Life Saving Rules Procedure

Originator: Afolabi Banu

Senior Operational HSEQ Adviser

Owner: Andy King

VP Health and Safety

Approver: Bob Fennell

Operations Director

Function: HSEQ

Review Frequency: 2 years

Revision Number: 1

Issue Date: 23 April 2020

To comment on or suggest improvements to this document, please contact [email protected]

Uncontrolled when printed or downloaded from the Chrysaor BMS.

Life Saving Rules Procedure CHRY-UKO-HSEQ-PROC-0584

mailto:[email protected]

Life Saving Rules Procedure Revision 1

CHRY-UKO-HSEQ-PROC-0584 Page 2 of 18


REVISION CHANGE NOTICES

Rev Location of Change Brief Description of Change

1 Throughout. This document issued by Chrysaor as part of the BMS Review Project 2018. Legacy Document Number(s): CHRY-BMS-PROC-HSEQ-1474.

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CONTENTS

1.0 PURPOSE ............................................................................................................................. 4

2.0 SCOPE .................................................................................................................................. 4

3.0 GLOSSARY OF TERMS ....................................................................................................... 4 3.1 Abbreviations .............................................................................................................. 4 3.2 Definitions .................................................................................................................. 5

4.0 ROLES AND RESPONSIBILITIES ........................................................................................ 5 4.1 Chrysaor Personnel .................................................................................................... 5 4.2 Offshore Management Team ...................................................................................... 5 4.3 Offshore Installation Manager ..................................................................................... 5 4.4 Asset Manager ........................................................................................................... 6 4.5 Senior HSEQ Adviser ................................................................................................. 6 4.6 Human Resources Business Partner .......................................................................... 6

5.0 INTRODUCTION ................................................................................................................... 6 5.1 General ...................................................................................................................... 6

6.0 LIFE SAVING RULES ........................................................................................................... 7 6.1 Rule 1: Obtain Authorisation before Entering a Confined Space ................................ 8 6.2 Rule 2: Protect Yourself Against a Fall when Working at Height ................................ 9 6.3 Rule 3: Verify Isolation before Work Begins and Use the Specified Life

Protecting Equipment ............................................................................................... 10 6.4 Rule 4: Know Your Role in Major Accident Prevention, especially Relating to the

Observance of Preventative Measures and Report all Near Misses ......................... 11 6.5 Rule 5: Know Your Responsibilities Under the Formal Management of

Change Process ....................................................................................................... 12 6.6 Rule 6: Know Your Role in the Control of Work Process ......................................... 13 6.7 Rule 7: Conduct Safe Lifting Operations .................................................................. 14

7.0 CONSEQUENCE MANAGEMENT ...................................................................................... 15 7.1 Consequence Management Process ........................................................................ 15

8.0 REFERENCES .................................................................................................................... 18

LIST OF FIGURES Figure 1 – Life Saving Rules ........................................................................................................... 7

Figure 2 – Life Saving Rules Breach – Consequence Management – Process Flowchart ............. 16

Figure 3 – Chrysaor Life Saving Rules Consequence Matrix ........................................................ 17




1.0 PURPOSE

This Procedure describes the seven Life Saving Rules (LSRs) implemented by Chrysaor. Following these LSRs is mandatory for all personnel (both Chrysaor employees and contractors) entering a Chrysaor site, office or offshore installation.

This Procedure provides a consequence management process, describing the management of an LSR breach for Chrysaor personnel. Should any contractor breach an LSR, they are removed from the Chrysaor site and their employing company informed.

2.0 SCOPE

This Procedure applies to all personnel operating in Chrysaor United Kingdom (UK) and United Kingdom Continental Shelf (UKCS) locations.

