is being performed. The Asset Operator shall be accountable for the asset equipment being in a safe condition for the scope of work to be performed. The Asset Operator or an Asset Operator Designee (if used) is responsible for the completion of the ATW form. Revision Date: July 8, 2014 Effective Date: December 31, 2014 Next Review Date: July 8, 2019 Paper copies are uncontrolled and valid only at the time of printing. The controlled version of this document can be found in DRM in the HSSE Policies folder. BP U.S. Pipelines and Logistics (USPL) Cold Work Safety Manual Page 2 of 13 Asset Operator Designee (AOD)—A BP employee or contractor individual who is authorized to issue ATWs and / or permits on behalf of the Asset Operator. Note: Reference the Authorization to Work policy for additional information Authorization to Work (ATW)—An approved management system that controls work in a safe manner through the use of the ATW form. Boundary—For the purposes of this policy, an approach limit as applied to electrical safety: • Arc flash boundary—When an arc flash hazard exists, an approach limit at a distance from a prospective arc source within which a person could receive a second degree burn if an electrical arc flash were to occur. • Limited approach boundary—An approach limit at a distance from an exposed energized electrical conductor or circuit part within which a shock hazard exists. • Prohibited approach boundary—An approach limit at a distance from an exposed energized electrical conductor or circuit part within which there is an increased risk of shock, due to electrical arc-over combined with inadvertent movement, for personnel working in close proximity to the energized electrical conductor or circuit part. • Restricted approach boundary—An approach limit at a distances from an exposed energized electrical conductor or circuit part within which a shock hazard exists. Cold Work—Cold work is a work classification that includes construction, maintenance, demolition, remediation, operation or other work that does not fall into one of the following categories. • Confined Space Entry • Excavation • Hot Work • Lifting and Rigging Exposed (as applied to electrical live parts)—Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to parts that are not suitably guarded, isolated or insulated. Isolations—Blocking in, blinding or lockout of equipment or systems Job Site—Within visual proximity of the work being performed Level 2 Hazard Identification Task Risk Assessment (HITRA)—Is a structured process to identify the hazards and specify actions to mitigate these hazards for a work activity or task. On-site—Physically being on the property or within the property fence line where work is being performed Overrides—Controls or interlocks that have been bypassed or disabled Performing Authority—A BP employee or individual contractor who receives a permit once it has been issued by the Asset Operator or Asset Operator Designee. The Performing Authority is responsible for ensuring that everyone working under a specific permit adheres to the permit’s documented conditions. Note: Reference the Authorization to Work policy for additional information Permit Issuance—The act of the Asset Operator or Asset Operator Designee issuing a permit to a Performing Authority. Permit Issuance is documented in Section C of the ATW form. Note: Reference the Authorization to Work policy for additional information Permit Issuance Delegation—The act of the Asset Operator delegating the responsibility of issuing permits to an Asset Operator Designee on behalf of the Asset Operator. Permit Issuance Delegation is documented in section D of the ATW form. Permit Register— A log for recording the status of permits and Lock Outs Tag Outs (LOTOs). Revision Date: July 8, 2014 Effective Date: December 31, 2014 Next Review Date: July 8, 2019 Paper copies are uncontrolled and valid only at the time of printing. The controlled version of this document can be found in DRM in the HSSE Policies folder. BP U.S. Pipelines and Logistics (USPL) Cold Work Safety Manual Page 3 of 13 Permitted Cold Work is work that requires a Cold Work Permit and may require a Level 2 Hazard Identification and Task Risk Assessment (HITRA). The types of Permitted Cold Work include the following which are defined in Section 6.1: • Breaking Containment Pressure Relief • Diving • Energized Electrical Work • Movement of Heavy Equipment inside a Facility • Radiation Source • Toxic Substance Exposure • Work at Heights Qualified person—One who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved. Shall—is used where a provision is mandatory. Should—is used where a provision is preferred. Simultaneous Operations (SIMOPS)—Separate activities including product movement or work tasks that have the potential to impact each other. Workforce—Any BP employee or contractor who is engaged in performing work on behalf of USPL 5. Roles and Responsibilities 5.1. Asset Operator (or designee) A. Shall issue permits to the Performing Authority or can delegate permit issuance to the AOD. 1. Shall review and verify that permit conditions are deemed acceptable for the defined scope of work and affected equipment. B. Shall determine if changes can be made to a permit if permit conditions are exceeded or if the permit should be cancelled and a new permit issued. 1. If the Asset Operator determines that changes to the permit can be made, he / she shall document their approval of the changes by initialing the changes where they are documented on the permit. Note: Refer to the Authorization to Work policy for additional requirements. 5.2. Performing Authority A. Shall receive permits from the Asset Operator or Asset Operator Designee. B. Shall monitor the permitted cold work and verify that the work is performed within the conditions documented on the Cold Work Permit C. Shall reassess the job site and revalidate the permit before work can resume if permitted work is interrupted or if the job site is left unattended, or if necessary, cancels the permit and returns it to the AO / AOD. D. Shall stop work, suspend the permit, and notify the AO / AOD if permit conditions are exceeded. E. Shall verify that changes to permits issued by phone-validation are verbally approved by the Asset Operator or Asset Operator Designee if utilized, and shall initial approved changes on the permit and communicate them to the workforce before allowing work to recommence (see Section 6.3.H). Revision Date: July 8, 2014 Effective Date: December 31, 2014 Next Review Date: July 8, 2019 Paper copies are uncontrolled and valid only at the time of printing. The controlled version of this document can be found in DRM in the HSSE Policies folder. BP U.S. Pipelines and Logistics (USPL) Cold Work Safety Manual Page 4 of 13 Note: Refer to the Authorization to Work policy for additional requirements. 5.3. Workforce A. Shall participate in the development and / or review of Level 2 HITRAs. B. Shall verify that equipment used in performing work is fit for purpose through visual inspection and / or review of any certification. C. Shall stop work per Stop Work Procedure if conditions change in such a way that permit conditions or controls listed in the permit are not in compliance. D. Shall report any lessons identified per Lessons Learned Procedure. Note: Refer to the Authorization to Work policy for additional requirements. 6. Cold Work Permit A Cold Work Permit (Appendix lll) is a formal documented agreement between the Asset Operator and the Performing Authority that along with a completed ATW and a Level 2 HITRA (if applicable), authorizes the performance of the tasks specifically identified in the permit. 6.1. Types of Permitted Cold Work Note: A Level 2 HITRA is required for the following Cold Work Permits: Breaking Containment Pressure Relief, Diving, Energized Electrical Work, Toxic Substance Exposure, and Work at Heights.