Shutdown Safety

During shutdown execution the management must emphasize on achieving the safety goal� It requires a coordinated effort by all stakeholders involved in the shutdown process� While excellent performance is expected throughout plant operations on a day-to-day basis by own employees, additional effort and rigor during shutdowns is required due to increased activity levels and involvement of many contract workers� The shutdown manager must assure that potential physical, mechanical, chemical, and health hazards are recognized and provisions are made for safe operating practices and appropriate protective measures are in place� These measures may include hard hats, safety glasses and goggles, safety shoes, hearing protection, respiratory protection, and protective clothing such as fire-resistant clothing where required� In addition, procedures should be established to assure compliance with applicable regulations and standards�

The shutdown team needs to have experience in plant operations, hazardous materials management (asbestos, lead, polychlorinated biphenyls, mercury, catalyst handling), occupational hygiene, and construction safety to ensure success and prevent incidents from occurring� A pre-assessment of work areas should be completed by the shutdown team during the preplanning stage of the shutdown� The assessment should involve a discussion of work scope and a visual assessment of the work area for potential worker exposure risks� Potential risks need to be flagged and brought to the attention of the shutdown team� A detailed plan then needs to be developed for dealing with the hazards� Occupational health and safety hazards that need to be integrated into the shutdown plan include airborne contaminants (asbestos, fly ash, coal dust, catalyst dusts, welding fumes, refractory ceramic fibers, lead, radiography); personal fall protection:

• Falling objects, eye protection, slipping and tripping hazards, proper storage of gas/air cylinders

• Confined space entry and vessel ventilation

One of the major hazards during shutdown is exposure to hazardous substances, as these are a deviation from routine operations� Plant turnarounds require careful planning, scheduling, and step-by-step procedures to make sure that unanticipated exposures do not occur� Any plant shutdown requires a complete plan in writing to cover all activities, the impact on other

operations, and emergency planning� Plans are normally formulated by plant personnel in conjunction with contractors�

In a refinery, hazardous chemicals can come from many sources and in many forms� In crude oil, there are impurities such as sulfur, vanadium, and arsenic compounds� These components are inherently hazardous to humans, as are the other chemicals added during processing� The main hazards in this process come from possible exposure to the catalysts, hydrofluoric acid or sulfuric acid, and their dusts, by-products, and residues, as well as hydrogen sulfide, carbon monoxide, heat, and noise� Other processes utilize acid catalysts and caustic “washes�” These can lead to hazardous situations, especially in shutdowns where a contractor’s personnel may be exposed to residues or other contaminants� Other hazards include fire, explosion, toxicity, corrosiveness, and asphyxiation� Information on hazardous materials manufactured or stored in a refinery should be supplied by the client’s representative when a work permit is issued� Information is required from refinery personnel and specialized training is required in the necessary procedures and personal protective equipment, including its care and use�

Health and Hygiene Hazards

Table 10�1 reviews common hazardous chemicals and chemical groups typically present and their most significant hazards to workers� Care should be exercised at all times to avoid inhaling solvent vapors, toxic gases, and other

respiratory contaminants� Because of the many hazards from burns and skin contact, most plants require that you wear long-sleeved shirts or coveralls�

Fire and Explosion

Other principal hazards at refineries are fire and explosion� Refineries process a multitude of products with low flash points� Although systems and operating practices are designed to prevent such catastrophes, they can occur� Constant monitoring is therefore required� Safeguards include warning systems, emergency procedures, and permit systems for any kind of hot or other potentially dangerous work� These requirements must be understood and followed by all workers� The use of matches, lighters, cigarettes, and other smoking material is generally banned in the plant except in specially designated areas�

Confined Spaces

On most jobsites, there are potential confined space hazards� These hazards are multiplied, however, on a refinery site because of the complex collection of tanks, reactors, vessels, and ducts combined with a wide variety of hazardous chemicals and emissions, often in enclosed areas� Many of these chemicals can produce oxygen-deficient, toxic, or explosive atmospheres� Knowledge of general confined space procedures and specific in-plant requirements is critical in refinery work�

Confined Space Entry and Vessel Ventilation

Confined space work during shutdowns can be associated with refractory removal and replacement, chemical cleaning, catalyst handling, welding/ gouging, and coating applications to name a few� In these “closed-in” environments, there is usually an increased potential for worker exposure� Attention needs to be given to heat stress, personal protective equipment and ventilation requirements� All personnel entering into a confined space must have specialized training�

