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Section 2 Subsection 7
POLICY
A process must be in place to conduct Energy Isolations.
PURPOSE
The purpose of this policy is to ensure that, prior to working on equipment or systems, all
energy sources are isolated, any stored energy is safely released or adequately controlled
and equipment or systems are safely de-isolated.
SCOPE
This policy covers all personnel, inclusive of Third Party and Service Providers, who work at
Company installations and facilities.
REQUIREMENTS
4.1 General
All personnel conducting Energy Isolations must have completed appropriate Energy
Isolation training.
The Responsible Person (RP), Competent Person (CP) and Person Performing the Work
(PPW) may be a company employee, Service Provider or Third Party person.
There are 3 levels of Energy Isolation:
Where different tasks require the same isolation source, a separate Isolation Certificate,
padlock and/or tag is required for each task.
Energy sources, which include mechanical, electrical, pneumatic, hydraulic and kinetic
energy, are defined in HQS-HSE-PP-01 Energy Sources policy.
The identification of energy sources must consider:
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Where stored energy must be released from equipment or systems, the consequences of
doing so must be fully understood, effectively controlled and documented in a written
procedure and/or included in the Risk Assessment.
When connecting or installing equipment into pressurized systems, for example connecting
equipment such as power slips or casing tongs into a central hydraulic system, the Area
Authority must ensure the equipment will not operate unintentionally when the power supply
is applied.
When de-isolating or re-energizing equipment, there must be a clear understanding of
stored commands, the fail-safe position, and the reset and/or re-start sequence upon reenergizing equipment and systems with a Programmable Logic Controller (PLC) or similar
memory function.
4.1.1
Try To Operate
The Responsible Person (RP), Competent Person (CP) and the Person Performing Work
(PPW) must all be present and verify the effectiveness of the Energy Isolation by following
the Try to Operate process from all control points when:
The on-coming and off-going RP and PPW must Try to Operate from all control points
when work is handed over.
The PPW must Try to Operate from all control points on return to the worksite when
physical lock out has not been possible.
Consider applications where systems or equipment may be in manual or auto mode, may
start on a pressure or temperature sensor or can be remotely operated.
Physically Disconnect - equipment or tool is removed from all energy sources. For
example, an appliance is unplugged from an electrical socket or disconnected from an
air supply.
Lock Out - energy sources are isolated from the equipment or system, physically locked
out (e.g. with a padlock) and tagged.
Tag Out - energy sources are isolated from the equipment or system and tagged.
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4.2.2
Double Block and Bleed for example double valve isolations and the de-energized part
of the circuit is vented to atmosphere and continuously monitored.
Valves tagged.
4.2.3
Certain activities require the installation of a coffer dam on the hull or external blanks fitted
to sea chest intakes and other hull penetrations.
Coffer dams and external blanks and plugs fitted to hull openings are considered Level 1
Energy Isolations and the requirements for Level 1 Energy Isolations must be met.
Each coffer dam, blank or plug must:
Be clearly and individually marked such that the reference markings are clearly visible to
divers and/or ROV
The reference marking must be used in the PTW, Energy Isolation Certificate, WRA, MRSP
and any communications such that it is clear which isolation is under consideration.
Level 3 Isolations must be conducted by a person that has been formally trained in the
use of the equipment being worked on.
4.3.1
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4.3.2
The PPW is the Competent Person authorized to isolate the system being worked on.
The OIM approves the work and stipulates a L2 isolation at the Control of Work Planning
meeting.
Level 3 (L3) Energy Isolations are done by the Person Performing Work and there is a very
low likelihood of unplanned energy release.
L3 Isolations:
Must only be used on equipment that has a single point of operation that remains in the
line of sight and within sole control of the Person Performing Work for the full duration of
the task.
4.3.4
L1 and L2 Requirements
An OIM approved list of Competent Persons to perform L1 and L2 Energy Isolations must
be displayed at the Control of Work Center. This list must include the persons name,
position and the systems the person is authorized to isolate.
The OIM must approve all work requiring L1 or L2 isolation at the Control of Work Planning
meeting.
