Military reference books and manuals (2009-2023, Volume 4)

Control Of Protective System Overrides and Alarm Blocks

Page 3 of 22

5.5

ALARM BLOCKING

5.6

REGISTERS

5.6.1

eLogbook Register

5.6.2

Paper Register

5.7

REVIEW OF OVERRIDES & ALARM BLOCKS

6.0

KEY DOCUMENTS/TOOLS/REFERENCES

Appendix A - AUDIT CHECKLIST

Appendix B - Safety override risk assessment (SORA)

APPENDIX C - PAPER REGISTER

APPENDIX D - FEEDBACK & IMPROVEMENT SUGGESTIONS

Revision/Review Log

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 4 of 22

Introduction

1.1

Purpose

The purpose of this document is to describe the roles and responsibilities for all

personnel involved in the risk assessment, application, and sanction of protective

system overrides and alarms during operation and maintenance activities. It ensures

there is an audit trail for the application, sanction, approval, removal of trip overrides

and ensures that the application of plant overrides is managed and assessed to reduce

risks to a level that is as low as reasonably practicable.

There are numerous examples of accidents and incidents in oil, gas and condensate

processing and transportation activities due to the uncontrolled use of trip

overrides/inhibits on running plant. It is equally true that in some instances, it is

necessary to use overrides as a temporary means of maintaining operation and

conducting essential maintenance intervention activity. This is acceptable only with the

appropriate controls in place to reduce any risks generated to As Low As Reasonably

Practicable.

1.2

Scope

This procedure applies to all protective system overrides, PSD, ESD, Fire and Gas,

Software and hard-wired inhibits and alarms blocks, on all existing and new Caspian

region assets.

The contents of this procedure are applicable to all BP owned and managed sites /

installations in Azerbaijan and Georgia. Contractors working on BP owned or managed

sites / installations are also responsible for alignment with this SSOW.

This document does not replace the procedures prepared and adopted by specialist

contractors. Neither does it supersede any national and local regulatory requirements.

All guidelines contained shall be regarded as the minimum requirements for BP owned

or managed sites / installations in Azerbaijan and Georgia.

Drilling areas which are not the responsibilities of the Senior Toolpusher AA for the

purposes of inhibit tracking; will be covered by this procedure. Drilling areas, which are

the responsibility of the Senior Toolpusher, must have a robust system in place for the

control of inhibits. Regular communication between the Senior toolpusher AA and the

Process AA in charge of the main control system must take place to ensure all possible

conflicts are addressed.

1.3

Deviations

This procedure is written in sufficient detail that it should be able to be applied

consistently at all sites / installations. There may still be the requirement for some local

rules covering site / installation specific logistical/administrative arrangements and local

variations in responsibilities to reflect differences in organisational arrangements.

These local rules should not deviate from the core processes within this document. Any

form of deviation from this procedure, including but not limited to local rules, shall be

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 5 of 22

requested and authorised in accordance with SSOW, Procedure for Deviations (Doc.

No: AZSPU-HSSE-DOC-00011-2).

DEFINITIONS

ALARP

As Low As Reasonably Practicable means risks are reduced to a

point where further risk reduction is not justifiable

Block

A means of preventing nuisance alarms from activating and

distracting the operator

CRO

Control Room Operator

Defeat

See override definition

ESD

Emergency Shutdown, usually caused by a Yellow Shutdown, a

Red Shutdown or Blow-down activation

ICC

Isolation Control Certificate

Integrity level, highest of Safety Integrity Level (SIL), Environmental

Integrity Level (EIL) and Commercial Integrity Level (CIL)

Inhibit

See override definition

LTO

Long Term Override, any override in place for more than 7 days

OIM

Offshore Installation Manager

Override

Means a software selection or hardwired link that prevents a trip

action

ORA

Operational Risk Assessment

PCS

Process Control System

PSD

Process Shutdown system also known as Protective Systems

PTW

Permit to Work

SIF

Safety Instrumentation Function

(any instrumented protective

system, sometimes known as Instrumented Protective System or

IPS)

SORA

Safety Override Risk Assessment

SSOW

Safe System Of Work

Technical Authority

TRA

Task Risk Assessment

GENERAL REQUIREMENTS

3.1

Legislation & Standards

The aim of this Safe System of Work is to achieve ”no accidents”, “no harm to people”

and “no damage to the environment”. To achieve this aim, this SSOW complies with

National Legislation, the terms of the Production Sharing Agreement

(PSA) and

mandatory BP Standards.

The best International Oil Industry practice has been adopted to reduce the level of risk

to ALARP.

In the absence of local regulations, BP Group Standards will apply. In addition,

appropriate UK and US regulations and industry best practice have been considered in

setting suitable goals and targets.

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 6 of 22

3.2

Company Requirements

It is a company requirement that all tasks are subjected to an assessment of risk to

demonstrate that risks have been reduced to as low a level as reasonably practicable

(ALARP). This can be achieved by complying with the Company‟s existing standards.

Where compliance with Company standards cannot reasonably be achieved, a formal

Risk Assessment will be undertaken to identify any additional controls and demonstrate

that risks remain as low as reasonably practicable.

- Operating Management System OMS Essentials 3.2(3.2.1) and 4.5(4.5.1)

- BP Group Engineering Technical Practice GP-30-81

3.3

Stopping Unsafe Work

To stop the continuation of potentially unsafe work at the earliest possible stage, the

Control of Work (CoW) Policy and this Control of Protective System Overrides and

Alarm Blocks procedure make it very clear that all personnel are obliged and have the

authority to “STOP” the work that they consider to be unsafe.

3.4

Document Review

This document will be reviewed on an bi-annual basis when users from the sites will

have an opportunity to propose changes to the existing processes and procedures. The

document Authority will be responsible for coordinating this review.

3.5

SSOW Specific Cross References

This Control Of Overrides Procedure shall, where appropriate, be used in conjunction

with this suite of BP AzBU SSOW Procedures referenced below.