Vessel ventilation is critical prior to workers entering into the confined space� The key reasons vessels are ventilated are to purge the vessels of process contaminants such as hydrocarbons, inert gases, and steam; for comfort ventilation; for heat stress control; and to control generated contaminants� The success of ventilation is verified by gas testing prior to entry� Gas testing typically includes testing for lower explosive levels, oxygen percentage, toxics such as hydrogen sulfide (H2S), and carbon monoxide (CO)�

Airborne Contaminants

In dealing with airborne contaminants, the shutdown team’s goals are to control risk of worker exposure to airborne fiber; to control risk of airborne fiber release into the plant environment; and to identify improvements to programs�

Personal Fall Protection

Workers exposed to falls need to meet the minimum requirements of provincial/local occupational health and safety (OH&S) regulations� If handrails or floor gratings are removed to facilitate work, workers must use approved fall restraint or fall arrest equipment� Other workers must be protected by either temporary scaffold guardrails or a flagged/ribboned area a minimum of 6 ft from the fall hazard� The flagged area should not be left unattended for long periods of time�

Falling Objects

Job tasks that pose a risk of falling objects should be flagged off� A plant procedure should be developed and understood for flagging and ribboning� Past experiences show near-miss incidents occur with falling objects include hoisting materials and equipment; storage of tools and material laid down inside the toe boarded area of a scaffold or work platform; passing of materials or equipment from hand to hand outside the bounds of the handrails and toe boards, work platforms, and scaffolds�

Eye Protection

Safety goggles are required during work tasks that involve grinding, buffing, and all cut and saw operations�

Slip and Trip Hazards

Slipping and tripping hazards are common during shutdowns, and can be minimized by ensuring contractors implement proper housekeeping procedures� Wet materials such as oil, wet ash, and water should be cleaned up immediately or flagged off as slip hazards�

Areas used for lay-down equipment must be arranged to prevent tripping hazards in common walkways� Hoses, cords, and air lines must be arranged to prevent tripping hazards in walkways� Scaffold support piping and hoist support piping (typically used for hoists at floor levels) should be flagged and ribboned for visibility�

Proper Storage of Gas/Air Cylinders

All air and gas cylinders should have the main valves closed before workers leave their areas for all breaks� Regulators should be removed and

safety caps installed at the end of each work shift� All cylinders should be securely stored at all times�

The participation of owners in safety starts at the very beginning and lasts till the end� Owner involvement in safety planning includes selecting safe contractors, addressing safety in design, including safety requirement in the execution, and being actively involved in the shutdown safety management�

Owners must make a group responsible for planning, developing, organizing, implementing, and auditing of a safety system for the shutdown job� They must develop a structure to assure implementation of the commitment to safety and health at work by own employees and contract workers� Owners must ensure

• In-house safety rules are in place to provide instructions for achieving safety management objectives�

• Training is imparted to equip personnel with knowledge to work safely and without risk to health�

• Evaluation of job-related hazards or potential hazards and development of safety procedures are done well ahead of execution�

• Promotion of safety and health awareness at the workplace� • Evaluation, selection, and control of contractors and subcontractors

to ensure that they are fully aware of their safety obligations and are in fact meeting them�

• Emergency preparedness to develop, communicate, and execute plans prescribing the effective management of emergency situations�

An important aspect of preplanning is to integrate occupational health and safety into the overall shutdown plan� Ownership needs to be created by the shutdown team, which will involve key stakeholders, SHE professionals, and contractors� Unique hazards occur during shutdowns that sometimes are not well understood by plant personnel� It is therefore important during the preplanning stages that a clear work scope is prepared and a plan is put into place to manage all safety and occupational hazards�

To bring increased focus on occupational health and safety during shutdowns, it is required to document safe work plans and hazard assessments

for all work scope� A list of safety responsibilities for managing safety and health by everyone involved in the work activity should be followed� A list of risks and the risk assessment results, including the contingency plans for foreseeable emergencies should be noted� The procedures for monitoring and assessing the implementation of these actions should be carried out� Occupational health and safety budgets and resources need to be considered for collection and analysis of hazards such as asbestos, lead, refractory, silica, welding, and off-gassing materials� Specialized instruments such as photoionization detectors, H2S detectors, are excellent for quick detection� But sometimes are expensive and not easy to obtain�

Evaluation and Selection Strategy

The evaluation and selection strategy should clearly aim at ensuring that contractors and subcontractors with knowledge of good safety standards and a good record of putting them into practice would be selected for the work� A practicable approach to evaluate and select suitable contractors and subcontractors is set out below:

1� Each contractor and subcontractor wishing to qualify as a bidder should be asked to provide a safety policy, which would be vetted to assess its adequacy�

