Professional Documents
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Permit to Work System
Introduction
The petroleum operations have been constantly developing, upgrading and improving their design and
operating techniques in terms of economy of scale, high quality products and energy optimization to meet
the stiff market competition.
Major accidents like Bhopal , Mexico city ,Seveso , Flexiobro and others in the last two decades or so
have shaken the confidence of general public about the safety of the people, property and environment.
In fact, some companies have been closed down on account of poor safety and environmental performance.
After these major disastrous government authorities, human activist groups and corporate
houses in many countries including India have taken a number of steps to evolve a strategy
to avert major mishaps in the installations which have the potential to cause loss of human
life, property and environmental damage.
No doubt, health, safety and environment issues are very critical in the petroleum
operations in the current scenario.
HSE Model and its Integration with Business
Whatever way you look at these functions, industrial hazards–unsafe acts or situations are the basic
problems to be managed.
When an industrial hazard leads to an immediate or sudden accident or incident like an injury, fire,
explosion or a toxic release, it becomes a safety issue and safety management comes in the picture.
When the hazards have chronic effects on the health of workforce like stress, musculoskeletal disorders
and other industrial diseases, it becomes occupational health problem.
On the other hand, when the effect of the unsafe situations is long term and spread over larger areas
beyond the boundary limits, it becomes an environmental problem.
No doubt, HSE efforts of many organizations are driven by statutory requirements and they do whatever
minimum is required to avoid litigation and fines.
However, an efficient and enlightened corporate see HSE in a much broader perspective. For them a good HSE
performance is an integral part of efficient and profitable business management.
They are committed to improve their health, safety and environment and fire protection performance on a
continuous basis and in a sustainable way, i.e., meeting needs of present without compromising the ability of
future generations to meet their needs.
The compulsion of integrating HSE functions with business can be well appreciated by looking into the cost of
an accident/ incident.
The above does not include the cost of psychological and social factors associated with major incidents.
Considering all these it is sensible to integrate HSE as important management function like production,
maintenance, finance, marketing, human resources, etc.
HSE Management Framework
•As said earlier, many organizations try to meet only the minimum regulatory requirements. But this is not enough
in today’s business and social environment. Regulations alone can not guarantee the safety of petroleum installations.
•Most of the regulatory agencies lay down rules and regulations, which are the minimum basic requirements for the safe
design and operation of an installation.
•Sound and safe engineering practices are equally important but are not adequately addressed in their requirements. The
statutory and law enforcing agencies are generally slow in updating their rules and requirements to keep pace with the
technological and social changes.
•Further, many regulatory agencies do not have adequate infrastructure and manpower to exercise superintendence and
control of industrial safety performance on a continuous basis.
•For example, number of safety inspectors, boiler inspectors and environment specialists in most states are far less than
what would be required to undertake meaningful inspection visits to a large number of installations under their jurisdiction.
•Further, with the background and training that many factory inspectors have, their visits to factories are restricted to
checking basic amenities like first-aid facilities, guards for machines, personal protective equipment, potable water and
canteen facilities, etc. They probably don’t have the right training and aptitude for identifying the many process
hazards which are not so obvious.
• The regulatory requirements are just very minimum requirements to obtain licence and operate an installation.
• In petroleum operations which is a hazardous industry, lot of self-regulatory initiatives by the management are required
to maintain a high level of safety.
• So the best framework of HSE management is to comply with the regulatory requirements and have a highly efficient self-
regulatory system in-house.
NEED FOR HSE MANAGEMENT
• Regulations alone are not enough to maintain a very high level of safety in petroleum
and allied industries, which have many inherent hazards.
• In order to prevent major accidents and mishaps and to win confidence of general public
- management, leadership and commitment is very essential.
• Even for implementing and compliance of regulatory measures, a committed leadership
is necessary.
• This can be achieved by establishing an effective and efficient Health, Safety and
Environment (HSE) Management System.
HSE Management Profile
There are certain characteristics of an integrated HSE management system that should be in
place to ensure that the system functions most efficiently and effectively.
These characteristics are sufficiently generic to apply to any type of petroleum installation-
whether an offshore or onshore oil/ gas exploration and production facility, a refinery or a
petrochemical complex, bulk or retail marketing outlet, etc.
Not all characteristics or features may be needed in every installation; however, these have
particular value as a profile of the principal requirements of an effective HSE management
system that can be adopted to suit the particular needs of the installation.
Some important features of an effective and efficient HSE management system are
discussed below.
HSE Policy
• Every organization must have a written policy on health, safety and environment signed
by the Head of the organization with date.