Document Number

Title of Procedure

AZSPU-HSSE-DOC-00011-2

Deviations from Regulations and Procedures

AZSPU-HSSE-DOC-00060-2

PTW Procedure

AZSPU-HSSE-DOC-00063-2

Task Risk Assessment

AZSPU-HSSE-DOC-00002-2

BP Control of Work Standards

AZSPU-HSSE-DOC-00048-2

Energy Isolations-Electrical

Key RESPONSIBILITIES

The key roles and responsibilities within the control of overrides and alarm blocks are

described below.

4.1

Site Managers (SM) / Site Controllers (SC) / Offshore Installation Managers

(OIM)

Offshore Installation Managers/ Site Managers and Site Controllers are responsible for:

 Overall operation of the control of overrides on their site and ensuring that the

procedures described in this document are consistently followed.

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 7 of 22

 Ensuring that the control of overrides process is subject to regular monitoring and

auditing, acting upon the results of these audits to maintain the integrity of the

system and proposing any recommendations for system improvement.

 Authorising the Area Authority and Control Room Operator as competent to carry

out their duties, as described in this document, and ensuring that a controlled log of

all authorised personnel is maintained.

 Auditing the system to ensure the procedure is being followed.

4.2

Area Authority (AA)

This shall be the person designated by OIM/Site Controller as accountable for the

management of overrides and alarm disables. If this role is not designated to the Area

Authority then a standing instruction should be issued to define who is accountable for

this role.

4.3

Control Room Operator (CRO)

This shall be the person normally responsible for applying the overrides. Overrides or

alarm blocks requiring engineer level password access will be applied by a healthcare

engineer where required. Overrides requiring hardwired links will be applied by an

instrument technical under Permit to Work and Electrical Isolation procedure.

PROCEDURE

The application of overrides can only be applied after due consideration and

consultation to assess the risks. The Area Authority (AA) must ensure that there are

valid reasons to affect any disablement and a risk assessment will be performed, with

the AA deciding what level of approval is required. The results of any assessment must

be documented and retained for future reference. The AA must also record and

document any subsequent amendments to the assessment that were not originally

considered.

The risk assessment shall ensure that appropriate control remains and that safety is

not compromised. The assessment must take account of the possible cumulative effect

of existing overrides. It should detail any particular control or mitigation measures that

need to be in place. In addition, reference should be made to the future resolution of

the problem that has caused the over-ride to be applied, ie, MOC (Management of

Change Procedure), etc. It must also consider the duration that the disablement shall

be in place for. This risk assessment must be conducted by suitably qualified and

experienced operations and maintenance staff, HSE and or specialist input shall be

sought where relevant.

Risk assessments should all be registered and must be retained and be readily

accessible, for auditing of the process.

Even for routine tasks such as trip testing or sampling, a PTW and a SORA shall be

required, however a generic SORA may be prepared for repetitive tasks.

Irrespective of priority, after seven days the override is deemed to be long term (LTO)

and will be subject to a higher level of approval and review.

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 8 of 22

Reoccurring problems such as pump-change over or pigging problems shall be flagged

up for a corrective engineering solution using the EQ or MOC procedure as appropriate

and shall be treated the same as LTOs..

At every shift handover the CROs and AA shall discus the status of protective systems

overrides and alarm blocks to ensure it is clearly understood. An entry shall be made in

logbook to record the fact that this discussion has taken place.

5.1.

RISK ASSESSMENT OF OVERRIDES

All protective system overrides shall have some form of risk assessment. The

requirements are described in the flowchart in Figure 1 but are repeated below for

clarity.

5.1.1 Equipment not commissioned yet/decommissioned equipment

There is no need for a Safety Override Risk Assessment (SORA) for new equipment

not commissioned yet or old equipment that is decommissioned. Also no need to

classify equipment as Long Term Overrides (see below).

5.1.2 PM/trip test/sampling/bombing related

A PTW will be issued but the override should be recorded in the register. However a

number of tags can be recorded on a single register entry if they are for routine PM

work. A generic testing SORA can be developed or the AA can prepare a SORA

specific for the test.

If the override continues past end of the shift then an individual register entry shall be

made for the override.

5.1.3 Recently discovered faulty trip instrument

A SORA is required. In addition the SORA shall be approved by OIM/Site Controller for

any of the following:

 Protective instruments with IL 1 or above. Note IL ratings can be found on

cause & effects.

 Riser valves; sub-sea valves; down hole safety valves

 ESDV‟s

 Yellow or Red Shutdown functions

The relevant Technical Authority shall be informed of any overrides on these critical

systems at the earliest opportunity.

Some assets have ability to switch trip logic from the PSD to the PCS transmitter. If this

facility is used it shall be treated as a faulty trip instrument override.

All overrides on faulty trip instruments shall be recorded in the register.

5.1.4 Recognised reoccurring problem (e.g. pump switch over or pigging

issues).

Occasionally we have reoccurring system issues that require an override for routine

activities for example pump switch over or pigging issues. For this case a SORA can be

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 9 of 22

made on the first application then reused. Use of the override shall be recorded in the

5.1.5 Alarm Block

Risk Assessment is discussion between CRO and AA. Record override in register.

5.1.6 Long Term Overrides

If the override is in place for more 7 days it shall be reclassified as a long term override

(LTO) and shall be approved by the OOE/Production Superintendent. LTOs shall be

reported to asset management as required by OMS. Depending on the risk associated

with the loss of protection, the OOE/Production Superintendent will assess if OIM/Site

Controller or Technical Authority approval of the SORA is required. There is no need to

report overrides associated with equipment not in commission as LTOs.

5.1.7 General requirements for all Safety Override Risk Assessments

Risk assessments on overrides need to consider the following factors.

 Identify the consequence and risk associated with the failure of the protective

system or alarm to act.

 Identify the cumulative impact and risk of applying the override in addition to

any other existing overrides

 Identify any measures or actions that may be taken to reduce the risk to an

acceptable level when the override is applied.

 Specify the maximum duration for which an override/bypass may be applied.

 Specify whether any further actions need to be taken.

 Request Technical Authority review where applicable. For example, loss of a

whole fire detection zone or loss of a complete voted protective system shall

be reviewed by the Technical Authority

Risk assessments shall be recorded on a SORA sheet an example of which is given in

Appendix B.