2� The contractor and subcontractor should also be required to submit the safety organization and details of responsibility, track records in safety, working experience with clients of high safety standards, safe systems of work/safety programs in place, current safety management system, and training standards� These should also be vetted to assess adequacy�

Pre-bid briefing should be provided to all qualified bidders� They should be invited in writing to attend the briefing and their attendance should be recorded� Provisions in the contract, as well as the local safety laws that apply, should be clearly communicated to bidders in the briefing�

Bidders should identify all of the safety and health hazards within the specifications� To help them do this, a checklist on all the common safety and health problems, which may arise during the work should be provided/communicated to them in the specifications before the bid is made�

• The bids submitted by the potential subcontractors should be checked against the potential safety and health problems to ensure that all the safety and health hazards that may arise during the work have been clearly identified by them and that proper provisions have been made for the control of the risks assessed� Each potential subcontractor should also be required to submit an outline safety plan

for the implementation of the risk control measures� The outline safety plan should be set out in summary from the subcontractor’s proposed means of complying with his or her obligations in relation to safety and health at work�

• The contract should go to the subcontractor who is able to identify all the safety and health hazards that may arise during the work, can assure that the most proper and adequate provisions have been made for the control of the risks, and has the best outline safety plan compared to other bidders�

The contractor should provide all safety and personal protective equipment (PPE) required to complete the contracted scope of work�

The contractor should ensure that the supervisor on site is well trained on environment, health, and safety activities and regulations in the performance of the work�

Safe Work Practices and Procedures

Site Access and Use

All sites must have controlled access to limit unauthorized individuals from entering the construction area�

Cleanup

The contractor shall keep the work area, specifically walking and working surfaces, clean and free from debris and trash, which could cause slipping and tripping hazards� Tools, materials, dirt, lumber, concrete, metal, insulation, paper, etc� should be promptly cleared and disposed of by the contractor� All debris should be disposed of each day off the campus or in a contractor-supplied dumpster�

General Safety

• Hearing protection and safety glasses must be worn in all operating areas or as posted�

• Respiratory protection or equipment must be fit-tested� Facial hair is unacceptable where the mask must make an airtight seal against the face�

• Shirts must be long-sleeved and worn with full-length pants or coveralls�

• Clothing must not be of a flammable type such as nylon, Dacron, acrylic, or blends� Fire-resistant types include cotton, Nomex, and Proban�

• Other PPE required may include acid hood, impervious outerwear, rubber boots, face shields, rubber gloves, disposable coveralls, monogoggles, and fall-arrest equipment�

• Smoking is allowed only in designated areas� • Vehicle entry is by permit only� • Vehicles must be shut down at the sound of any emergency alarm�

Evaluation of Job-Related Hazards

This refers to carrying out hazard analysis for jobs� The objective of hazard analysis should be to provide a means whereby job hazards or potential hazards are identified, evaluated, and managed in a way that eliminates or reduces them to an acceptable level� Safe working procedures and safety precautions that are to be taken to prevent the hazards and to control the risks should be developed after the hazard analysis�

Hazard identification is the process of identifying all situations or events that could give rise to the potential for injury, illness, or damage to plant or property� Hazard identification should take into account how things are being done, where they are done, and who is doing them, and should also consider how many people are exposed to each hazard identified and for how long�

The following should be accorded top priority in the hazard identification process:

• High frequency of accidents or near misses Jobs or works with a high frequency of accidents or near misses pose a significant threat to the safety and health of employees at work�

• History of serious accidents causing fatalities Jobs or works that have already produced fatalities, disabling injuries or illnesses, regardless of the frequency, should have a high priority in the hazard identification process�

• Existence of a potential for serious harm Jobs or works that have the potential to cause serious injury or harm should be analyzed by the hazard identification process, even if they have never produced an injury or illness�

• Introduction of new jobs or work Whenever a new job or work is introduced, a hazard identification process should be conducted before any employee is assigned to it�

• Recent changes in procedures, standards, or legislation Jobs or work that have undergone a change in procedure, equipment, or materials, and jobs or work whose operation may have been affected by new regulations or standards should require the carrying out of hazard identification process�

PPE

In the hierarchy of control measures, PPE should always be regarded as the “last resort” to protect against risks to safety and health� Engineering

controls and safe systems of work should always be considered first� It may be possible to do the job by another method, which will not require the use of PPE or, if that is not possible, to adopt other more effective safeguards�

However, in some circumstances, PPE will still be needed to control the risk adequately�

PPE includes the following, when they are worn for protection of safety and health:

1� Protective clothing such as aprons, protective clothing for adverse weather conditions, gloves, safety footwear, safety helmets, highvisibility waistcoats, etc�

2� Protective equipment such as eye protectors, hearing protectors, life jackets, respirators, breathing apparatus including those used underwater, and safety harness

The shutdown manager and the contractors should ensure that appropriate PPE and training for its usage is provided to the workers�

1� Conducting PPE risk assessment: If it is necessary to provide PPE, an enterprise should conduct an assessment� The purpose of the assessment is to ensure the correct PPE is chosen for the particular risk� Except in the simplest and most obvious cases that can be repeated and explained at any time, the assessment will need to be recorded and kept readily accessible by those who need to know the results�

2� Proper selection of PPE: The proprietor or contractor of an enterprise should determine what type of PPE is required, taking into consideration the legal requirements for specific situations, the intended use of the PPE, the manufacturer’s product standards, the ergonomics of the design of the PPE, acceptability of the PPE to its wearer and user, and, if used in conjunction with other PPE, compatibility with the PPE in question, etc�

3� Steps to ensure adequate supply of PPE, including replacement supply and spare parts�

4� Steps to ensure adequate training, information, and instruction to workers on the safe and proper use and maintenance of PPE�

Permit Requirement

No work takes place in a refinery and process plant without a safe work permit� A safe work permit is a document issued by an authorized representative of the client permitting specific work for a specific time in a specific area� Work permits should indicate the date and time of issue, the time of expiry, a description of the work to be done, and the name of the company performing the work� Permits also specify any possible hazards and any protective

equipment needed for the job� The permit will advise you on any steps required to make the area or equipment safe for work, tell you the results of any gas tests, advise you on any electrical lockouts that have been done, and tell you about any work practices required for the specific job� Safe work permits are valid only for a limited time and must be renewed following expiry� Normally during a shutdown, short-term permits are issued rather than ongoing permits� This means the contractors and line supervisors must check daily or more frequently to ensure that hazardous activities are coordinated well and remedial actions are taken� After an emergency event, any required gas testing or other testing must be repeated to ensure a safe return to the work�

Owners must make a group responsible for planning, developing, organizing, implementing, and auditing of a safety system for the shutdown job� They must develop a structure to assure implementation of the commitment to safety and health at work by own employees and contract workers�

The types of safe work permits required typically include the following; specific categories may vary from site to site:

• Hot work-covers any work that involves heat or an ignition source, including welding, grinding, and the use of any kind of motor� In high-risk areas, a spark watch may be required�

• X-ray and radiation� • Confined space entry hot work-involving potential ignition hazards� • Confined space entry cold work-involving work that will not pro-

duce a spark� • Hoisting-permit� • Electrical-for other than routine work� • Camera-typically requires a hot work permit when lighting is

required� • Vehicle movement� • Excavation�

Training

Oil refinery workplace safety also involves extensive training of workers in safety standards� Workers are educated on processes that are designed to prevent potential disasters� Creating a safe workplace through regulations and safety procedures can reduce accidents and injuries�

Executing

1� Provide adequate and appropriate resources to implement safety� 2� Place occupational safety and health as one of the prime responsi-

bilities of line management, from the most senior executive to the first-line supervisory level�

3� Ensure that employees at all levels receive appropriate training and are competent to carry out their duties and responsibilities�

4� Provide adequate and effective supervision to ensure that the policies and the plans are effectively implemented�

5� Determine and execute plans to control the risks identified� 6� Arrange safety audits and periodic status analysis as an indepen-

dent check to the efficiency, effectiveness, and reliability of the safety management system, and carry out the required corrective actions�

7� Motivate all employees by a combination of rewards and sanctions and stress on the reinforcement of the positive behavior contributing to risk control and the promotion of a positive safety culture�

Facilities

The following site facilities are required during the execution phase�

Washing facilities: Adequate and suitable facilities for washing should be provided for the use of the persons employed for the construction work�

Toilets: Suitable and sufficient conveniences are to be provided for the exclusive use of the males engaged or employed in or around the place of work, and for the exclusive use of the females employed in or around the place of work�

Where there are more than 15 employees, the minimum requirements are

• One urinal where 15 males are employed, plus one urinal for each 30 males or part thereof

• One water closet where 15 or less employees are employed, plus closets for each of the 30 employees or part thereof

Where females are engaged or employed, there should be suitable provision for the disposal of sanitary towels�

Drinking water: An adequate supply of wholesome drinking water should be provided to all persons on the construction work in accordance with the following conditions:

• It should be readily accessible to all persons engaged in the work and clearly labeled as drinking water�

First aid facilities: Every employer is required to provide adequate first aid facilities, appliances, and requisites� Normally, first aid is to prevent the condition of the injured person from becoming worse until more skilled help becomes available�

Lighting: Poor light can be a major contributor to accidents, and employers must ensure that adequate lighting is provided� Lighting should be provided over the entire place of work�

Housekeeping (general): Confusion will be reduced and operations will be more efficient when the work area is orderly and tidy� Tidiness and safety go hand in hand� Untidiness causes accidents-for example, employees trip over objects, slide on greasy surfaces, cut hands on shutdowning nails, or walk into poorly stacked materials, or vehicles run over or back into materials, plant, or employees�

All rubbish around machinery, plant, accessways, stairwells, site facilities, and the site in general should be regularly gathered and disposed of in suitable bins�

Where rubbish is burned on site, this should be done in a suitable incinerator well away from flammable material� Appropriate permits may need to be obtained to burn rubbish on site�

Safe access: Employers should ensure that

• All employees are able to reach their place of work safely� • There are safe roads, gangways, passageways, ladders, and scaffolds� • All walkways are level and free from obstructions� • Materials are stored safely� • Holes are securely fenced or covered and clearly marked� • Chutes are available to avoid waste being thrown down in the open� • Nails in reused timber are removed or hammered down� • There is adequate lighting provided for the work • Temporary props and shoring are in place to support temporary

work as necessary

Working at Heights over 3 m: The first and essential step in ensuring that work is done safely is to ensure that it is practicable for the work to be carried out safely�

Safe work practices may include one or more of the following:

• Guarding • Safety nets • Fall arrest systems

Guardrails/toeboards: A toeboard must be installed where there is a risk of tools or materials falling from the roof/place of work�

Safety nets: Safety nets can provide a satisfactory means of protection against falling, while allowing workers maximum flexibility of movement�

Fall-arrest systems: Individual fall-arrest systems include inertia reel systems, safety harnesses, lanyards, and static lines� People required to use this equipment must be trained in its use�

Scaffolding: It is important that a competent person inspect all scaffolding:

• Before it is used • At least weekly while it is in use

• After bad weather or any other occurrence that could affect its stability • After periods where the scaffold has not been used for some time

The person carrying out such inspections should ensure the following requirements are met:

• There is proper access to the scaffold platform� • All uprights are properly founded and provided with base plates�

Where necessary, there should be timber sole plates, or some other means used to prevent slipping and/or sinking�

• The scaffold is adequately braced to ensure stability� • Load-bearing fittings are used where required� • Uprights, ledgers, braces, or struts have not been removed� • Working platforms are fully planked, with the planks free from

obvious defects such as knots and arranged to avoid tipping and tripping�

• All planks are securely restrained against movement� • There are adequate guardrails and toeboards at every side from

which a person could fall�

Electrical supply: Electricity is almost universally used on construction sites as a power source for a range of machinery and portable tools� In addition, lighting and heating are in wide use on construction sites�

Temporary supply switchboards: All supply switchboards used on building and construction sites should be of substantial construction and should

• Where installed in outdoor locations, be so constructed that safe operation is not impaired by the weather

• Incorporate a stand for the support of cables and flexible extension cords

• Be provided with a door and locking facility acceptable to the electrical supply authority

Safe use of chemicals: Many different chemicals and hazardous substances are used in construction work� It is essential that effective control measures and policies are developed and implemented to ensure that the chemicals or substances are used safely�

These measures should include policy on

• Safe handling of chemicals or hazardous substances • Correct storage procedures to be adopted • Safe transportation procedures • Safe disposal procedures

The safe handling of chemicals should be aimed at eliminating or minimizing risk to employees or others, and will involve reading labels and material safety data sheets (MSDS) and complying with instructions�

All chemicals should be stored in their original containers in a safe, wellventilated, secure place and in accordance with directions on their labels and MSDS�

If chemicals are transported, regulatory requirements should be observed in respect to documentation, compatibilities, and load security�

All employees should be trained in the correct practices to be followed when using chemicals and hazardous substances, and in how to deal with emergencies that may arise while using any substance�

Cranes and lifting appliances: Cranes and other lifting appliances are valuable assets on construction sites� It is important, however, to pay regular attention to certain aspects of their operation� Employers and employees using cranes and lifting appliances should ensure that

• Cranes are inspected weekly, and thoroughly examined every 12 months by a competent person� The results of inspections should be recorded�

