Safe isolation of plant and equipment
The Regulator I Issue 3 I October 2021
The safe isolation of plant and equipment is essential to offshore oil and gas operations because it allows various processes to take place, such as cleaning, maintenance, repair, and modification. Failures during isolation and reinstatement of plant and equipment are a significant cause of loss of containment incidents and potential major accident events.
Recently, NOPSEMA took enforcement action against a dutyholder following multiple isolation incidents on a facility resulting in a loss of containment. NOPSEMA determined that the risks associated with conducting intrusive activities at the facility were not being reduced to as low as reasonably practicable and there was a significant risk to the health and safety of persons at the facility.
Operators are reminded of their duty to take all reasonably practicable steps to ensure that any plant, equipment, materials, and substances at the facility are safe and without risk to health.
The most effective way to achieve safe and effective isolation of plant and equipment, without creating unnecessary constraints on plant operation, is good initial design of plant and equipment. NOPSEMA supports the Australian Government’s proposed amendments to the safety regulatory framework that will require proponents to engage with and submit design concept details to NOPSEMA for new production facilities.
Safe isolation also depends on the arrangements within a robust safety management system, including work control systems (especially permit-to-work), operating procedures, training and competence, management of change and contingency plans.
NOPSEMA recommends that operators review their safety management systems in relation to the safe isolation of plant and equipment to identify any gaps with industry good practice, such as described in HSE UK Guidance 'Safe Isolation of Plant and Equipment', HSG253.