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 10 of 22

Figure 1 - Override Process Flowchart

PM / Trip

Recently discovered

Recognised

Alarm block

Test/General

faulty trip instrument

problem (eg

Equipment not

permitted work

(includes PCS

pump switch

commissioned

(including

transmitters used for

over, pigging

yet/

overriding gas

PSD

difficulties

Decommissioned

detection while

etc)

equipment

sampling,

overriding

nucleonic level

while bombing

Confirm instrument

etc)

is faulty

AA approves

AA prepares SORA.

use of generic

Discussion

AA approves

AA approves via Permit

SORA.

between

work

to Work process.

Approval by Site Controller

control room

via Permit to

Refer to generic SORA

/OIM required for:

Refer to risk

technician and

Work process

for testing.

IL 1+

assessment

AA.

no need for

Record in register but

OR,

and confirm still

AA Approves

SORA

many tags may be

Riser/subsea/downhole

valid.

recorded as one entry

/ESDV

Yellow & red shutdown .

Record in register.

Do not count as

CRO applies

long term

override.

Record in register

overrides (LTO)

Note 1.

Record in register

CRO applies

override.

CRO applies

Note 1.

Record as

Note 1.

alarm block.

individual entry in

Inform TA at

stays on past the

earliest

end of the shift

opportunity.

Fix problem as soon

as possible

AA to classify as long term

override (LTO) if in place more

than 7 days.

Review & approval required by

OOE/Site Controller.

Reference any WO‟s EQ‟s,

Review every week by OOE/Production

MOC‟s in place to rectify to

Superintendent

Discus overrides/alarm blocks at every

problem

handover, make entry into logbook to

Review at least every month by OIM/Site

record this discussion.

LTOs require AA to revalidate

Controller

the SORA every 7 days and

Remove inhibits as soon as possible and

periodically check if solution to

Review every 2 years by SIS Technical

update paperwork.

problem is still on track.

Authority or nominee (Maximo generated)

NOTES

1. If override can only be done in the field, this will be carried out by an Instrument Technician. Overrides requiring hardwired links shall also have an

ICC. Some overrides need engineering log on, this will be done by the Control/Protective System Healthcare Engineer. Some field inhibits can be

via key-switch on remote panels, controlled by the AA, implemented by his delegate/nominee.

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 11 of 22

5.2 APPLICATION OF OVERRIDES

Application of Overrides will generally be the responsibility of the CRO. He will also be

responsible for recording the Override/Inhibit Register, and shall make reference to the

specific Risk Assessment that applies. This will form part of the shift handover report.

Overrides that cannot be applied by the CRO for example password protected systems

will be applied by the Control & Protective System Healthcare engineer but will still be

recorded by the CRO.

Hardwired Overrides are a particular concern as they can be less visible than other

types of overrides. Where a hardwired override is required, an Isolation Certificate will

also be put in place. An ICC label must be displayed on the outside of a cabinet along

with any labels attached to the cable.

5.2.1 REMOVAL OF OVERRIDES

Overrides should be removed from the systems as soon as possible, when the reason

for its application has been resolved.

5.3

FIRE & GAS OVERRIDES

Fire & Gas overrides shall follow the same procedure for trip system overrides and a

SORA is required. For F&G overrides pay particular attention to the cumulative effect of

multiple overrides.

F&G systems are not IL rated but when a whole fire or gas zone is overridden, the

SORA shall be approved by the OIM/Site Controller and Technical Authority informed.

5.4

LONG TERM ISOLATIONS & ICCs

Instrument related long term isolations and ICCs that have trip or alarm functions shall

be treated as overrides and recorded in the overrides register.

5.5

ALARM BLOCKING

Alarm blocking is sometimes required to remove the distraction of bouncing alarms.

The facilities to allow this are usually built into the control system but in a similar way to

protective system overrides, application of alarm blocks needs to be controlled,

recorded and subject to continuous improvement.

Application of Alarm Blocks

Application of alarm blocks will generally be by the healthcare engineer responsible for

the control system. The CRO will be responsible for updating of the alarm block

The CRO and AA shall review the register and sign the review log at every shift

handover.

Removal of Alarm Disables

Alarm blocks should be removed from the systems as soon as possible, when the

reason for application has been resolved

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 12 of 22

5.6

REGISTERS

Protective system overrides shall be recorded in eLogbook or on paper log during the

transition to eLogbook or if eLogbook fails.

5.6.1 eLogbook Register

The protective system overrides register will contain the following details for each

override applied. An example is given in Figure 2

Process system - Primary System

Tag number - use Title field

Tag description - use Title field

Type of override - override method field (ESD/PSD, F&G, Alarm)

Reason for override - use Details field

Risk assessment ref - write Yes if SORA attached.

Permit no - use details field

Isolation Confirmation Certificate no if applicable (hardwired overrides) - use

details field

Approved by - leave blank, this is just a text field for those assets not using

electronic approval. For AzSPU approval is via anyone with Supervisor level

access at the New Event page.

Date applied & time applied

Action required, for any reference to Maximo Job, EQ, MOC, etc where

remedial action is being worked towards removal of long term overrides - use

details field.

Date removed & time removed

Figure 2 - Example of eLogbook entry

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 13 of 22

5.6.2 Paper Register

If the eLogbook system is not in use or not available, the paper register in Appendix C

can be used.

5.7

REVIEW OF OVERRIDES & ALARM BLOCKS

An audit shall be conducted on a bi-weekly basis by the OOE/Production

Superintendent to review the number of overrides and record keeping.

An audit by the OIM/Site Controller shall be conducted on a monthly basis.

An annual audit shall be completed the someone independent from the asset, usually

the Safety Instrumented Systems Technical Authority (SIS TA) or nominee.

Just prior to the audits, the CRO shall obtain a list of active inhibits/overrides in the

system for reconciliation with the register.

The AA‟s responsibility is to ensure the requirement for long term overrides (LTOs) and

frequent or repeat overrides is subject to continuous improvement. Depending on the

situation this might be by raising an EQ or MOC for an engineering solution, or

addressing a spare parts issue.

Long term overrides shall be revalidated every 7 days. the AA will check the basis for

Long Term Overrides is still valid and mitigations are still in place and effective.