• The copies of this policy should be displayed at prominent places in the organization so
that everybody is familiar with its contents/intentions.
• Some organizations ensure that every employee receives a copy of its HSE policy.
• HSE policy spells out the values, beliefs and commitment of the organization towards
health, safety of its employees, community and at the macro level of the nation.
What does ‘HSE POLICY’ Contain?
•Health and safety of personnel, and protection of environment overrides all production
targets in our organization.
• Production and HSE are complementary to each other. Safety and environment protection
is everybody’s business in the organization.
•All personnel must use approved safe working procedures without making any risky short
cuts
• All personnel–own or contractors–must be given relevant training before assigning
them work
• All plants, facilities and work procedures/ systems must be audited periodically by in-
house teams as well as external agencies
• A very high standard of house keeping must be maintained at all places of work–
plants, offices and facilities
• All accidents, however small, must be investigated and followed up. The lessons learnt
from these accidents should be disseminated to all levels of workforce
• HSE Chief should be a qualified engineer with long experience in various functions.
• HSE organization should be fully integrated with various safety and health committees.
Custodianship/Ownership
Health, Safety and Environmental management is a teamwork.
Every member of the team contributes in maintaining a high level of safety in his area of work.
In order to manage HSE effectively in a petroleum installation or complex which is usually a large entity it is important
and desirable to demarcate each area of the installation/complex and assign the ownership/custodianship to a senior
member of the concerned area.
These areas are commonly called safety districts.
These districts should be shown on the layout drawing of the complex with all the boundaries clearly identified and
marked.
The objective of safety districts is to decentralize the HSE responsibility to the functional
owner/ custodian of the area who is fully responsible and accountable for all management
functions in his district with specific reference to control/management of health, safety
and environment.
Following is a broad list of typical procedures on health , safety and fire protection and environment functions
applicable for most petroleum operations.
The procedures relevant to particular installations should be identified and documented clearly in simple language so
that everybody working in these installations understand them.
Procedure should be revised and update periodically to reflect changes that might take place over time
Safety related procedure
Basic Safety Related procedure for Employees, Contractors and Visitors-------
• Safe Work Permit System
• Mechanical Isolation
• Pre Start-up Safety Review
• Entering and Working in Confined Spaces
• Working at Height
• Safe Scaffolding and Ladders
• Safe Excavation
• Safe Handling of Hazardous Substances
• Safe Handling of Hydrogen Sulfide, Chlorine, Ammonia, etc.
• Safe Use of Hoses
• Contractor Safety
Ionization Radiation Safety
Safety Audits
Personnel Movement and Transportation by Road , Cranes, Basket, Boats and Helicopters
• Grinding, Welding and Cutting
• Safety Signage’s, Labelling and Posters
• On-site Emergency and Disaster Management
Grinding, Welding and Cutting
https://www.marineinsight.com/marine-safety/7-precautions-to-take-while-grinding-using-hand-held-grinders-on-ships/
Working at height
DO as much work as you can while you are on the ground.
DO make sure that the employees can safely move to and from the area
where they are working at height.
DO ensure that the equipment that you’re using for the job is strong, stable
and suitable enough to get the job done. Inspect and maintain them
regularly.
DO be careful when you are working near to a fragile surface.
DO ensure that you are protected from falling objects.
DO make preparations for emergency evacuations and rescues.
DON’T overload the ladders that they are working on, with equipment or
materials.
DON’T try to reach too far when you’re on a ladder or stepladder.
DON’T use ladders or stepladders to do work that entail heavy or strenuous
tasks. Only use them to do work that’s quick and light.
DON’T allow incompetent workers do any work at height.
DON’T lean or place the ladder on or fragile upper surfaces.
DON’T stay quiet when you feel someone is compromising their own safety
or the safety of others
https://www.convergencetraining.com/hazwoper-confine
d-spaces.html https://advancedct.com/the-safety-dos-and-donts-of-working-at-height/
Environment Related Procedures
• Air Pollution Control and Monitoring
This document should address following items related to the health, safety and
environment aspects of the installation:
•Access/Entry to the premises
• Prohibition of smoking, alcohol and drugs
Restriction on naked lights, sparks, use of cameras and mobile phones
Traffic control
Use of Personnel Protective Equipment, PPE
Safe Work Permit System
Accident/Incident reporting
Maintaining good house keeping standard
Basic color codes of piping/equipment, etc.
Safety signage’s
Electrical safety
Hand and portable power tools
Hazards of flammable products and chemicals
Emergency alarms and communication and what to do in such situations
Some general dos and don’ts
Other specific rules
Basic Rules for Visitors
As a bare minimum requirement, every visitor to the premises must be given a safety
briefing before giving him an entry pass.
