HSE DIRECTIVE 3 WORKING AT HEIGHTS

WORK AT HEIGHTS HSE DIRECTIVE 3 WORKING AT HEIGHTS Directive owner per 01.01.2014 Bjarte Skulstad Please consult the asset s HSE instructions for potential installation specific requirements

1 GENERAL Purpose The purpose of this directive is to ensure that all work at heights is carried out safely there are no accidents due to dropped objects all use of ladders takes place in a safe manner all scaffolding is erected, taken down and used safely work above the sea is carried out safely Domain This directive applies to all BP-operated installations and contracted installations on the Norwegian continental shelf. Contracted mobile installations which have a system that satisfies the requirements in this directive, may use their own system provided this has been clarified upon implementation. By following this directive, all requirements in the Working at Heights section in the BP 8 Golden Rules of Safety are complied with. Onshore facilities or projects where BP Norge have a particular responsibility and which are assessed being part of the petroleum activities References Regulations relating to scaffolding, ladders and work on roofs, etc. Regulation relating to use of work equipment The Norwegian Labour Inspection Authority s regulations OMS Procedure 4.5 Control of Work OMS Risk 3.2 Personal Safety Norwegian Oil and Gas Association guideline 088 Common model for work permits NS-EN 795 Protection against fall from heights. Anchoring methodes. HSE Directive no. 1 Work permits HSE Directive no. 11 Safe job analysis Use of Work Basket - ref. HSE Directive 4 Lifting Operations Norwegian Oil and Gas Association guideline 113 - Securing and rescue when working in heights (only in Norwegian) Norwegian Oil and Gas Guidelines 105 Scaffolding (including competence requirements) Norsk Standard NS 9600-1, 2, 3, 4 Definitions and abbreviations Working at heights means all work carried out standing with one s feet two metres or more above deck level where there is no fixed platform or approved scaffolding Work permit is a written permit to carry out a defined work task at a given place onboard an installation under given conditions and in a safe manner Safe Job Analysis (SJA) is a systematic and step-bystep review of all elements of risk carried out prior to a 101

» specific task or operation so that measures can be taken to remove or control any elements of risk identified during the preparation for or performance of the said task or operation First line MOB (Man overboard) preparedness includes oothe platform s MOB crew standing by in case of an emergency or ooa standby vessel ready by the installation 2 WORKING AT HEIGHTS Competence for using fall arrest equipment Complete BP fall arrest course offshore (4 hour in house training for fall protection) or onshore basic fall protection safety courses For both courses the BP requiremet is 3 yearly verification/ repetition Use of safety devices all work carried out standing with one s feet 2 metres or more above the deck requires: oofixed platform with handrail, or ooscaffolding with green scafftag, or oouse of approved safety harness secured in a suitable anchor point which limits free fall to 2 metres from the footing, normally by use of a fall block, and oofilled in and signed Checklist for Work At Heights/Use of Harness. When moving at height outside a fixed platform, scaffolding or ladder an approved safety harness with fallblock (or, alternatively, a Y-line) shall be used. When relocating the fallblock, the person involved must be secured with a fall arrest line. When using fall arrest equipment ooat least one person shall be present in the area nearby at all times in order to alert and start basic rescue work in case of a fall ooif needed prepare a written Rescue Plan oothe rescue plan shall take the time for a safe rescue into consideration in order to be able to rescue a person within sufficient time (i.e. prevent blood circulation injuries). There shall be a site specific instruction on how required competent personnel are organized (for instance a rescue team) Securing underlaying area Tools and equipment shall, as far as practical, b e secured with suitable means to prevent them from being dropped If there is a potential for dropped objects the underlaying area shall be secured either with a guard person or roped off in co-ooperation with the area technician. 102