3.0 GLOSSARY OF TERMS

3.1 Abbreviations

CoW Control of Work

HIRA Hazard Identification and Risk Assessment HR Human Resources HSEQ Health, Safety, Environment and Quality

JHA Job Hazard Analysis

LSR Life Saving Rule

MAH Major Accident Hazard MEI Major Environmental Incident MoC Management of Change

OGP Oil and Gas Producers OIE Offshore Installation Engineer OIM Offshore Installation Manager OOE Offshore Operations Engineer

PTW Permit to Work

RA Risk Assessment

SC Safety Critical SECE Safety and Environmental Critical Element STL Services Team Lead

TBT Toolbox Talk

UK United Kingdom UKCS United Kingdom Continental Shelf




3.2 Definitions

COMET Chrysaor incident investigation tool. Incident Review Panel A meeting that ensures a thorough and appropriate investigation of an

incident has been completed per criteria, and to determine whether further preventive actions or cross-asset learning is required.

Major Accident Hazards (MAHs)

Physical situations or dangerous substances characterised by their potential to cause loss of life or significant and lasting environmental damage.

4.0 ROLES AND RESPONSIBILITIES

4.1 Chrysaor Personnel

All Chrysaor personnel are responsible for:

• Reading and understanding the LSRs

• Discussing any concerns regarding LSR implementation with their Supervisors

• Adhering to the LSRs at all times

• Reporting LSR breaches identified through supervisory or peer-to-peer intervention to their Line Manager

4.2 Offshore Management Team

The Offshore Management Team hold a supervisory role offshore, supporting and reporting to the Offshore Installation Manager (OIM). They include Offshore Operations Engineer (OOE), Services Team Lead (STL), Shift Supervisor, Offshore Installation Engineer (OIE), Medic and Construction Supervisor. The Offshore Management Team are responsible for:

• Reporting any LSRs to the OIM

• Gathering initial incident information to support the investigation

4.3 Offshore Installation Manager

The OIM is responsible for:

• Ensuring an investigation is initiated for a potential LSR breach

• Ensuring Human Resources (HR) are involved in any potential LSR investigation

• Adhering to the consequence management process, defined in Section 7.0




4.4 Asset Manager

The Asset Manager is responsible for:

• Assigning a Lead Investigator for a potential LSR breach investigation

• Approving any deviations from the requirement to conduct an Incident Review Panel meeting for an LSR breach

4.5 Senior HSEQ Adviser

The Senior Health, Safety, Environment and Quality (HSEQ) Adviser is responsible for:

• Contributing to the potential LSR breach investigation

• Providing COMET support for the investigation

4.6 Human Resources Business Partner

The HR Business Partner is responsible for:

• Ensuring a fair investigation is completed for LSR breaches

• Adhering to the consequence management process, defined in Section 7.0

5.0 INTRODUCTION

5.1 General

Chrysaor has implemented a set of LSRs that set out clear safety expectations for activities with the highest potential safety risks. LSR compliance is mandatory for all Chrysaor staff, including employees, contractors, subcontractors and direct labour workers working for and contractually liable to Chrysaor.

The LSRs, shown in Figure 1, outline safe working practices to be followed. They are laid out to ensure people and equipment are protected during high risk work operations where it has been proven that failure to comply has a high potential for serious injury or death. All Chrysaor staff must adhere to the LSRs.

Along with industry-standard LSRs, focused on personal safety, Chrysaor has also implemented LSRs that relate to process safety hazards and preventing major accidents – low likelihood, high consequence events.

These LSRs ensure there is a balanced focus on both personal and process safety hazards specifically relevant to the oil and gas industry and associated offshore operations. Four of Chrysaor’s LSRs align with the suite of industry rules available in Oil and Gas Producers (OGP) Life-Rules, Report No. 459 [Ref 1].




6.0 LIFE SAVING RULES

The seven LSRs are:

Figure 1 – Life Saving Rules




6.1 Rule 1: Obtain Authorisation before Entering a Confined Space

Explanation

A confined space is a place which is substantially, although not always entirely, enclosed. It is a place where serious injury can occur from hazardous substances or conditions within the space or nearby. Vessels are the most obvious examples of confined spaces. However, confined spaces may also include, e.g. tanks, vats, silos, culverts, ducts, void spaces (roof, under floor, between modules), inadequately ventilated rooms, some excavations, crane pedestals, machinery spaces, valve cellars, wellhead cellars, manholes and large pipework. Refer to Confined Space Entry Procedure, BG-BMS-PROC-OPS-0553 [Ref 2].