The sheet in Appendix A can be used for all audits.

6.0

KEY DOCUMENTS/TOOLS/REFERENCES

This procedure shall be used where appropriate in conjunction with the suite of AzSPU

Procedures referenced below.

Document Number

Title of Procedure

AZSPU-HSSE-DOC-00011-2

Procedure for Deviations

AZSPU-HSSE-DOC-00060-2

Procedure for Permit To Work

AZSPU-HSSE-DOC-00012-2

Procedure for Authorization

AZSPU-HSSE-DOC-00063-2

Procedure for Task Risk Assessment

AZSPU-HSSE-DOC-00002-2

Procedure for Control of Work

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 15 of 22

OVERRIDES, INHIBITS, AND ALARM DISABLES REVIEW CHECKLIST

FACILITY

DATE

Review Purpose

To review the management and control of safety systems overrides, and alarm blocks in

compliance with Procedure AZSPU-HSSE-DOC-00015-2. This pro-forma can be used for

weekly/monthly/annual reviews.

COMMENTS

1. Verify users of the override procedure

understand the procedure and their

responsibilities.

2. Verify that the record of overrides & alarm

blocks is up to date with the overrides applied.

Compare with control system reporting facilities.

3. Verify that appropriate risk assessments have

been carried out. Review a sample of SORAs

made since the last review.

4. For Long Term Overrides (LTOs) verify

mitigations are still valid and check orders for

parts, EQ’s, or MOCs are in progress.

Record here all current LTOs or attach on a

separate sheet.

Report LTOs numbers once per week to asset

management.

5. Check all instrument related long term

isolations (ICC or LTI) that have trip or alarm

functions are recorded on the overrides register

and are still valid.

6. List any PCS transmitters used for PSD and

check they are all in overrides register.

7. If paper system is in use, dispose of paper

sheets more than one year old during 2-yearly

review by TA

COMMENTS / ACTIONS

REVIEW COMPLETED BY

NAME

SIGNATURE

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 16 of 22

Appendix B - Safety override risk assessment (SORA)

Tag number of SIS device:

Plant ID:

(Specify tag no. of input or output field device)

Descriptor:

Input override/bypass

Output override/bypass

Integrity level:

(Input and output devices to be considered separately)

(If applicable)

Integrity basis:

Safety

Environment

Commercial

(Identify highest overall requirement)

Hazard from applying override/bypass:

(What are the consequences if this SIS/trip fails to act on demand?)

Possible reasons for applying override/bypass:

(Critical maintenance, fault diagnosis, etc. Note: Startup overrides/bypasses normally provided for

process operations.)

Mitigation:

(What action should be taken to minimise risk whilst SIS/trip is overridden/bypassed?)

Considering the level of risk and the potential for mitigation, the override/bypass of this SIS/trip is

classed as:

Acceptable

Unacceptable

Maximum duration of override/bypass:

Startup only

10 min

30 min

4 hr

7 days

7 days +

(How long can override/bypass remain applied?)

Observations:

(Detail any additional monitoring or precautions required?)

Assessment performed by:

Date:

Authorisation

Area Authority:

Date:

Affected Area Authority (if covered by a 2nd AA):

Date:

OOE/Production Supr:

Date:

Site Controller / OIM:

Date:

Technical Authority

Date:

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 17 of 22

APPENDIX C - PAPER REGISTER

OVERRIDES AND INHIBITS REGISTER. FACILITY _____________ AREA _____________

SHEET NO__________

Tag No

Type of

Reason

ORA ref/ Approved

Applied (CRO)

Removed (CRO)

MOC /

override Rating

Permit/

(AA)

Maximo

ICC no

Date

Time

Date

Time By Ref

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 18 of 22

APPENDIX D - FEEDBACK & IMPROVEMENT SUGGESTIONS

Procedure Feedback & Improvement Suggestions

Project Name: ______________________________

Date: ______________________________________

Name:_____________________________________

Badge Number: _____________________________

Procedure Reference: ________________________

Procedure Title: _____________________________

Improvement Suggestions (Write below your improvement suggestions)

Forward your Improvement Suggestion to the Offshore H&S

Signature: _____________ Manager at the Offshore H&S Office, Hyatt Tower 2, 6^th Floor

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 19 of 22

Revision/Review Log

Revision Date

Authority

Custodian

Revision Details

28 December 2004

Alan McNulty

Esmira Akhundova

Initial Issue

30 June 2008

Alan McNulty

Abbas Islamov

General:

(AzSPU CH&S

(Central Safety TL)

Throughout the procedure the

Manager)

document numbering for referred

procedures has been changed.

Section 1. Introduction:

1.2 Scope, 1.3 Deviation,

1.4 Legislation & Standards,

1.5 Company Requirements,

1.6 Stopping Unsafe Work,

1.7 Document Review,

1.8 SSOW Specific Cross References,

1,9 Language Facilitation

Changes were made to:

Section 2. Abbreviation &

Definitions

Section 3. Roles & Responsibilities

Paragraph 3.2 Area Authority replaces

Responsible Person (RP),

Paragraph 3.3 Control Room Operator

Section 5. Categorisation of

Overrides

Categories now refer to IL rating,

Category A and B swapped, A is now

highest, followed by B then C,

Section 6. Reason for override

New section with chart showing how

the reason for the override affects the

way it is dealt with.

Removed the need for PM driven

overrides to be put in the register

unless they go on past the end of the

shift.

Appendices:

Appendices renumbered.

Some new columns added to blank

forms

05 December 2008

Yuliy Zaytsev

Adalat Mamedov

Authority position/name and custodian

(AzSPU Safety &

(Central Safety TL)

position/name have changed to reflect

Compliance Systems

org changes in HSE&TD as of

Manager)

December 1st 2008

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 20 of 22

19 May 2009

Yuliy Zaytsev

Adalat Mamedov

Next review/revision date is extended

(AzSPU Safety &

(Central Safety TL

to 15.08.2009 due to rescheduling

Compliance Systems

Manager)

19 August 2010

Yuliy Zaytsev

Elman Shikhkerimov

The document has been re-formatted

(Offshore Health and

(CoW/Safety Systems

to be compliant with the requirements

Safety Manager)

Lead)

of Standardized HSE Document

Control Template (AZSPU-HSSE-

DOC-00025-A1)

Sub section 1.2

Changed order of paragraphs in this

section.