If dropped objects can damage pressurised equipment, the area shall be physically protected or de-pressurised in cooperation with the area techncian. Upon completion of work the area shall be checked to secure that no potential dropped objects are left. Inspection of fall arrest harness The user shall always visually check his/her safety harness, - system and anchor point and also have it checked by a coworker. If there is any doubt contact the scaffolding foreman or inspection re. anchor points. Defective harnesses or harnesses that lack the control tag (yearly control) for approved lifting device shall not be used and handed in for repair Use of fall lifeline The anchorage point for the lifeline shall bear a load of 1000kg and the anchorage point should be above the user The lifeline shall be connected to the anchorage point at the approved fall Harness. The rear anchorage point should be used but depending on the work the front anchorage can be used. Normally a self retracting lifeline shall be used Restraint lanyard shall not be used as lifeline Composition of the fall arrest system shall be based on identified risks like: potential pendulum movement, horizontal movement 3 USE OF LADDERS Use Ladders may only be used for access or work of short duration, like installing temporary chain hoists, control and cleaning of F & G detectors Which ladders can be used Ladders shall be in accordance with Chapter VI in the Regulations relating to scaffolding, ladders, work on roofs, etc. Ladders must have rubber knots at both ends and have no visual deformation Only single ladders may be used. Stepladders up to 3.5m, may be used on firm and even foundations when there is no potential for fall to a lower level / sea. Maximum climb height in the ladder is 2m. The 2m shall be clearly marked on the ladder In electrical switchrooms, ladders shall be of non-conducting material Inspection The user is responsible for checking the ladder before use Defective ladders must be discarded 103

Safety measures Ladders must be secured to prevent them from sliding or tipping over when used, by a person securing at the bottom until it is secured at the top. During movement on a ladder nothing must be carried in the hands. During work on a ladder three-point contact must be maintained (e.g. 2 feet and one hand). When working, standing above 2 meters fall arrest harness shall be used. 4 SCAFFOLDING Approval of work Erecting/dismantling scaffolding higher than 2m requires a Work Permit level 2. Erecting/dismantling scaffolding lower than 2m requires a general platform/area Work Permit level 2. Erecting/dismantling scaffolding over sea requires approval according to section 6 of this directive. Erecting/dismantling scaffolding Scaffolding shall be erected/moved and dismantled by authorised scaffolders only Scaffolding shall be in accordance with Chapter III of the Regulations relating to scaffolding, ladders, work on roofs, etc. A work platform (including access platforms) shall be secured with handrails and kick plates and other required covering/securing to prevent dropped objects. If this is not possible, the green scafftag shall be marked with necessary safety precautions, such as use of harness and closing of underlaying area. Erecting/dismantling scaffolding over sea When scaffolding is erected/dismantled over sea: the rules for Work over sea shall apply. a Toolbox Talk or Job Safety Analysis shall be performed. there will always be 2 scaffolders. Scaffolding approval Approval of scaffolding for use shall only be performed by authorised approval personnel. Ref. competency requirements, section 1. Approved scaffolding is shown with a green scafftag with date and signature. The scafftag must be at the scaffolding entrance The scaffolding foreman must ensure scaffolds are inspected/approved at least once every 7 days, as well as before and after spells of strong wind or other conditions that may damage the scaffolding 104

Approval of the scaffolding used for temporary securing Approval of the scaffolding used for temporary securing shall be performed by authorized personnel. Ref competency requirements section 1 Approved scaffolding is shown with a green scafftag with date and signature. The scafftag must be at the scaffolding entrance The scaffolding foreman must ensure scaffolds are inspected/approved at least once every 14 days, as well as before and after spells of strong wind or other conditions that may damage the scaffolding Use of scaffolding Only scaffolding having a green scafftag is approved for use Scaffolding must be used in accordance with limitations given on the green scafftag. 5 ROPE ACCESS (RA) Standard, training, procedures and methods NS 9600 part 1, 2, 3 and 4 shall be used for rope access work NS 9600-4 Requirements to and certification of suppliers of services sets the standard to the skills requirements, roles, responsibilities, methods and the execution of work Approval RA work requires approved work permit level 1 oowork shall be planned and executed according to NS 9600 oorescue plan shall be attached to the Work Permit form 6 WORK OVER OPEN SEA Introduction Work over sea means work taking place outside permanent railing where there is a risk of a person/persons falling into the sea. Use of Rope Assess (RA) is not defined as work over sea when it is performed in compliance with RA requirements in section 5. Work in hydraulic basket in moon pool and on approved scaffolding is not defined as work over sea when extra barriers are in use such as oofall arrest equipment ooman-riding belt oonet ooscaffolding build as a class 3 and to be certified and used as a class 2 scaffolding with extra heighten hand rail (railing). The scaffolding shall be certified every week and inspected after external influence e.g. strong wind 105