Every installation should make a similar briefing relevant to its operations and local
conditions.
Access /Entry to the Premises
•Every person must display a valid identification badge issued by the security
•Visitor should visit the designated area only for which he has obtained the entry pass
•Matchboxes, lighters, flashlights and cameras are not allowed inside the premises
•Visitor is not allowed to touch any equipment interfere with the plant activities
• All persons must wear safety helmets and safe shoes in process areas. Requirement of
any other personal protective equipment will be advised by plant personnel
•Use following telephone nos. in case required: Fire l00 Security 101, Medical 108
Accident Reporting and Investigation
In spite of good systems in place and people taking precautions while doing their
work,
the possibility of, accident can not be ruled out.
It is necessary that each organization should have a good accident reporting and
investigating system in place.
Methodology
The first step is to have a proper accident reporting system.
In this direction, every petroleum installation should make a standard procedure for
notification and reporting of any accident to the concerned officials of the installation and
outside agencies.
This procedure should list the contact telephone numbers of key people.
In case of any accident, the personnel on duty should inform the concerned people as per
this procedure.
Depending upon the nature of accident, an investigation team should be set up which should
go into all details-plant data, log sheets, strip charts, historian, interviews with personnel,
photographs, videos of effected area and equipment, etc.
Effects and consequence models are available which can be very helpful in the investigation
of process type of accidents.
The team should make an honest report so that right decisions can be taken.
Many a times investigations done by internal teams are not very objective.
They tend to blame only the hardware and design of the facilities.
They are not comfortable in bringing out the human factors and fixing accountability.
If we have to learn from an accident and take proper corrective actions to avoid recurrence,
the investigation report must be frank and unbiased.
Management should establish a system to determine and document the response to each
finding of the report to ensure agreed upon actions are completed in a time frame.
The lessons learnt from the accidents should be disseminated to all the concerned personnel
in the complex.
In case of multi Unit Company, the conclusions of the investigation report should go to all
the units of the company.
In some cases, the information could also be shared with the other industry.
Training and its Validation
Training is an essential part of any HSE Management programme especially in the petroleum industry.
It must be recognized that imparting relevant training and strict validation of personnel after training is an
absolute requirement for safe operation of any petroleum installation.
The training on health, safety and environment is given to all employees–new and those already working,
contractors, third parties and visitors.
The training received by the new employees and contractors is called the initial training,
which includes comprehensive classroom and practical training in the various HSE
procedures applicable in the installation.
Everybody working in a petroleum installation must receive at least a basic fire fighting
training before he is assigned any work.
Those already working should also receive periodic HSE refresher training to keep them
updated with any changes or developments..
Training through video films can also, to some extent, minimize the language problem.
To ensure that a candidate has understood the instructions, some validation is a must.
This can be an objective type of test at the end of the session. If a candidate has not
performed satisfactorily in the test, he should go through the session once again.
Similarly, visitors should be given a safety brief before entry into the installation so that
they don’t do something unknowingly that may put themselves or others into danger.
Many good companies issue entry passes/ID cards to those entering the premises only after
they have received the required HSE training
Methodology
HSE training should be a mix of theoretical classroom lectures and practical training in the
use of various fire and safety equipment and appliances.
Care should be taken to select the right language(s) to meet the requirement of multilingual
workforce.
Some companies have produced video films, which are shown to the newcomers, especially
contractors, third parties and visitors to give them basic HSE training with minimum
requirement of faculty.
Health, Safety and Environmental Audits
• Statistics show that the root cause of many major accidents and mishaps all over the world is human
error.
• And the main cause of human errors has been the lack of written procedures and/or non-compliance of
the same.
• New plants/ facilities get normalized over a period after meeting the initial challenges of
commissioning and stabilization.
• Thereafter people tend to start relaxing and the systems/ procedures/facilities are not followed as in the
earlier times.
• Many a times systems/procedures are not followed and hardware is not maintained, inspected and tested
as intended.
• Sometimes they are bypassed because of negligence, over-confidence and complacency.
•Various health, safety and environment programmes including their management
systems require thorough auditing to exercise proper control and ensure that the systems
are working effectively
• Such audits are conducted periodically on the systems, procedures and operational
aspects to ensure that a desired level of health, safety and environmental standards are
maintained as per the requirements of company policy and statutory requirements
• Internal audits
• External audits.