• There is a current test certificate� • The driver is trained, competent, and over 18 years of age� • The controls (levers, handles, switches, etc�) are clearly marked� • The driver and dogman determine the weight of every load before

lifting� • Every jib crane with a capacity of more than 1 ton has an efficient

automatic safe load indicator that is inspected weekly� • A hydraulic excavator being used as a crane has the maximum safe

load clearly marked and hydraulic check valves fitted where required� • The crane is on a firm level base� • There is enough space for safe operation� • The dogman has been trained to give signals and to attach loads cor-

rectly and knows the lifting limitations of the crane� • If it can vary its operating radius, the crane is clearly marked with its

safe working loads and corresponding radii� • The crane is regularly and thoroughly maintained� • The lifting gear is in good condition and has been thoroughly examined�

Confined spaces: Confined spaces are not limited to closed tanks with restricted means of entry and exit�

Also included are open manholes, trenches, pipes, flues, ducts, ceiling voids, enclosed rooms such as basements, and other places where there is inadequate ventilation and/or the air is either contaminated or oxygen-deficient�

Before entry into any confined space, it should be tested to determine that there are adequate levels of oxygen present, and that dangerous amounts of flammable and/or poisonous gases are not present�

No one is to enter any space if testing shows that the air is dangerous inside� Forced ventilation should be used to remove or dilute the gases and supply fresh air� The air should be tested again prior to entering, and monitoring continued while work is being conducted inside the space�

Among the confined spaces that may be inherently hazardous are

• Manholes, tunnels, trenches set in chalk soil, which can partly fill with carbon dioxide gas, displacing breathable air

• Poisonous or flammable gases can collect in manholes in contaminated ground (e�g�, near underground petrol tanks or refuse tips)

• In manholes, pits, or trenches connected to sewers, there can be a buildup of flammable and/or poisonous gases and/or insufficient oxygen in the air

• Sludges and other residues in tanks or pits, if disturbed, may partially fill the confined space with dangerous gases

Precautions

If work in a confined space could be potentially dangerous, entry should be strictly controlled and detailed precautions taken�

Preferably, employers should adopt an entry permit system, so as to ensure that employees and others are aware of the location of anyone required to enter confined spaces� As mentioned earlier, tests may be required to identify any dangerous amounts of flammable or poisonous gases�

Where the confined space itself may be dangerous (regardless of the work carried out):

• People who are required to work in or enter the space should receive training and instruction in the precautions to be taken inside the area�

• At least one person should be stationed outside the space to keep watch and communicate with anyone inside�

• Rescue harnesses should be worn by all those inside the confined space, with a lifeline attached to the harness and a suitable winching mechanism at or near the point of entry�

• Rescue procedures should be included in the training of workers� Reliance should never be placed on one person alone to lift injured or unconscious people out of a confined space during rescue, unless they are equipped with special lifting appliances� Rescue equipment, including emergency breathing apparatus, should be available near the entrance at all times�

• No attempt should ever be made to clear fumes or gases with pure oxygen�

• Appropriate respiratory protection shall be provided where the results of monitoring assessment indicate that a safe atmosphere cannot be established�

Electrical Precautions

• Electrical tagging and lockout procedures must be understood and followed by all workers�

• All electric tools, cords, and equipment must be grounded or double-insulated�

• Use explosion-proof fixtures where required�

Sewers

• Sewers must be covered when hot work is being done in the vicinity� • Sewer covers must be in good condition with no openings for vapor

flow� • Sewer covers are to be removed when hot work is discontinued at

the end of the job or overnight to accommodate drainage�

Blinding or Blanking-Off

• Piping connected to a work area from vessels, pumps, and other sources is isolated or blinded with a solid plate prior to the start of work�

• Blanking can sometimes be done with two valves and a bleeder valve between them� In this case, the valves should be closed, chained, locked, and tagged�

Control Strategy

The control strategy should aim at monitoring the safety performance of the subcontractor and keeping him or her on the right track with regard to the achievement of the client’s safety and health objectives during the execution of the contract� A practicable control approach should include the following:

1� Special terms and conditions in the contract: All safety rules and provisions should be set down in detail in the contract for the contractor to follow and implement� One of these provisions should be that the subcontractor agrees to abide by all the provisions of the client’s safety policy, which may affect his or her employees’ work,

including compliance with workplace safety rules� In case the contractor further subcontracts all or part of his or her work to other subcontractors, the contractor should ensure that the subcontractors are fully aware of the safety policy and safety rules of the owner�

The following special conditions should therefore be attached to the contract for the contractor to undertake: to inform any subcontractor of all safety requirements; to incorporate observance of all safety requirements as a requirement of any future subcontract; to require the sub-subcontractor to do similarly if he or she in turn subcontracts any work� Another provision in the contract should be that the subcontractor is required to submit a detailed and comprehensive safety plan based on the outline safety plan, indicating how he or she and the subcontractors (if any) are going to implement the safety measures for risk control during the work� The safety plan should include detailed policies, procedures, rules, safety obligations, and responsibilities of the contractor which, when being implemented, should ensure compliance with all safety rules set out in detail in the contract� The subcontractor should adhere to the safety plan in carrying out his or her obligations under the contract and should ensure that his or her own subcontractors of any tier (if any) receive copies of the safety plan and comply with its requirements as well�

2� Risk assessment by the subcontractor before the commencement of the work: The subcontractor should be requested to conduct a risk assessment before the work commences and recommend a safe system of work for the work� The safe system of work should include safety precautions, work methods, tools and equipment to be used, and how the subcontractor organizes his work to reduce risks to employees’ safety and health� The subcontractor will be required to submit the risk assessment report together with the organization chart and expected workforce, list of the subcontractors and their key personnel, safe working procedures, list of tools and equipment, and the preventive maintenance schedule, etc�

3� Control of subcontractor on site: The following are some of the approaches for controlling the safety performance of a subcontractor on site� The contractor will be required to appoint/nominate a person or a team to coordinate all aspects of the contract, including safety and health matters on site� In addition, the contractor should develop communication paths to pass on all relevant safety information to those in the shop floor level� The contractor will be required to attend a pre-contract commencement meeting with the client to review all safety aspects of the work� The proprietor or contractor should carry out regular safety inspections daily to check on a contractor’s activities� The contractor will be required to provide written method statements in advance of undertaking any special work such as demolition, confined space

work, working with asbestos, work on energized electrical installations, erection of false work or temporary support structures, erection of steel, and any work that involves disruption or alteration to main services or other facilities of the client’s activities� The contractor will be required to report to the client all lost time, accidents and dangerous occurrences, including those of subcontractors� All employees of the contractor should be properly and effectively trained in safety and health matters in connection with the job requirement�

Monitoring/Auditing

To carry out the proactive monitoring of performance by, for example, surveillance and inspections of both hardware (i�e�, premises, plant, and substances) and software (i�e�, people, procedures, and systems of work), and monitor the degree of compliance with the safety and health arrangements of the enterprise�

A safety auditor should be appointed to periodically conduct a safety audit� Immediate causes of deficiency should be determined for the substandard

performance and the underlying causes identified� Necessary actions should be taken on the safety audit report submitted,

including drawing up a plan for improvements to the safety management system and implementation of the plan�

How a safety system can be enforced properly The written safety program is the backbone of any company safety policy� A for-

mal written program covering the regulations that apply to your specific job should be framed� A compact field manual is also to be provided for distribution to the field personnel� The manual is designed in a notebook format to make it easy to update the program� It should include

1� Toolbox talks 2� Hazardous communication 3� Safety checklists 4� Fleet policy 5� Substance abuse policy 6� Emergency procedures 7� Respiratory protection 8� Disciplinary action plans

Promotion of Safety and Health Awareness in the Workplace

• Evaluation of job-related hazards or potential hazards and development of safety procedures�

• Training to equip personnel with knowledge to work safely�

• In-house safety rules to provide instruction for achieving safety management objectives�

• A program to identify hazardous exposure or the risk of such exposure to the workers and to provide suitable PPE as a last resort where engineering control methods are not feasible�

Safety Department

A safety department or similar setup should be established to coordinate the implementation of safety plans or programs by the line management� Its primary role is to advise the line management on safety and health practices, requirements, and standards� It should not play a “line” and certainly should not be held accountable for the consequences of the lack of control on the shop floor or at the site�

The safety office or safety department should have the following main roles:

1� To serve as a resource person and in-house safety consultant� 2� To plan and prepare safety programs� 3� To advise top management and line management on safety and

health matters� 4� To coordinate the implementation of safety plans and programs� 5� To monitor compliance and implementation of safety plans and

programs� 6� To track corrective actions and verify the effectiveness of safety

matters� 7� To serve as a trainer in safety matters�

Line management (including managers and supervisors) has the following responsibilities�

• To assist in the implementation of policies and procedures� • To assist in the identification, assessment, and elimination of haz-

ards and the control of risks� • To supervise employees to ensure safe and correct working procedures� • To ensure that effective consultation on safety and health matters

occurs� • To investigate accidents and incidents at work� • To participate in induction and ongoing safety training programs

for employees� • To respond to safety initiatives of safety adviser/safety officer, safety

supervisor, or other employees and to the safety advice from government officers�

• To communicate effectively the hazards to employees and keep abreast of current safety and health legislation and information�

• To submit periodically to senior management statistics and reports concerning safety and health performance�

Safety adviser: A safety adviser should have the responsibility to assist the top management and senior management in promoting the safety and health of employees in the enterprise� His main duties should include the following:

• To identify and assess the hazards at work� • To work with senior management or line management to elimi-

nate or control these hazards by advising them regarding measures to be taken, and, with their endorsement, implement such measures�

• To resolve shop floor safety and health issues� • To conduct safety and health inspections to check the safety perfor-

mance and recommend corrective action to senior management or line management�

• To investigate industrial accidents and incidents and recommend remedial measures to prevent recurrence�

• To be well informed about workplace safety performance� • To consult with senior management, line management, and employ-

ees about changes in the workplace which would likely affect the safety and health of employees at work�

• To report regularly to the top management and senior management about the safety and health performance in the enterprise�

Identifying training needs: To equip his or her workers with knowledge on work safety and health, the proprietor or contractor of an enterprise must first identify what their safety and health training needs are� These needs are best established as part of an overall training needs analysis� For existing jobs, he or she can do the following:

1� Consult job-specific accident, ill-health, and incident records to see what caused loss of control and how it can be prevented�

2� Gather information from employees about how the work is done� 3� Observe and question workers when they are working, to under-

stand what they are doing and why� This may be particularly relevant in complex process plants where any analysis has to take account of all the possible consequences of human error�

4� Consult risk assessment for the work�

Emergency preparedness: Emergency preparedness is vital because, when an emergency does occur, a quick and correct response is necessary to reduce injuries, illnesses, property damage, environmental harm, and public concern�

Emergency planning: A list of potential emergency situations such as fire, electric shock, flood, explosion, hazardous chemical spills or releases, internal/ external leaks of explosive or flammable gas, personal injuries and illnesses, natural disasters, electrical outage, and critical damages to facility/equipment should be drawn up, with priority�

In oil refineries, there will be both plant alarms or whistles and individual unit alarms� All workers must receive training in recognizing and responding to these alarms� Verbal messages usually accompany the alarms� There will be different alarms for a fire emergency and toxic emergency�

• When an alarm sounds, secure all equipment and shut down all vehicles�

• Note the wind direction (wind socks) and proceed to the appropriate assembly area (or safe haven)�

• Do a head count to make sure all personnel are accounted for and report the result to a client contact person�

• Know the local designated safety areas or safe havens and emergency phone number(s)�

• Proceed to the assembly area�

Safety Promotion Program

The objective of safety promotion is to develop and maintain awareness among all personnel, of the organization’s commitment to safety and health, and of the individual employee’s responsibility to support that commitment� Safety promotion programs should be developed and maintained by the proprietor or contractor of an enterprise in order to put into practice the promotion of safety� The plant management or contractor should, as part of a safety promotion program, develop a procedure to recognize and acknowledge good safety performance by individuals, teams, sections, departments, or the organization�

Safety Promotion Approaches

Promotion of Safety in Meetings

A meeting can provide a good opportunity for promoting safety� Meetings suitable for promoting safety include orientation meetings for newcomers, training meetings, problem-solving meetings such as quality management meetings, information meetings such as toolbox meetings, and regular safety meetings� Safety and health films/videos of relevant subjects should be selected and screened for the benefit of those in the meetings and time should be allowed for the discussion of the subject after the viewing�

Promotion of Safety in Print

1� Safety handbooks and brochures: Up-to-date safety handbooks and brochures should be issued to increase safety awareness and as part of the safety training for staff�

2� Safety bulletins and newsletters: Safety bulletins and newsletters should be published by the enterprise to promote safety� They should contain interesting articles including how critical jobs executed in shutdown, pictorial presentations of safety rules, safety procedures and safe systems of work, a staff suggestion scheme, to encourage readership�

3� Safety notice boards: The boards should be used to post safety policy, rules, news, suggestions, accident reports, accident reporting procedures, emergency procedures, circulars, memos, notice of safety video shows and drills, etc�

4� Safety billboards: Vital statistics (such as up-to-date safety performance statistics of the enterprise and the individual work site including up-to-date accident-free days, no-loss days, or number of accidents) should be posted at the main entrance to the workplace or a conspicuous position within the workplace (such as the site office entrance)�

5� Safety posters: Safety posters should be posted at strategic locations in the workplace (such as the main entrance and the production line)� They should be weatherproof, relevant, up-to-date, clear, and attractive�

6� Promotion of safety with awards and recognition: The purpose of safety awards is to recognize and promote safe work practices and reinforce positive attitudes toward safety� An award does not have to be large but it should be meaningful and appropriate for the occasion and the employee or a group of employees