Note: use of fall arrest equipment, man-riding belt or net requires independent securing. (not attached to the scaffolding). Approval Work over sea requires an approved work permit level 1 Restrictions Work over sea is permitted provided: The wind speed is < 30 knots, measured at a 10 m level The wave height is < 5 m (corresponds to 3 m significant wave height) Standby vessel is in near-standby mode or MOB in extra preparedness mode The MOB boat onboard or on the standby vessel is operative and can be launched/retrieved in case a person falls into the sea The light and view is good enough to perform the work and rescue any person that may fall into the sea Consent has been obtained from the diving supervisor if there is diving activity near the work site Safety precautions When working over sea, a safety guard must be present and monitor the personnel located over sea at all times. The safety guard shall be familiar with and carry out tasks stated in the Safety guard s duties in connection with work over sea A life buoy with line and light shall be easily available The performing personnel shall be familiar with all procedures, preconditions, risks and safety precautions relating to the work Everyone working over open sea shall wear a life vest When working below the cellar deck, consider whether to secure spills, overflow, etc. from e.g. fire water Consider the need for implementing measures to avoid objects falling to lower levels or down on vessels. 106

HSE DIRECTIVE 3 WORKING AT HEIGHTS ATTACHMENTS Attachment 1: Duties for the safety guard during work over sea Attachment 2: Safety Critical Work Procedure BP Attachment 1: Work Permit Form Level 1 Attachment 2: Work Permit Form Level 2 Attachment 3: Guidelines For Completing And Using Work Permit Form Attachment 4: Fire Guard s Duties Attachment 5: Safety Measures For Working With Hydrocarbon Carrying Systems Attachment 6: Safety Measures For Working With Hazardous Chemicals Attachment 7: Safety Measures For Jet Water Washing Over 250 Bar Attachment 8: Safety Measures For Pressure Testing Attachment 9: Form For Approval Of Hot Work Class A In Classified Areas Attachment 10: Advance Approval Of Hot Work Class A In Classified Areas Attachment 11: Form For Logging Heating Value

ATTACHMENT 1: DUTIES FOR THE SAFETY GUARD DURING WORK OVER SEA The Safety Guard shall be clearly marked with sikkerhetsvakt Before commencing the work The Safety Guard shall: participate in the work planning, including SJA / pre-job talks locate the nearest fire call point/telephone ensure that the agreed MOB function (Standby boat or the installation s MOB crew) is informed and operational establish and check radio communication with the work place, CCR and MOB function. (Standby boat or the installation s Radio room when using the installation s MOB boat. Check that the radio in the MOB boad can communicate with the Safety guard). ensure escape routes are known by involved personnel be familiar with the weather limitations for work over sea perform comradeship check upon fall arrester equipment and life vest During work The Safety Guard shall: inform CCR and MOB function at start, interruption and completion of work be located at a permanent deck of the installation and have an unhindered view of the personnel working over sea not take part in work that may interfere with his/her duty as safety guard monitor changes in weather conditions/visibility and light and stop the work if the preconditions and limitations for the work are exceeded monitor the work and surroundings and stop work should a situation arise that calls for such action facilitate a good dialogue with the stand-by vessel regarding light and weather conditions, if and when any limitations should occur Interruptions/ completion of work The Safety Guard shall: inform CCR and MOB function secure equipment/workplace If man over board The Safety Guard shall: notify colleagues CCR and MOB function activate alarm throw out a life buoy maintain visual contact with person in sea secure equipment/workplace Alarm situations The Safety Guard shall: notify personnel over sea and stop work secure that all personnel return to a permanent deck of the installation secure equipment/workplace 109