Internal audits
• The external audits are done by outside agencies or third parties approved by statutory
authorities to meet requirements under various statutory rules and regulations
• In leading companies, external audits are done not only to meet statutory requirements
but also to bring in a fresh approach and additional objectivity through a third eye.
• It must be understood that external audits are supplementary to the internal audits.
• External audits are generally more global covering the entire premises/installation.
• Typical external audit agencies approved by various statutory authorities include:
• Oil Industry Safety Directorate, OISD
• British Safety Council (5-star audit)
• National Environmental Engineering Research Institute, NEERI
• Central Labour Research Institute, CRI
• Loss Prevention Association, LPA
• National Safety Council, NSC
• Engineers India Limited, EIL
• Lloyds Register of Shipping
• Det Norske Veritas
• Comet Consultancy Services
• Netal Chromatographs
• KLG/TNO
• SGS India Limited
• Others as approved from case to case
Methodology of Audits
Audit Report
Follow-up
Composition/Selection of Audit Team
The team for a comprehensive internal audit comprises a member each from
• Operation
• Engineering/Maintenance,
• Technical services/Technology,
• HSE and any other specific discipline if required.
The chief of the installation through an office order nominates the team.
• The Chief of HSE nominates the team for a mini audit in consultation with individual departments. The
team comprises of two members–one from the area/department to be audited and the other from HSE.
• The programme of such audits is published by HSE through procedures audit schedule published by
him every month.
Conducting the Audit
• To start with, the team gets organized and
holds a kick-off meeting to discuss the
plan of action.
• They try to collect all relevant data of the
area/plant/department they are going to
audit.
• The team visits the area and talks to
various personnel there to get feedback
about their plant/area.
• The team checks the various
systems/procedures and records.
• The safety aspects of the plant are checked
using checklists. These checklists could be
standard lists made as part of a written audit
procedure and supplemented by specific
checklists made for special systems/equipment
by each team before starting the audit
• They check the level of compliance to each checklist item by talking to the plant
personnel and seeing the situation in the field and rate the item on a 1-5 scale (1 is
least compliant, 5 full compliance).
• After discussion, the final report with action plan for implementing the agreed recommendations is
issued by the leader of the audit team to the concerned action parties with copies to top management
team.
• In case of mini audits, the audited checklist is itself the report. This is issued to the concerned
custodian/manager of the area immediately on the same day after the audit is done.
Follow-up
• The effectiveness of the audit lies in the degree of implementation of the agreed recommendation.
• HSE plays a pivotal role in monitoring the recommendations of various audits and presenting the
implementation status to the top management.
• Record of an audit report is maintained with the custodian and HSE till all the recommendations
agreed to be implemented are liquidated.
PERMIT TO WORK SYSTEM
• There are numerous cases where people worked without proper isolation of equipment, cutting off electrical
supply, proper personnel protective equipment, etc.
• Every petroleum installation must have an approved Permit to Work System in place.
• The permit is an official record of safe working conditions agreed upon by the issuer and acceptor of the permit for
carrying out any maintenance, repair, inspection or modification work.
Types of Permits
Various permits applicable in a petroleum installation are listed below:
Depending upon the nature of activities, some or all of the above permits may applicable in a petroleum
installation.
Elements of a Typical Work Permit
•Every installation should design work permit formats as per its requirement and nature of
activities.
•Oil Industry Safety Directorate (OISD )and National Safety Council (NSC) give
guidelines for designing work permit formats.
Some important elements of a typical work permit are as below:
• Type of permit
• Date, time of issue and validity
• Description of location where work is to be carried out
• Brief description of the work
• Detailed safety precautions to be taken
• Name and signatures of person(s) issuing the permit
• Name and signature of the person receiving the permit
• Authorisation by senior management personnel depending on seriousness of the
hazard
• Declaration of completion of job by the receiver withdate and time
Permit Procedure
• Work permit is generally issued by an operating supervisor, called issuer of the permit to the
maintenance supervisor or a contractor, called the acceptor of the permit after ensuring all the
necessary precautions.
• The nature and location of work to be done must be clearly specified in the permit by the issuer who
should explain and show the same to the acceptor in the field.
• The issuer and the acceptor of the permit must be clear regarding the precautions to be followed
for doing the work safely.
• The work can proceed only when both the parties have signed the permit after taking the necessary
precautions.
• The agreed precautions and conditions mentioned in the permit must be maintained during the tenure
of the work.
.
• After the work is completed, both the parties must sign the permit to certify that the work has been
completed as intended, the area has been cleared of all personnel, tools, oil, grease, debris, etc.
• This check is necessary before restarting the equipment.
Following is a list of some precautions required to be taken for giving different work permits.