Personnel conducting L1 and L2 isolations must be authorized to do so by the OIM.
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In addition to the CP Department lock and tag, all personnel involved in work requiring a L1
or L2 isolation must have a personal lock (or personal tag where tag out only is used) on
each isolation point or on a lock box (refer to section 4.5).
A written procedure including the steps required to conduct and verify the effectiveness of
the isolation and de-isolation, for example a Mandatory / Rig Specific Procedure (MRSP /
RSP) RMS procedure or Service Provider specific procedure, and appropriate level of risk
assessment is required for all L1 and L2 Energy Isolations.
The written procedure must include:
Verification of any stored commands, fail-safe positions, reset and / or re-start sequence
or indexing upon re-energizing equipment and systems with a Programmable Logic
Controller (PLC).
The isolation requirements for L1 and L2 isolations are the same in that the physical lock
out/tag out requirements do not differ. The difference is that Area Authority approval is
required for L1.
L1 Isolation Process
1.
The OIM assigns an Area Authority for the Energy Isolation and delegates his
authority to the assigned Area Authority to approve the Energy Isolation. The OIM
may elect to act as Area Authority for certain activities. In the unlikely event that the
Area Authority, RP and CP are proposed to be the same person the OIM must
approve through Control of Work and record on the Control of Work Log.
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2.
3.
The CP and RP review the written procedure and system schematic and identify:
-
The means of starting or energizing the equipment including remote, auto and
pressure activated
4.
The RP ensures the relevant sections of the Energy Isolation Certificate are
completed.
5.
6.
CP conducts isolations.
7.
CP applies department locks and isolation tags. RP applies a personal padlock (or
personal tag where tag out only is used) on every point of isolation unless a lock box
is used.
8.
Where additional personnel will be involved in the task the CP must utilize multihasps or a lock box. Where a lock box is used the CP must place the key to each
department lock into the lock box that will be used on the task. The CP and RP
attach a personal padlock to the multi-hasp or lock box and retain the key.
9.
The CP, RP, PPW work together to release any stored energy in a controlled
manner.
10.
The CP, RP, PPW must be present and Try to Operate from all control points.
11.
PPW ensures all persons involved in the task must have a personal lock (or personal
tag where tag out only is used) on a multi-hasp at each isolation point or on the lock
box relevant to the task.
12.
The PPW must inform the Control of Work Administrator on start, completion and
suspension of the work and the Control of Work Administrator must update the
Control of Work Log accordingly.
13.
On completion of the work, the PPW and the RP must ensure that the worksite is
inspected, is in a safe condition and that all equipment is ready to operate.
14.
RP informs Area Authority and CP that work is complete and equipment can be deisolated.
15.
16.
PPW ensures personal padlocks and keys are handed over or returned to dedicated
cabinets, departmental registers are updated accordingly and that any personal tags
are removed.
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17.
CP de-isolates equipment.
18.
19.
RP returns closed Energy Isolation Certificate to the site designated by the Area
Authority. Refer section 4.7.4.
20.
At the end of every shift, the Area Authority must ensure all closed Energy Isolation
Certificates are returned to the Control of Work Administrator.
4.4.2
L2 Isolation Process
The means of starting or energizing the equipment including remote, auto and
pressure activated
2.
3.
Conducts isolations.
4.
5.
Where additional personnel will be involved in the task the CP must utilize multihasps or a lock box. Where a lock box is used the CP must place the key to each
department lock into the lock box that will be used on the task.
6.
7.
8.
CP ensures all persons involved in the task must have a personal lock (or personal
tag where tag out only is used) on a multi-hasp at each isolation point or on the lock
box relevant to the task.
9.
Completes the Energy Isolation Certificate and informs the Control of Work
Administrator on start, completion and suspension of the work. The Control of Work
Administrator updates the Log accordingly.
10.
11.
Ensures any personal padlocks and keys are handed over or returned to dedicated
cabinet and departmental registers are updated accordingly.
12.
De-isolates equipment.
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13.
14.