All personnel should:

Rule 1.1 Confirm with the Supervisor or the Permit Holder of the work that it is safe to start work.

Rule 1.2 Confirm with the Standby Person that it is permissible to enter a confined space.

Rule 1.3 Follow the requirements of the work permit.

Rule 1.4 Report any non-conformances or deviations to the Supervisor.

Standby Persons should:

Rule 1.5 Approve and control access to a confined space.

Rule 1.6 Have means of communication with people in the confined space.

Supervisors or Permit Holders should:

Rule 1.7 Confirm that the requirements of the work permit are in place.

Rule 1.8 Confirm that a qualified Standby Person is always present when people are in a confined space.

Rule 1.9 Confirm that gas testing is carried out as per the work permit.

Rule 1.10 Confirm that it is safe to start work.




6.2 Rule 2: Protect Yourself Against a Fall when Working at Height

Explanation

Working at height involves all work activities where there is a need to control the risk of falling a distance that could cause personal injury. Collective measures (e.g. guardrails, nets, mats and inflated devices) should be preferred over personal protective measures (e.g. fall arrest equipment). Refer to Working at Height Procedure, CHRY-UKO-HSEQ-PROC-0819 [Ref 3].


Rule 2.1 Have authorisation to work at height outside a protective environment.

Rule 2.2 Be aware of the appropriate fall protection equipment to use for the task, and how to use it.

Rule 2.3 Check the integrity of fall arrest equipment before using it.

Rule 2.4 Always tie off when working at height outside of a protective environment.



Rule 2.6 Confirm that it is safe to start work at height.

Rule 2.7 Ensure personnel working at height are competent to do so.




6.3 Rule 3: Verify Isolation before Work Begins and Use the Specified Life Protecting Equipment

Explanation

It is Chrysaor policy that the highest quality and security of isolation, which is reasonably practicable in the prevailing circumstances, is always used. The minimum isolation standard for entry into a vessel or confined space is positive isolation from all connected sources of process and utilities fluids. If the isolation cannot meet the defined minimum standard, then an isolation Job Hazard Analysis (JHA) must be conducted (per the Control of Work (CoW) process) to justify working to a lower level. This must clearly identify what additional control measures are being applied to reduce the risk to an acceptable level. Refer to Safe Isolation and Reinstatement of Plant Procedure, CHRY-UKO-PRD-PROC-0232 [Ref 4].


Rule 3.1 Understand the isolations that are in place to mitigate danger.

Rule 3.2 Confirm with the Supervisor or Permit Holder of the work that isolations are in place.

Rule 3.3 Confirm with the Supervisor or Permit Holder of the work it is safe to start work.



Rule 3.5 Confirm isolation is in place, e.g. lock switches, separate pipes with spades, or lock access doors.

Rule 3.6 Confirm no stored energy or other dangers remain.





6.4 Rule 4: Know Your Role in Major Accident Prevention, especially Relating to the Observance of Preventative Measures and Report all Near Misses

Explanation

The offshore installation’s Safety Cases identify the MAHs and Major Environmental Incidents (MEIs) which are required to be managed to maintain a safe place of work and prevent serious impact on the natural environment offshore. MAHs are characterised by their potential to cause loss of life or significant and lasting environmental damage. The maintenance of Safety and Environmental Critical Elements (SECEs), equipment and systems are in conjunction with a strong reaction to weak signals fundamental in preventing a major accident event. Refer to Corporate Major Accident Prevention Policy, CHRY-COR-HSEQ-PLCY-0056 [Ref 5].

All personnel working offshore should:

Rule 4.1 Be aware of the MAHs/MEIs and controls relevant to the activity to be carried out.

Rule 4.2 Be aware of their role; either preventing the event occurring, preventing escalation, or dealing with the consequences of an incident. Any person who is unsure of their role should discuss this with their Line Manager.

Rule 4.3 Know where to find the relevant installation Safety Case. Personnel should ask their Supervisor to explain what their role is in regard to the Safety Case.


