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Permit-To-Work System - (20-0029PR) - tcm24-174597 REPSOL
Permit-To-Work System - (20-0029PR) - tcm24-174597 REPSOL
Purpose
The purpose of this document is to establish a standardized Permit to Work (PTW) System in E&P production
assets.
The main objectives are:
Establish the mandatory conditions to control any work executed by an Organization Unit in the Area of
responsibility of another Organization Unit, by means of written documents known as “Permits to Work”.
Establish the process and responsibilities for operating the PTW System.
Specific local legal requirements shall be applied when implementing this procedure. In case of difference between
the requirements of this procedure and local requirements, the more stringent requirement shall be applied.
Scope of application
It covers all E&P activities and projects that are carried out in the operated production assets onshore and offshore.
In case of non-operated production assets, all reasonable attempts to influence partners to implement this procedure
should be made.
Framework regulations
Permit to Work System (00-00468NO)
Safety and Environmental Risk Management at Industrial Assets Standard (00-00353NO)
Confined Space Entry (00-00472PR)
Incident Management (00-00343PR)
Implementation and compliance with the "Basic Safety Rules" (00-00533NO)
© REPSOL, S. A., 2017. All rights reserved. This document is the exclusive property of Repsol, S. A. and may only be used by the companies of the Repsol Group and their staff, in the exercise of their respective roles as employees
of the Repsol Group, except with the express written consent of Repsol, S. A. It may not be revealed to third parties, copied, distributed, reproduced, made public and/or modified, totally or partially, without the express written consent
of Repsol, S. A. Repsol reserves the right to take appropriate action against any violation of the terms in this section.
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Index
1. Definitions and Acronyms.................................................................................................................................... 4
1.1. Definitions ............................................................................................................................................. 4
1.2. Acronyms .............................................................................................................................................. 5
2. Permit to Work process ........................................................................................................................................ 6
2.1. Step 1 – Generate PTW ........................................................................................................................ 8
2.1.1. Carry out Risk Assessment ................................................................................................... 8
2.2. Step 2 – Authorize and verify ................................................................................................................ 9
2.3. Step 3 – Perform the Work ................................................................................................................... 9
2.3.1.Perform Gas/Atmosphere tests ............................................................................................ 10
2.4. Step 4 – Manage Revalidation, Suspension, Cancellation and Closure ............................................ 10
2.4.1.Revalidation .......................................................................................................................... 10
2.4.2.Suspension ........................................................................................................................... 10
2.4.3.Cancellation .......................................................................................................................... 11
2.4.4.Closure .................................................................................................................................. 11
2.5. Step 5 – Record .................................................................................................................................. 11
3. Types of PTW and Certificates .......................................................................................................................... 11
3.1. Cold Work Permit ................................................................................................................................ 12
3.2. Hot Work Permit .................................................................................................................................. 12
3.3. Confined Space Entry Certificate ........................................................................................................ 14
3.4. Radiation Certificate ............................................................................................................................ 14
3.5. Excavation Certificate ......................................................................................................................... 15
3.6. Isolation Certificate.............................................................................................................................. 15
3.7. Work at Height Certificate ................................................................................................................... 16
3.8. Electrical Work Certificate ................................................................................................................... 16
3.9. Additional Verifications ........................................................................................................................ 16
3.9.1.Lift Plan ................................................................................................................................. 17
3.9.2.Diving Plan ............................................................................................................................ 17
4. Use of PTW in unmanned installation ............................................................................................................... 17
5. Use of PTW in simultaneous operations (SIMOPS) ......................................................................................... 18
6. Use of PTW in Major Work areas ....................................................................................................................... 18
7. Personnel qualified to authorize PTWs ............................................................................................................ 19
8. Monitoring and auditing ..................................................................................................................................... 19
9. Roles & Responsibilities .................................................................................................................................... 20
10. Exemptions .......................................................................................................................................................... 22
11. Appendices .......................................................................................................................................................... 22
Appendix I. Reference documentation ............................................................................................................. 22
Appendix II. Cold Permit to Work ..................................................................................................................... 22
Appendix III. Hot Work Permit.......................................................................................................................... 22
Appendix IV. Confined Space Entry Certificate ............................................................................................... 22
Appendix V. Radiation Works Certificate ......................................................................................................... 22
Appendix VI. Excavation Certificate ................................................................................................................. 23
Appendix VII. Isolation Certificate .................................................................................................................... 23
Appendix VIII. Work at Height Certificate ........................................................................................................ 23
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Simultaneous Operations (SIMOPS): Simultaneous Operations are considered when there are different
operations in the same Area, authorized by different authorizers, typically when Drilling, Workover,
Construction or other operations take place in the Production Area. This situation is likely to increase the
level of risk due to the interferences between them.
