Isolation Documents – A Hidden Risk?

Introduction

The author takes a deep dive and relates his in-field operation and commissioning experiences over the past 20 years on equipment isolation systems.

The article focuses on Plant and Equipment ISOLATION DOCUMENTATION and areas where documents are conflicting,  confusing and not up to date.

A common starting point is to examine the Reference Table and other references in the body of each document to see if a review and update has been done when other related documents have been changed.

Common & Related Documents

• Isolation Procedure and forms
• Task Isolation Matrix/Database
• Permit to Work Procedure and form
• High Risk Procedures and forms  
• Work Instructions and Operating Procedures
• Induction, Training and Competency Assessment modules
• Company Standards and control procedures.
• Drawings : P&ID, SLD , General Arrangement.
• Supplier/Manufacturer – Operating & Maintenance Manuals
• WHS Acts & Regulations, Codes of Practice.

Consequences

Consequences of inadequate document alignment and management results in:

1.  Inadequate training , competency assessment, implementation and oversight, causing  human error with potential for injury, plant damage, catastrophic failure and attention of the WHS regulator .
2. Extra workload for the plant owner to create isolation plans and coordinate plant shutdown isolations.
3. Inadequate information on Task Handover from one shift to another.

Common issues

• Verbose, hard to understand and complex writing, inadequate process flow charts and pictures.
• Procedures, processes and forms designed and approved by persons who are not familiar with plant processes and field operator /maintainer practical requirements.
• Permit Hand over and time extension not clearly described.
• Changes not carried over to related documents.
• No process or accountability to review , update and coordinate changes to each document
• Document terms and definitions not consistent across linked documents
• Different terms introduced in the body of the document but not defined in or contrary to the Terms and Definition Tables.
• Inconsistent version control for updated documents
• Document has not been peer reviewed and approved, omits details such as:
• Author, Reviewer, Approver
• Dates
• Brief description of changes
• Piping & Instrumentation Diagrams (P&ID), Single Line Diagrams(SLD), Process Flow Diagrams(PFD) and isolation matrix database are not updated when changes are made to plant processes.
• OEM manual specifications not aligned with P&IDs, SLDs, operating procedures and risk assessments (JSA).
• “Test for dead”  not clearly described for mechanical isolations.
• No “Naming Convention” for different types of valves and mechanical isolation devices.
• Induction, Training and Competency Assessment documents do not reflect approved procedures.
• Emphasis on theory training and e-learning , omitting practical field training and practical competency assessment.
• Training modules and competency assessments designed and conducted by unqualified and inexperienced personnel.
• Lack of “In Depth” In -Field procedural compliance audits
• Compliance audits designed and conducted by inexperienced personnel.
• Operations, Maintenance and Planning staff and project personnel not trained and do not understand the detailed requirements of the Isolation and Permit to Work processes and procedures.
• Isolations are not treated and assessed as a “Critical Risk”