Rule 4.4 Confirm the workforce are aware of MAHs/MEIs and that those related to their activity are pointed out.

Rule 4.5 Ensure an approved Risk Assessment (RA) is completed and used for the activity.

Rule 4.6 Ensure personnel have the necessary competencies for the work assigned to them.

Rule 4.7 Ensure all MAHs/MEIs potential activities are clearly identified at the planning stage and brought to the OIM’s attention.

OIMs should:

Rule 4.8 Confirm workforce are aware of MAHs/MEIs and controls described within the Safety Case or supporting documentation.

Rule 4.9 Regularly discuss major accident and MEI prevention with the workforce, including Chrysaor and Contractor Safety Representatives, to maintain awareness.

Rule 4.10 Ensure all SECEs are maintained in accordance with the agreed maintenance and test schedule, and that any failure of a safety or environmentally critical system, equipment or process is identified and rectified as a priority.




6.5 Rule 5: Know Your Responsibilities Under the Formal Management of Change Process

Explanation

Work arising from temporary or permanent change to the organisation, personnel, process, systems, procedures, equipment, and products should proceed only when a Management of Change (MoC) process is completed. The MoC process is a systematic approach to identifying areas of impacts and risk assessing these impacts, to provide appropriate mitigations to safely execute the change from an individual and organisational perspective. The MoC process ensures that changes are managed through multi-disciplined, detailed impact and RA considering all phases including execution and handover. Refer to Management of Change Procedure, CHRY-UKO-TAI-PROC-0236 [Ref 6].


Rule 5.1 Utilise the MoC process for all applicable changes.

Rule 5.2 Intervene when a relevant change has not been managed through the MoC process.



Rule 5.4 Ensure the MoC process is applied to relevant changes.

Rule 5.5 Ensure the change proposal has been reviewed by all relevant parties.

Rule 5.6 Ensure no work, which is under MoC, commences without being at the correct state in the MoC process.




6.6 Rule 6: Know Your Role in the Control of Work Process

Explanation

CoW includes three primary elements; Hazard Identification and Risk Assessment (HIRA), Permit to Work (PTW) and Isolation Management. The PTW system is an integral part of the safe system of work, and is a formal recorded process used to control work (other than normal monitoring and control activities of an installation) which is identified as potentially hazardous and which may adversely affect the safety of staff, plant or the environment. A PTW is not simply permission to carry out a hazardous job; it is an essential part of a system which determines how that job can be carried out safely and helps to communicate this to those doing the job. It should not be regarded as an easy way to eliminate hazard or reduce risk. Refer to Control of Work, CHRY-BMS-PROC-OPS-1246 [Ref 7].

All personnel working offshore should:

Rule 6.1 Confirm the work permit is valid.

Rule 6.2 Understand the work permit and adhere to it.

Rule 6.3 Confirm all prerequisite controls are in place prior to starting work.

Rule 6.4 Participate in Toolbox Talk (TBT) and worksite dynamic RA.

Rule 6.5 Obtain authorisation before overriding or disabling Safety Critical (SC) equipment.

Rule 6.6 Work only on the permitted system or location, as specified in the permit.

Rule 6.7 Double-check that the system to be worked on is the correct one.



Rule 6.9 Confirm the work permit is valid.

Rule 6.10 Confirm that a TBT has been completed.


Rule 6.12 Explain how the work permit keeps working conditions safe.

Rule 6.13 Confirm that the signalling and communications methods are agreed and clear.

Rule 6.14 Confirm the adequate level of RA has been completed and authorised.

Rule 6.15 Confirm the Isolation Certificate is signed.

Rule 6.16 Confirm authorisation for overriding or disabling any SC equipment comes from the correct level.

Rule 6.17 Identify SECEs at the worksite.




6.7 Rule 7: Conduct Safe Lifting Operations

Explanation

All lifting operations must be properly planned by a competent person, appropriately supervised and carried out in a safe manner. The required level of planning and RA increases with the complexity of the lifting and hoisting operations, as does the required level of competence for personnel in the supervision and implementation of the lift. It should always be the preferred option for a lift plan to be developed offshore in the first case. Refer to Control and Management of Lifting Equipment and lifting Operations Procedure, CHRY-UKO-TAI-PROC-0238 [Ref 8].