Sub section 1.5

Removed references to level 2 risk

assessments, using SORA approach

instead.

Sub section 1.8

Update procedure numbers in line with

ISSOW.

Sub section 1.9

Language Facilitation removed - didn‟t

mean anything.

Section 3 General Requirements

Updated against relevant group

defined practice, link attached

Removed references to level 2 risk

assessments, using SORA approach

instead.

Sub section 3.5

Update procedure numbers in line with

ISSOW.

Section 5 Procedure

 Remove requirements for Level 2

Risk Assessment - use SORA

approach instead.

 AA decides on level of approval for

SORA

 No Level 2 or SORA risk

assessment required for routine

tasks unless they go past end of

shift.

 Use IL rating to identify priority.

 Signing hand over sheet at shift

hand over - change to eLogbook

entry.

Sub section 5.1 Risk Assessment of

Overrides

 Section re-titled

 Old section 6 now included in

section 5.1

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Control Of Protective System Overrides and Alarm Blocks

Page 21 of 22

 Remove category reference and

use IL rating to prioritorise.

Sub section 5.1 Risk Assessment of

Overrides

 Section re-titled

 Section titled “Project/Modification

related work” changed to

“Equipment not commissioned

yet/decommissioned equipment

 PM related overrides to be

recorded in register but multiple

overrides on one entry allowed for

PMs

 Old section 6 now included in

section 5

 Remove category reference and

use IL rating to prioritorise.

 Update flow chart with changes

from other sections

Sub paragraph 5.2.2 Fire & Gas

Overrides

 New section

Sub paragraph 5.2.3 Long Term

Isolations & ICCs

 New section

Sub paragraph 5.2.5 Registers

 Section renumbered was 9

 Change to using eLogbook to

record overrides as well as paper

Sub paragraph 5.2.6 Review of

Overrides

 Section renumbered was 10

 Changed reviewing frequency and

responsible persons, now includes

OOE/Production Superintendent

and OIM/Site Controller.

 Changed TA review to 2-yearly

 Changed the word „Audit‟ for

„Review‟.

Appendix A

 Add check of roles and

responsibilities

 Overlapping sections from previous

audit removed.

 Include check of ICC and LTI

Add check of PCS transmitters used

for PSD

Appendix D

Updated address details inline with

Control Tier:

<<2>>

Revision Date: 19 August 2010

Document Number: << AZSPU-HSSE-DOC-00015-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE

CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 1 of 11

Procedure for Deviations

AZSPU-HSSE-DOC-00011-2

This number supersedes UNIF-HSE-PRO-101-C2

Authority:

Safety & Compliance

Custodian:

Safety Systems/CoW Lead

Systems Manager

Scope:

AzSPU

Document

Administrator:

Document Control MS Coordinator

Issue Date:

11 October 2004

Issuing Dept:

Safety & Compliance Systems

Revision Date:

25 January 2011

Control Tier:

Next Review

14 February 2011

Date:

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 2 of 11

TABLE OF CONTENTS

1 PURPOSE / SCOPE

1.1 SCOPE OF DOCUMENT

1.2 REASON FOR CHANGES

DEFINITIONS

GENERAL REQUIREMENTS

3.1 AZSPU REQUIREMENTS

3.2 LEGISLATION AND STANDARDS

3.3 STOPPING UNSAFE WORK

3.4 LANGUAGE FACILITATION

RESPONSIBILITIES

4.1 SITE MANAGER (SM) / SITE CONTROLLER (SC) / OFFSHORE INSTALLATION MANAGER (OIM)

4.2 AREA AUTHORITY (AA) / DELIVERY MARINE AUTHORITY

4.3 TECHNICAL AUTHORITY (TA) / MARINE AUTHORITY

DEVIATION APPROVAL PROCESS

5.1 APPLICATION FOR DEVIATION APPROVAL

5.2 REQUIREMENTS FOR APPROVAL

5.3 PROLONGED OR FREQUENT DEVIATIONS

5.4 WORK CONTROL (PERMIT TO WORK REQUIREMENTS)

KEY DOCUMENTS REFERENCES

APPENDIX A: AUTHORIZATION FOR LOCAL DEVIATION

APPENDIX B - GROUP MARINE STANDARD EXCEPTION OR VARIATION PROCESS

REVISION/REVIEW LOG

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 3 of 11

1 PURPOSE / SCOPE

1.1 SCOPE OF DOCUMENT

The contents of this procedure are applicable to all AzSPU owned and managed sites /

installations in Azerbaijan and Georgia. Contractors working on AzSPU owned or managed sites

/ installations are also responsible for alignment with this procedure.

This document does not replace the procedures prepared and adopted by specialist contractors.

Neither does it supersede any national and local regulatory requirements.

This procedure contributes to compliance with Group Control of Work (CoW) standard that the

Hazards associated with BP activities are identified and that the risks are assessed and

managed.

All guidelines contained shall be regarded as the minimum requirements for BP owned or

managed sites / installations in Azerbaijan and Georgia.

This dispensation process should be used whenever it is deemed necessary to deviate from

current practice, standards and procedures on a specific work site.

This procedure defines:

 Who needs to authorise deviations

 The conditions which must be met before authorisation is given

 The vehicle for documenting the process

1.2 REASON FOR CHANGES

Operations within BP Azerbaijan / Georgia are supported and controlled by:

 BP Group and subsidiary policy

 Local Legislation & International Conventions / Standards

 BP Azerbaijan / Georgia procedures

 BP Group Requirements

 Business Unit management system and other manuals, procedures, standing instructions,

etc

However, occasions may occur where the best solution to an operational need involves deviating

from one or more of the above requirements excluding legislation due to specific circumstances

at the time.

2 DEFINITIONS

Refer to document AzSPU-HSSE-DOC-00021-2 HSSE Definitions for definitions common to this

Procedure. Definitions specific to the Procedure are included below.