In these cases a SIMOPS form shall be created to coordinate all the works managed or authorized by every
authorizer.
Task Observed Person: A person who was observed on an specific task and deemed fully competent to
carry out the task safely according to the applicable procedures. Task Observation is a system based on
competency, evaluation and monitoring which has to be done by Repsol and according to the BU Task
Observation program.
Task Observation is valid for a limited period of time, and when expired has to be renewed accordingly.
Tool Box Talk: A talk by a Permit Requester / Performing Authority with the Work Performers about the task
risks and conditions of the PTW at the workplace.
Unmanned Installation: An installation where the owner of the area is not present daily.
Work Performer: A person who works under the terms of the PTW , i.e., a performing crew.
1.2. Acronyms
ALARP: As Low As Reasonably Practicable
BU: Business Unit
E&P: Exploration & Production
HSE: Health, Safety and Environment
JSA: Job Safety Analysis
LEL: Lower Explosion Limit
LOTO: Lock Out / Tag Out
OU: Organizational Unit
PTW: Permit To Work
Repsol: The Repsol Group of Companies
TRA: Task Risk Assessment
WO: Work Order (OT: Orden de Trabajo)
SIMOPS: Simultaneous Operations
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If any of the Worker Performers is changed, the Performing Authority shall inform new Work Performer about the
identified hazards and implemented safety measures for the correct execution of the work. In case of existence of
JSA, the new Worker Peformer has to sign it.
The Authorizer shall maintain safe operations while the work covered by the PTW is being performed. It is
recommended that both Authorizer and Requester conduct regular inspections in order to verify compliance with the
specifications stipulated for the work.
2.3.1. Perform Gas/Atmosphere tests
The Authorizer is responsible for ensuring that Gas/Atmosphere tests are performed and registered as established
in the PTW and during the permit validity period.
Should any of the Authorizer’s inspections reveal deviations from the specifications, he or she shall immediately
suspend the work and correct the deviations (see Step 4).
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2.4.3. Cancellation
If the work environment or equipment conditions established in the PTW change, the current PTW shall be
cancelled, and a new one shall be prepared.
PTWs shall be cancelled if the following circumstances occur, and in order to restart the work, a new PTW is
required:
Expiration of their validity date and time, with no revalidation being possible (i.e. more than five days since
first authorization, no revalidation boxes available).
Unforeseen modifications in the work conditions provided for in the original permit.
Changes in the pre-established safety conditions.
Only the Authorizer is allowed to cancel a PTW.
2.4.4. Closure
PTWs shall be closed once the work has been fully completed or when the work is dismissed (the work will not be
restarted again).
The following steps shall be carried out either when the work has been completed or dismissed:
Re-establish normal operating conditions in the area and/or equipment involved.
Remove all additional protective devices and isolation means (alarm by-passes, safety systems inhibits,
etc.) used for the work.
Ensure all waste is properly handled and the work area is clean with proper housekeeping.
Before Closing the PTW, the Authorizer or delegated person shall verify that the previous actions have been
implemented. Only the Authorizer is allowed to close a PTW.
Once the Performing Authority and the Authorizer have confirmed compliance with all these conditions, they shall
close the PTW and sign all the copies indicating their respective approval.
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Isolation
Working at Height
Electrical Work
Templates of PTWs and Specific Certificates are provided in Appendix II to IX. However:
a) BUs are expected to include local requirements if necessary
b) In all cases, the form shall be printed out in keeping with the following considerations:
Correlative number pre-printed.
At least two copies, Authorizer and Performing Authorizer.