ATTACHMENT 2: SAFETY CRITICAL WORK PROCEDURE BP Safety Critical Work Procedure BP Task / Title: USE OF FALL ARREST HARNESS / WORKING IN HEIGHT SiKAP No.: 1.70.076 Verified by: OTL-V Mech/Utility Date: 01.01.2011 Field: Discipline: BPN Offshore ALL TAG no.: N/A Validated by: B.Skulstad, S.G.Hellevik, A.Hide, G.Lied Date: 03.11.2011 Approved by; Owner HSSE Directive no 3 Working in Height Date: 01.01.2012 Rev. No.: 03 Expire: 12/2015 Consequence 1 2 3 4 5 D C B A Probability The objective for the work procedure (ref. classification sheet no,): K 1.70.076 Prevent personnel injury from using fall arrest harness and associated equipment. Identified dangers (ref. classification sheet no,): K 1.70.076 1. Lack of competence in inspection, control and use of fall arrest harness and lines. 2. Uses anchor points of less strength than 1000kg load bearing capacity. 3. Incorrect limitation in use of equipment in relation to fall distance to protruding equipment or swinging can result in collision and hurt oneself. 4. If hanging for a long time in fall protection harness one can get circulation failure if one does not get to use relief (leg) strap. (Hang trauma) References: (Refers to relevant laws, regulations and BP s directives, manuals, HMS-instructions, vendor s documents, datasheet for chemicals and other dangerous substances,) Governing documents: 8 Golden Safety Rules Permit to Work, Working at Hights; HSE directive 1 Work Permits, HSE directive 3 Working at Hights. Vendor documents: Users Guide Drawings: Users Guide HSE data sheet, N/A (LogiChem): Planning / Preparation: WP Level 1 when working over sea, otherwise Level 2 Work Permit (WP) no.: Level 1 Class A Class B Level 2 Class B Direct involved roles Performing technician, one person/safety guard (number): 2+ Gassfree /Access / Ref WP Scaffolding: Requirement for service by N/A vendor: Tools / Equipment / Chemicals: (Refers to special personal protective equipment, tools listings, special equipment and expected state of equipment / systems, in excess of WP, in advance to allow start of work) Equipment/system state: Ref WP Special personal protective Fall arrest harness and associated line(s) equipment: Special tools & equipment: N/A Special lifting equipment: N/A Special position of valves: N/A Step Description of the activity: (step number Comments: (especially critical steps and warning no.: gives the sequence of actions; bullets indicates about adjacent activities are marked with underlined that the actions can be performed in any chosen BOLD letters and eventual risk reducing measures are order) noted, ref to Tr@ction no. and SJA as relevant.) Plan for working at hights: NOTE! - Consider the need for WP level 1 or 2 It is vital to initiate rescue immediately after a - Follow check list and tick off each step fall. To be hanging in the harness without being - Step 7, see identified danger no. 4 able to use the relief strap may indulge hang - The need for written rescue plan shall trauma to the person and stop the blood from always be considered circulating. Evt.kvitter ARKIVERT: Eustvs2/BPN Info Vol//Templates/BP Norge Templates 1 av 2 110

Safety Critical Work Procedure BP Task / Title: TAG no.: USE OF FALL ARREST HARNESS / WORKING IN N/A HEIGHT SiKAP No.: Field: Discipline: Validated by: B.Skulstad, S.G.Hellevik, A.Hide, G.Lied 1.70.076 BPN Offshore ALL Date: 03.11.2011 Verified by: OTL-V Mech/Utility Date: 01.01.2011 Approved by; Owner HSSE Directive no 3 Working in Height Date: 01.01.2012 Rev. No.: 03 Expire: 12/2015 Consequence 1 2 3 4 5 D C B A Probability Check list for use of fall arrest harness / working in height Check points N/A YES NO Comments Are you using a full body harness with double latch self-locking snap 1. hooks and equipment with relief strap / foot strap? 2. Has a proper anchor point for the safety line been located? Is fall arrest equipment in use that will limit the free fall to 2 meters or 3. less? Has the fall arrest equipment been visually checked for: 4. - damage/wear or defects? - control tag with the latest control date? If a ladder is used, is the ladder free of visual damage and secured? 5. During securing of the ladder one person shall secure the ladder at the bottom until the ladder is secured at the top Has the fall arrest equipment, system and anchor point been checked by 6. a colleague? Is there a person in the work area that can initiate basic rescue, if a fall 7. should occur? Are equipment / tools used at height controlled and adequately secured 8. against dropping? And not left behind finishing the work? Are underlying areas closed off and pressurized/sensitive equipment 9. protected against dropped objects? 10. Are lighting, noise and weather conditions satisfactory for the task? Are there any other risks and have they been evaluated and found 11. acceptable? Use the 4 Point Risk assessment 12. Have the involved persons completed a course in fall arrest methods? Have all items on the checklist been answered YES without comments? 13. If NO, the work shall not be started. Contact the line manager to find alternative methods to perform the work. ADDITIONAL COMMENTS : Note! Work over open sea also require the use of Duties for the safety guard during work over sea (attachment1) Date: Area technician (Work w/o WP): Performing technician(s): Closure of work 14. Are all loose tools/equipment removed from the workplace? Performing technician (s): END END ARKIVERT: Eustvs2/BPN Info Vol//Templates/BP Norge Templates 2 av 2 111