Site Manager

Site Controller

OIM

Offshore Installation Manager

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 4 of 11

Marine Authority

DMA

Delivery MA

SSOW

Safe System of Work

ALARP

As Low as Reasonably Practicable

PTW

Permit to Work

3 GENERAL REQUIREMENTS

3.1 AZSPU REQUIREMENTS

It is a company requirement that all deviations are subjected to an assessment of risk to

demonstrate that risks have been reduced to as low a level as reasonably practicable (ALARP).

This can be achieved by complying with the Company’s existing standards. Where compliance

with Company standards cannot reasonably be achieved, a formal level 2 Risk Assessment will

be undertaken to identify any additional controls and demonstrate that risks remain as low as

reasonably practicable, whether by compliance with Company Standards or through level 2 Risk

Assessment.

- Operating Management System OMS Essentials 3.2.1 and 4.5.1

3.2 LEGISLATION AND STANDARDS

This procedure complies with applicable national law. Applicable national law is national law as

amended by project specific agreements, e.g. the ACG Production Sharing Agreement (PSA),

and relevant International Conventions, if any, in force in Azerbaijan or Georgia, as applicable.

In the absence of national legislation, or where national legislation is inconsistent with the

requirements of project specific agreements, BP Group Standards or applicable requirements

from UK or US legislation will be complied with.

Where requirements conflict, legal advice has been obtained and a defendable compliance

position adopted.

The standards and practices contained in this procedure are consistent with those internationally

recognized within the petroleum industry.

3.3 STOPPING UNSAFE WORK

To stop the continuation of potentially unsafe work at the earliest possible stage, the Control of

Work (CoW) Policy and this procedure for Deviations make it very clear that all personnel are

obliged and have the authority to “STOP” the work that they consider to be unsafe.

3.4 LANGUAGE FACILITATION

Due to the various languages spoken at sites / installations, there is a necessity to assist all with

“an ease of understanding”.

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 5 of 11

4 RESPONSIBILITIES

4.1 SITE MANAGER (SM) / SITE CONTROLLER (SC) / OFFSHORE INSTALLATION MANAGER (OIM)

The Site Manager / Site Coordinator / Offshore Installation Manager have final responsibility for

authorising a deviation and ensuring the relevant requirements of the deviation are met from:

 BP Standards

 Practices and procedures

With reference to the Group Marine Standard this responsibility extends only as far as is required

to allow the above to discharge their accountabilities with regard to statutory duties and

authorities

4.2 AREA AUTHORITY (AA) / DELIVERY MARINE AUTHORITY

The Area Authority / Delivery Marine Authority are responsible for:

 Informing the Site Manager / Site Coordinator / Offshore Installation Manager / Marine

Authority at the earliest opportunity of the need to apply for deviation from standards,

practices and procedures

 Identifying and specifying the standards, practices and procedures from which deviation is

sought, along with the reason

 Seeking specialist technical advice where required to carry out the associated risk

assessment

 Carrying out a risk assessment and identifying mitigating measures

 Distributing the original, and copies of, the completed request with approvals

 Ensuring that all mitigating measures are in place

4.3 TECHNICAL AUTHORITY (TA) / MARINE AUTHORITY

The relevant technical authority is accountable for:

 Assessing the incremental risk to the operation with respect to the required dispensation

 Assessment of the identified mitigation requirements from the asset requesting the

deviation

 Identification of additional technical mitigation requirements should they be required.

 Reviewing current practices and updating as required following assessment

 Supporting the asset in obtaining dispensation from the company self regulated

standards, e.g. Group Standards and ETP’s

Technical Authority / Marine Authority should also provide an approval in case of deviation

request for non- or Site compliance with ETP Technical Practice / Group Marine Standard and

the process is to record it as MoC.

Limitations for the Group Marine Standard deviations are defined in section 5.1

The Register of Engineering and Technical Authorities, and Marine Authority, and Delivery

Marine Authorities, and Discipline Responsible Engineers retains in dk:

\\Bp1bakis003\baku_office\Operations\_engineering\EngWebPage\EngineeringFunctions\EA-TA-DRE.xls

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 6 of 11

5 DEVIATION APPROVAL PROCESS

5.1 APPLICATION FOR DEVIATION APPROVAL

Applications for site specific dispensation are submitted to the Site Manager / Site Coordinator /

Offshore Installation Manager at the place of operation using pro forma illustrated in Appendix A.

For such applications, the attached form should be used to document the:

 Procedure, practice recommendation, etc., from which a deviation is required

 Required duration of the dispensation

 Requested deviation

 Justification for the deviation

 Risk assessments carried out

 Mitigating measures to be implemented

 Signatures of those in charge of processing the request

 All deviations from the Group Marine Standard must be approved by the CEO BP Shipping

as appropriate via the Segment Marine Authority. Variations are a temporary authority not

to meet the standard and Exceptions are a permitted authority.The standard has a

mandated exception and variation process that is out with this procedure. The AzSPU

Marine Authority shall be contacted in the first instance for all Marine Standard variations

and exceptions. See Appendix D

5.2 REQUIREMENTS FOR APPROVAL

The Site Manager / Site Coordinator / Offshore Installation Manager at the place of operation

have the authority for final approval for deviations from BP standards, practices and procedures.

In order to authorise dispensation for a deviation, the Site Manager / Site Coordinator / Offshore

Installation Manager is responsible for ensuring that:

 A risk assessment has been properly carried out in accordance with AZSPU-HSSE-DOC-

00063-2 Task Risk Assessment

 Appropriate technical endorsement from the specific practice or standard has been

obtained

 Mitigating measures have been identified and appropriate actions implemented

 Interim procedures have been produced and distributed to all relevant personnel

Limitations for the Group Marine Standard are defined in Section 5.1

5.3 PROLONGED OR FREQUENT DEVIATIONS

If it proves necessary to deviate from a practice, standard, or procedure for a prolonged period of

time, or if the same deviation is requested on a frequent basis, the person handling the request is

responsible for implementing measures to either:

 Change the practice, standard, or procedure in order to bring it into line with what needs to

be done

or,

 Change the method of work to bring it into line with the practice, standard, or procedure.