Proposed colors:
i. Cold PTW. White with a light blue frame
ii. Hot PTW. White with a light red frame, and a diagonal light red band
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The following flowchart can be used as a guide for the selection of the PTW when potential ignition sources are
involved:
In general, and as example, if any of the following is used in a classified area (or an area with the possible presence
of flammable or combustible materials) the work shall be considered as a “high energy” hot work:
Welding machines
Radial cutters
Heat treatments
Flame cutting
Tin lamps, torches
Bonfires of any kind or type
Explosives
Pyrophoric handling
Decreased material stress / preheating prior to welding electrical induction.
Grinding
All open fires.
In Classified Areas, any activity in which the equipment used is capable of generating sparks or heat while being
operated shall be considered Hot Work. For example:
Equipment with internal combustion engines, including automobiles
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Electrical equipment that is not protected in accordance with the classification of the area
Tools operated by compressed air or by hand, that are used to chisel, cut, break, strike, caulk or drill metal,
concrete or masonry
Sand blasting and grout blasting
Flash photography
Opening of electrical equipment under power
Hand-operated tools not made of non-sparking material
Any source of static electricity
In the event of work in presence of naked/open flames (High Energy hot works), continuous Gas/Atmosphere testing
is required. Consequently, for works considered as ‘High Energy’ the following boxes in the Hot Work PTW form
(see Appendix III) have to be ticked:
- High Energy box
- Continuous Gas/Atmosphere monitoring box
It is recommended that continuous Gas/Atmosphere testing is used in Hot Work as well.
When the value of the gas concentration measured by the Gas/Atmosphere test is higher than 10% of the Lower
Explosion Limit (LEL), the work shall not be authorized, or must be stopped.
A Hot Work Permit can be used alone or in conjunction with other specific Certificates, depending on the nature of
the work. The Permit form includes risks and tasks and formally sets out the control measures to be put in place.
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Locking and unlocking of ionizing radiation sources requires control measures, including site inspection, source
exposure controls, access or containment barriers and radiation monitoring to minimize the risk of exposure (see
Appendix V).
Radiation Certificates are always used in conjunction with the corresponding Work Permit.
Only certified personnel are authorized to manage, handle or isolate ionizing radiation sources. Specific local
regulations must be followed.
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* except for works in the LIST OF WORKS THAT CONTRACTOR CAN CARRY OUT WITHOUT PTW IN
UNMANNED INSTALLATIONS.
List of works that the PTW can be issued remotely for contractors in unmanned installations: Only routine
works with risk level less than 35 based on Safety and environmental risk management at industrial assets standard
(00-00353NO) are included in this list. These works have to be carried out according to the specific procedures that
are already prepared and approved by Repsol. The workers have to be task observed by Repsol on these works
based on the procedures. The list of these works is provided in Appendix XII.
List of works that a contractor can carry out without PTW in unmanned installations: Only routine works that
do not need access to classified areas, with risk level less than 35 based on Safety and environmental risk
management at industrial assets standard (00-00353NO) are included in this list. These works have to be carried out
according to the specific procedures that are already prepared and approved by Repsol. These specific procedures
have to include required communications to area owner before, during and at the completion of work. The workers
have to be task observed by Repsol on these works based on the procedures. The list of these works is provided in
Appendix XIII.
The process to issue and authorize the PTW remotely requires:
- Filling out of the format by the Performing Authority
- Definition of communication channels including phone, radio, email, etc. between Authorizer, Performing
Authority, Operator, Requester and Affected Area when applicable.
- Auditable evidences and documents like photo, video, etc. for verification of safety measures definition and
implementation by Authorizer.
- Once the implementation of safety measures have been verified, the Authorizer issues the PTW
accompanied with the auditable evidences of PTW authorization including SMS text, email, electronic
signature, etc.
- Auditable evidences of PTW closure signature including SMS text, email, electronic signature, etc.
Each Asset shall prepare a formal written process for remote issue and approval aligned with the abovementioned
criteria.