4.4.3
L3 Isolation Process
Appropriate risk assessment, as a minimum the use of the Risk Assessment Prompt
Card and The Rules of Task Planning (CAKES).
On/Off switch or valve must remain in the line of sight and within sole control of the
Person Performing Work for the full duration of the task.
Note: If there is a possibility that the valve or switch can be operated unintentionally or
inadvertently then L3 Isolation is not appropriate and lock-out or tag-out must be applied
4.4.4
The status of the previous days L1 and L2 isolations must be reviewed and confirmed
during the next Control of Work Planning Meeting.
Where L1 and L2 isolations extend beyond 24 hours, the work must be reviewed at each
subsequent Control of Work Planning Meeting and either approved, closed or placed into
Long Term Isolation on instruction of the OIM.
Multi-hasp
The equipment is isolated and a multi-hasp is attached to every isolation point. The CP, RP
and each person involved in the task attaches a padlock to the multi-hasp and retains the
key.
One tag must be attached to each multi-hasp.
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4.5.2
Lock Box
The equipment is locked out by the CP and the key to the isolating padlock(s) is placed in a
lock-box. The CP, RP and each person involved in the task attaches a padlock to the lock
box and retains the key.
Lock boxes may be permanently fixed at locations determined by the OIM or be portable
and, for the duration of the task, kept at the worksite or at another area determined by the
RP.
One tag must be attached to each isolation padlock and one tag to the lock box.
Figure 2.7.1 Example Multi-Hasp
4.6
Where physical disconnect or Lock Out is not possible, all energy sources must be isolated
and tagged.
Isolation tags must only be removed by the CP once the equipment is de-isolated.
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4.7.1
Secured in dedicated cabinets and located in an area designated by the Area Authority
Name
Position
Date / Time In
Green
Mechanical
Blue
Marine / Deck
Red
Subsea
Yellow
Drilling
Black
All spare padlock keys must be controlled by the OIM in a secure lock box.
Keys for padlocks used on Long Term Energy Isolations must be kept in a secure lock box
under the control of the Maintenance Supervisor.
4.7.2
Tags must be robust, be able to be adequately secured and clearly state the:
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4.7.3
Lock Boxes (fixed or portable) are used to control access to the keys for Isolation padlocks
and must be fitted with multiple lock hasps for personal padlocks.
4.7.4
Energy Isolation must be reinstated if further maintenance work is required. The PPW,
RP and the CP, must all be present and Try to Operate the equipment or system, from
all control points, to prove that the Energy Isolation is effective.
4.9
The OIM must approve placing equipment or systems into Long Term Isolation using the
Control of Work Planning process.
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Where a L1 or L2 Energy Isolation extends beyond 24 hours, the isolation must be reviewed
at each subsequent Control of Work Planning Meeting and either approved for a further 24
hours, closed or instructed to be placed into Long Term Isolation by the OIM.
The Control of Work Administrator updates the Log accordingly.
When equipment is moved into Long Term Isolation all personal padlocks must be removed
and returned to the appropriate cabinet.
The CP must provide the key for the padlock on each point of isolation to the Maintenance
Supervisor.
All copies of the Energy Isolation Certificate and associated tags on all isolation points must
be marked Long Term Isolation.
The Maintenance Supervisor must retain a copy of all Long Term Energy Isolation
Certificates and maintain a log of all Long Term Energy Isolations.
4.9.1
The CP obtains the Long Term Energy Isolation Lock Out key from the Maintenance
Supervisor and reinstates the controls for the required Level of Energy Isolation.
The Maintenance Supervisor updates the Long Term Energy Isolation Log.
Equipment or systems moving from Long Term Isolation to a L1 or L2 Isolation do not
require a new Isolation Certificate.
Taking Equipment or Systems from Long Term Isolation Into Service
The OIM assigns an Area Authority and delegates his authority to the Area Authority to
approve de-isolation.
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The RP, CP and PPW must ensure that the worksite is inspected, is in a safe condition
and that all equipment is ready to operate.
RP informs Area Authority that work is complete and equipment can be de-isolated.
CP de-isolates equipment.