Limitations for the Group Marine Standard are defined in Section 5.1

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 7 of 11

5.4

WORK CONTROL (PERMIT TO WORK REQUIREMENTS)

All work requiring an authorised deviation from BP standards, practices and procedures shall be

carried out under a permit to work. This provides the vehicle for the Site Manager / Site

Coordinator / Offshore Installation Manager to ensure that all agreed precautions are in place

before the work proceeds.

Note:

The pro-forma illustrated in Appendix A is to be used for recording the deviation

authorisation. This form must be attached to the permit and must be brought to the attention

of the Performing Authority before he signs the permit.

6 KEY DOCUMENTS REFERENCES

This procedure shall, where appropriate, be used in conjunction with this suite of AzSPU

Procedures referenced below.

Document Number

Title of Procedure

AZSPU-HSSE-DOC-00060-2

Procedure for Permit to Work

AZSPU-HSSE-DOC-00063-2

Procedure for Task Risk Assessment

AZSPU-HSSE-DOC-00012-2

Procedure for Authorization

AzSPU-HSSE-DOC-00021-2

HSSE Definitions

AZSPU-HSSE-DOC- 00002-2

Procedure for Control of Work

AZSPU-HSSE-DOC-00072-2

Review/Revision Process for HSE Tier 2 Procedures

- Terms of Reference

APPENDIX A: AUTHORIZATION FOR LOCAL DEVIATION

http://docs.bpweb.bp.com/dkAzSPU:/published/hse/azspu/records/AZSPU-HSSE-REC-00203-2

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Page 9 of 11

APPENDIX B - GROUP MARINE STANDARD EXCEPTION OR VARIATION PROCESS

GROUP MARINE STANDARD EXCEPTION OR VARIATION PROCESS

Exception:

Permanent authority not to meet the GMS

Variation:

Temporary authority not to meet the GMS

Business Ops Leader

Raise GMS “Exception or

Operation Leader

Operation

Variation request”

Reviews and Approves

Records details In Annual

Leader

Via form on GMS website

“Exception or Variation”

Marine Report

Forward to SMA (S6)

(S1-S5)

Segment

SMA reviews And signs

Marine

Authority

GMD / CEO BPS

Group

Reviews and Comments

Request impacts

Informs Business

Marine

on Exception or

another Group

Type of

GMD /

Operation Leader

Director /

Variation (S8)

Standard

CEO

& SMA of decision

CEO

Request

BPS

Variation

signs

GMS

Exception

BP Shipping

Yes

Exception Form

sent

To EVP S & O

Group

GMD / CEO

Engineering

BPS

Director

and relevant

HoD

Review and

Red arrow = Not Approved: follow the red line back to BP

E GV P

Operations Leader

S & O

EVP S & O

Green Arrow = Approval of request to next stage

signs

S1 - S5 = Section 1 to Section 5 etc. of the Form

form (S11-S12)

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS DOCUMENT CAN BE FOUND AT

http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 10 of 11

REVISION/REVIEW LOG

Revision Date

Authority

Custodian

Revision Details

11 October 2004

Alan McNulty

Esmira Akhundova

Initial Issue as controlled document

25 January 2008

Alan McNulty

Abbas Islamov

General:

(CH&S Manager)

(Safety Team

Throughout the procedure the document

Leader)

numbering for referred procedures has been

changed from UNIF to AzSPU.

Section 1. Introduction:

1.2 Scope; Wording changes.

The following are inclusion to Section 1.

They are: 1.2 Scope; 4 additional paragraphs

added. 1.3 Legislation & Standards, 1.4

Company Requirements, 1.5 Stopping Unsafe

Work, 1.6 Document Review, 1.7 SSOW

Specific Cross References (new doc control

numbers), 1.8 Language Facilitation, 1.9

Procedure Summary

Section 2. Definitions:

New section

Section 3. Roles & Responsibilities:

3.1 Site Manager; Site Controller and Offshore

Installation Manager added. Foot Note added.

Added new paragraph - 3.3 Technical Authority.

Section 4. Deviation Approval Process:

Figure 1; Authorization for Local Deviation Pro-

Forma. Additional line added for approval of

Technical authority. This pro-forma has been

moved to Appendix A.

Appendices.

In addition to Appendix A, 2 new appendices

have been included to the document as follows:

Appendix A: Procedure Summary

Appendix B: Feedback & Improvement

Suggestions

05 December 2008

Yuliy Zaytsev

Adalat Mamedov

Authority position/name and custodian name

Safety&Compliance

Safety Team Leader

have changed to reflect org changes in HSE&TD

Systems Manager

as of December 1st 2008

05 February 2009

Yuliy Zaytsev

Adalat Mamedov

The next review/revision date is extended to

Safety&Compliance

Safety Team Leader

01.05.2009 due to rescheduling

Systems Manager

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Deviations

Page 11 of 11

14 August 2009

Yuliy Zaytsev

Niyaz Mamedov

The wording to deviations from legislation is

Safety&Compliance

HSE Systems -

taken out as it is mandatory to comply with all

Systems Manager

CoW Adviser

them.

The procedure’s numbering is structurally

changed in accordance with Standardized

Document Control Procedure Template

requirements.

25 November 2009

Yuliy Zaytsev

Niyaz Mamedov

Slight inclusions regarding Marine Ops made to

Safety&Compliance

HSE Systems -

Paragraphs 4.1, 4.2, 4.3, 5.1.

Systems Manager

CoW Adviser

Appendix B, Group Marine Standard Exception

or Variation Process, is included in the

Procedure.