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Operator Cross reference all of the hazards that may interact when there are multiple PTWs active in
the area under the responsibility of Operator, and keep the performers informed of the
possible interactions
Inspect the work area and verify that it has been left in safe working condition
Perform Gas/Atmosphere tests at the beginning of the work, and ensure that
Gas/Atmosphere tests are carried out according to the PTW requirements during the validity
of the permit
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ROLE RESPONSIBILITIES
Carry out the necessary activities to request authorization to do work under his or her
responsibility that must be controlled by permits
Inform third parties of potential dangers while the work is in progress
Propose preventive and hazard control measures
Ensure that frequent inspections are conducted to verify compliance with the PTW
Permit Requester
conditions
Suspend the work if compliance deviations are identified and correct any such deviations
Coordinate with the Performing Authority the work preparation and execution, in due time
and manner
Ensure all personnel performing the work are competent and skilled
Advise on general PTW issues and in the implementation of this procedure
If necessary provide initial risk assessment advice regarding activities and sites so the
Permit Requester can start the PTW process
BU HSE
Provide support for risk assessement
Representative
Monitor the open/ongoing and closed/filed PTWs on a regular basis and consolidate the
outcome
PTW System audit
Validate the PTW, if required, and provide advice regarding the risks associated with the
Affected Area work in the area of responsibility
Responsible
Inform any personnel within the area of responsibility that could be affected by the works
Ensure all personnel performing the work are competent and skilled
Post a copy of the relevant active Permit to Work in a visible place
Give an onsite safety talk to all employees involved and obtain signatures of all Work
Performers to confirm that they have attended the safety talk
Verify that all the conditions and preventive measures are fulfilled according to the
requirements included in the PTW form.
Performing Authority
Ensure that the safety measures are complied with by the work team once the work has
been completed
Suspend PTWs until compliance with procedures and safety practices is confirmed
Close the Permit to Work after inspecting the work area and ensuring that the area has been
left clean and safe and the equipment is operational or secured once the work has been
completed
Work Performer Follow the instructions provided in the PTW
Act in accordance with the applicable procedures and practices established in the BU and in
Contractors
this document.
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10. Exemptions
If for any reason, compliance with this procedure is deemed not possible, a formal risk assessment shall be
undertaken to demonstrate that the HSE risks associated with the PTW, will be both ALARP and Tolerable as
defined in the E&P Hazard Management Procedure (012 MR 03400 MN EP). The risk assessment must be
reviewed by the owner of this procedure and a variance must be signed by the corresponding level of authorization
according to the norm on Safety and Environment Risk Management in Industrial Assets (00-00353NO).
11. Appendices
Appendix I. Reference documentation
Internal Reference Documentation
DG E&P Managing HSE in contracts Practice (030 PR 03461 MN UP)
DG E&P HSE Bridging Document (031 PR 03464 MN UP)
DG E&P Lifting and Hoisting Operations Practice (026 PR 03467 MN UP)
Temporary Shut-down of Safety Protection Systems (00-00470PR)
Use of temporary electrical installations (00-00471PR)
Permit to Work Practice (North American Operations) NAO-HSEOI-PRA-05-02
Permit to Work (Malaysia) TML-HSE-GEN-PR-L-0023
Work Permit (Norway) POP-PRO-TEN-011
Permit to Work Program (Marcellus) HSSEOI-PRG-05-03-01
Safe Work Permits – Edson Gas Plant OP-1-28
Other Permit to Work related operational documents
External Reference Documentation
OGP - Guidelines of Permit to Work (P.T.W.) Systems. Report No 6.29/189 January 1993
Guidance on Permit-to-Work Systems. UK Health and Safety Executive, 2005
The safe isolation of plant and equipment. UK Health and Safety Executive, 2006
OGP – Diving Recommended Practice. Report No 411 June 2008
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Appendix XII: List of works that the PTW can be issued remotely for contractors in
unmanned installations
1. Crude Truck loading and unloading
2. Water Truck loading and unloading in classified Area
3. Road Maintenance (Only specific to Repsol owned roads/leases)
4. Vegetation Control (Walking and working with chemicals)
5. Trim Inspections (Checking valves and flanges to ensure they are still intact)
6. Hazardous waste removal
7. Meter calibration
Appendix XIII: List of works that a contractor can carry out without PTW in
unmanned installations
1. Water Truck loading and unloading in non-classified Area
2. Domestic waste removal
3. Drinking bottled water delivery
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Approval
Validity
This procedure will become valid on the tenth (10th) working day after the date of its approval.
Revoked regulation
None
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