The Maintenance Supervisor updates the Long Term Energy Isolation Log.
All padlocks must be returned to their dedicated storage cabinet.
Hand over their personal padlock key to their relief. The on-coming person must ensure
the padlock register is updated.
Remove their personal padlock and return both padlock and key to the dedicated
padlock cabinet and update the padlock register.
It is the responsibility of the PPW for L1 isolations, and the CP for L2 isolations, to ensure
that all personal padlock keys have been handed over to oncoming personnel or both
padlock and key are returned to the dedicated padlock cabinet.
The oncoming RP and PPW must sign the Energy Isolation Certificate at the worksite on
handover of Energy Isolations.
When the RP and PPW both change out at the same time, for example at a shift change,
both must be present and, together, Try to Operate from all control points.
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involved with the work. At the discretion of the OIM, the verification may be conducted as
part of a START Tour.
The Area Authority summarizes the Verification findings at the next Control of Work
Planning meeting.
Note: The OIM must assign Area Authorities to conduct at least one verification daily which
may be conducted on either PTW or Energy Isolations.
The Project Manager may propose Service Provider and Third Party personnel to act as
Area Authorities and Competent Persons. The proposed AA and CP must be approved
by the OIM.
RESPONSIBILITY
5.1 Person Performing Work
Inform the Control of Work Administrator when equipment or systems have been
isolated or de-isolated or placed into Long Term Energy Isolation.
Verify the effectiveness of Energy Isolations by following the Try to Operate process.
Ensure all Energy Isolations remain effective while the work is being performed.
Ensure that all personnel involved in the work apply a personal padlock to each isolation
point, the lockbox or multi-hasp.
Ensure a copy of the Energy Isolation Certificate is available at the work site.
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Ensure that all personal padlock keys have been handed over to oncoming personnel or
removed and returned to dedicated cabinets if no longer required.
Ensure that all isolation tags are clearly marked with the required information and are
adequately secured.
Ensure any trapped / stored energy has been released in a controlled manner.
Verify the effectiveness of Energy Isolations by following the Try to Operate process.
Ensure that there is a clear understanding of stored commands, fail safe positions and
the reset and / or re-start sequence upon re-energizing for equipment and systems with
a PLC.
For L2 isolations, ensure all personnel involved in the work apply a personal padlock to
each isolation point, the lockbox or multi-hasp.
For L2 isolations, ensure any personal padlocks and keys are handed over or returned
to dedicated cabinet and departmental registers are updated accordingly.
If an Energy Isolation is placed into Long Term Energy Isolation, hand over all Lock Out
isolation padlock keys and a copy of the associated Energy Isolation Certificate to the
Maintenance Supervisor.
Ensure that equipment or systems, and all affected areas, are made safe prior to deisolation.
Ensure that OIM approval has been given for all work requiring Energy Isolation.
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Inform the OIM of Energy Isolations being placed into, or out of, Long Term Energy
Isolation.
Maintain and display a record of the Energy Isolation Certificate Number and status of
the Energy Isolation.
5.6
Maintenance Supervisor
Ensure all keys used for Long Term Energy Isolations are secured in a dedicated, locked
cabinet.
Retain a copy of the Energy Isolation Certificate for all Long Term Energy Isolations.
5.7 OIM
Approve all work requiring L1 and L2 Energy Isolation and state if L1 or L2 is required.
Ensure all spare keys for Energy Isolation padlocks are removed from circulation and
secured in a dedicated, locked cabinet.
Ensure the URP HSE Bridging Document clearly defines how the requirements of this
policy will be met.
Propose Service Provider and Third Party personnel to act as Area Authorities and
Competent Persons.
DOCUMENTATION
Forms indicated below are included in eDocs and are not to be modified from the original
format. The forms have been developed by HSE and are a requirement of this policy.
Forward any suggested improvements to these forms via the Management System
Feedback Process in GMS.
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A copy of all Energy Isolation Certificates and Continuation Pages must be retained for at
least 12 months.
Examples of these forms are published on the HSE Rig Central web page.
Padlock Register
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