All personnel involved in lifting operations should:

Rule 7.1 Understand the lift plan before starting the work and follow it.

Rule 7.2 Confirm that the load does not exceed the capacity of the lifting equipment.

Rule 7.3 Confirm that the crane is level and positioned on a solid surface.

Rule 7.4 Verify that safety devices on the lifting equipment are installed and operational.

Rule 7.5 Make sure the lift area is controlled (mark the high-risk area and put barriers in place) and the surrounding area is clear of people, should the load swing or fall.

Rule 7.6 Complete a 20 second scan for spatial awareness, just before a lift.



Rule 7.8 Confirm that a general or specific lift plan is in place, depending on the type of lift.

Rule 7.9 Confirm that the Crane Operator understands and complies with the lift plan.

Rule 7.10 Confirm that people who supervise or perform lifting operations, and who inspect and maintain lifting equipment, are trained and competent.

Rule 7.11 Verify that equipment to be used for lifting and hoisting has been inspected, maintained and certified.

Rule 7.12 Confirm that the signalling methods and communications are agreed and clear.




7.0 CONSEQUENCE MANAGEMENT

If an LSR breach is reported, consequence management is applied. The primary aim of consequence management is to keep everyone safe via learning, coaching and/or disciplinary sanctions. To ensure a consistent approach, an LSR consequence management process flowchart has been developed (refer to Figure 2).

The LSR Consequence Matrix, as shown in Figure 3, is at the core of the process flowchart. It considers a combination of LSR intervention types against the accessed rationale for the breach.

The possible outcomes of an LSR investigation, using the LSR Consequence Matrix, align with Grievance Procedure, CHRY-UKO-HR-PROC-0290 [Ref 8]. The possible outcomes are:

• Coaching conversation

• Informal discipline sanction

• Formal disciplinary sanctions (formal written warning or dismissal)

Note: A peer-to-peer LSR intervention initiates the consequence management process.

7.1 Consequence Management Process

The LSR consequence management process is described within the process flowchart depicted in Figure 2.

The key points of note within the process are as follows:

• The outcome of the investigation is determined by the Line Manager and HR

• Once the LSR breach is confirmed, the Consequence Matrix (Figure 3) is applied. This determines the consequence of the breach, which can be either:

− Coaching

− Informal or formal disciplinary sanction

• If a formal disciplinary sanction is decided, this can either result in a written warning or dismissal

• For peer-to-peer intervention, if it is the person’s first offence for a specific LSR, the outcome is a coaching conversation; if it is not their first offence, an informal disciplinary sanction is applied

To ensure consistency, Chrysaor, in conjunction with the contractor’s management, applies its consequence management system to any contractors working onboard the installation.

Refer to Figure 2 and Figure 3 for personnel involved in the process.




Figure 2 – Life Saving Rules Breach – Consequence Management – Process Flowchart




Figure 3 – Chrysaor Life Saving Rules Consequence Matrix




8.0 REFERENCES

Note: The BMS document references below are subject to change. The electronic BMS should be consulted for the most up-to-date revisions.

1. OGP Life-Rules, Report No. 459.

2. Confined Space Entry Procedure, BG-BMS-PROC-OPS-0553.

3. Working at Height Procedure, CHRY-UKO-HSEQ-PROC-0819.

4. Safe Isolation and Reinstatement of Plant Procedure, CHRY-UKO-PRD-PROC-0232.

5. Corporate Major Accident Prevention Policy, CHRY-COR-HSEQ-PLCY-0056.

6. Management of Change Procedure, CHRY-UKO-TAI-PROC-0236.

7. Control of Work, CHRY-BMS-PROC-OPS-1246.

8. Control and Management of Lifting Equipment and Lifting Operations Procedure, CHRY-UKO-TAI-PROC-0238.

9. Grievance Procedure, CHRY-UKO-HR-PROC-0290.

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Life Saving Rules Procedure