25 January 2011

Yuliy Zaytsev

Elman Shikhkerimov

Section 3 General Requirements

Safety&Compliance

Safety

Removed reference to Getting HSE right,

Systems Manager

Systems/CoW Lead

Golden Rules and replaced with OMS, Group

requirements

Control Tier:

<<2>>

Revision Date: 25 January 2011

Document Number: << AZSPU-HSSE-DOC-00011-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION

OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 1 of 17

Procedure for:

Diving & Subsea Operations

AZSPU-HSSE-DOC-00017-2

Authority:

AzSPU Safety &

Custodian:

Safety Systems / CoW Specialist

Compliance Systems

Manager

Scope:

AzSPU

Document Administrator:

HSE Document Coordinator

Issue Date:

11 October 2004

Issuing Dept:

Safety & Compliance Systems

Revision Date:

09 April 2010

Control Tier:

Next Review

23 March 2011

Date:

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 2 of 17

Table of Contents

PURPOSE / SCOPE

DEFINITIONS

GENERAL REQUIREMENTS

3.1 Legislation & Standards

3.2 Company Requirements

3.3 Stopping Unsafe Work

3.4 Deviations

KEY RESPONSIBILITIES

4.1 Diving Technical Authorities

4.2 Dive Contractors

4.3 Management of the Diving and Subsea Operations SSOW

4.4 Dive Responsible Personnel and Company Authorized Representatives

SAFETY MANAGEMENT PROCESS

5.1 Compliance and Standards

5.2 Planning

5.2.1 COMMUNICATING EXPECTATIONS

5.2.2 ROLES AND RESPONSIBILITIES

5.2.3 COMPETENCY ASSESSMENT PROCESS

5.2.4 AUDIT PLAN 7

5.2.5 INFORMATION VALIDATION

5.2.6 WORK SCOPES AND PROCEDURES

5.2.7 EMERGENCY RESPONSE PLAN

5.2.8 RISK ASSESSMENT

5.2.9 MANAGEMENT OF CHANGE

5.2.10 BRIDGING DOCUMENT

5.3 Performing

5.3.1 SITE RULES 8

5.3.2 RISK ASSESSMENT

5.3.3 SAFETY BRIEFINGS

5.3.4 PERMIT TO WORK PROCESS

5.3.5 PROGRESS REPORTING

5.3.6 INCIDENT INVESTIGATION AND REPORTING

5.3.7 OPERATIONS COMPLETED

5.4 Measuring and Improving

5.4.1 HSE OVERVIEW

5.4.2 OPERATIONAL ISSUES

5.4.3 TECHNICAL ISSUES

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 3 of 17

5.4.4 COMMERCIAL

5.4.5 CLOSEOUT REPORTING AND MEETING

5.4.6 SHARING LESSONS LEARNED

5.5 Additional AzSPU Safe Systems of Work

KEY DOCUMENTS/TOOLS/REFERENCES

APPENDIX A - STANDING INSTRUCTION

PURPOSE / SCOPE

The purpose of this document is to define the Azerbaijan Business Unit standards and

expectations regarding diving and subsea operations within the AzSPU. This document

specifies the minimum mandatory BP and/or contractor safety management system

requirements for diving and subsea operations. Compliance with this Safe System of Work

(SSOW) will ensure that the standards of safety on diving and subsea projects are in

accordance with BP getting HSE right and the AzSPU safety management processes.

This SSOW applies to all inshore or offshore diving and subsea operations that take place on

behalf of the BP AzSPU. All contractors directly contracted by any AzSPU Project or

Operations Performance Unit, and those directly contracted by EPT Subsea Team working in

the Business Unit must comply with this Safe System of Work. Whereas the boundary of BP

control and accountability is defined by work that takes place on behalf of BP, it is the intent

that through BP influence that all diving and subsea contractors operating within the Caspian

and Black Sea regions shall likewise comply with these expectations.

DEFINITIONS

Refer to document AzSPU-HSSE-DOC-00021-2 HSE Definitions for definitions common to

this Procedure. Definitions specific to the Procedure are included below.

IMCA

International Marine Contractors Association

DMAC

Diving Medical Advisory Committee

ALARP

As Low as Reasonably Practicable

HAZID

Hazard Identification

DTA

Diving Technical Authority

CoW

Control of Work

ISSOW

Integrated Safe System of Work

WCC

Work Control Certificate

SCUBA

Self Contained Underwater Breathing Apparatus

SSoW

Safe System of Work

TRA

Task Risk Assessment

GENERAL REQUIREMENTS

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 4 of 17

- Operating Management System OMS Essentials 3.1; 3.2.1, 3.2.1.1; 3.4; 4.1.1, 4.1.2,

4.1.3, and 4.5, 4.5.1

3.1 Legislation & Standards

This procedure complies with applicable national law. Applicable national law is national law

as amended by project specific agreements, e.g. the ACG Production Sharing Agreement

(PSA), and relevant International Conventions, if any, in force in Azerbaijan or Georgia, as

applicable.

In the absence of national legislation, or where national legislation is inconsistent with the

requirements of project specific agreements, BP Group Standards or applicable requirements

from UK or US legislation will be complied with.

Where requirements conflict, legal advice has been obtained and a defendable compliance

position adopted.

The standards and practices contained in this procedure are consistent with those

internationally recognized within the petroleum industry.

3.2 Company Requirements

It is a company requirement that all tasks are subjected to an assessment of risk to

demonstrate that risks have been reduced to as low a level as reasonably practicable

(ALARP). This can be achieved by complying with the Company’s existing standards. Where

compliance with Company standards cannot reasonably be achieved, a formal level 2 Risk

Assessment will be undertaken to identify any additional controls and demonstrate that risks

remain as low as reasonably practicable.

3.3 Stopping Unsafe Work

To stop the continuation of potentially unsafe work at the earliest possible stage, the Control of

Work (CoW) Policy and this Diving and Subsea Operations procedure make it very clear that

all personnel are obliged and have the authority to “STOP” the work that they consider to be

unsafe.

3.4 Deviations

This procedure is written in sufficient detail that it should be able to be applied consistently at

all sites / installations. There may still be the requirement for some local rules covering site /

installation specific logistical/administrative arrangements and local variations in

responsibilities to reflect differences in organisational arrangements. These local rules should

not deviate from the core processes within this document. Any form of deviation from this

procedure, including but not limited to local rules, shall be requested and authorised in

accordance with SSOW, Procedure for Deviations (Doc. No: AZSPU-HSSE-DOC-00011-2).

KEY RESPONSIBILITIES

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 5 of 17

Operations and Project Groups operating within the AzSPU are responsible for the safe

management of diving and subsea projects. They control the diving or subsea requirement,

the worksite and the management control systems. These responsibilities are met through full

compliance with this document and those referenced. Those responsible for diving in the

AzSPU must verify that third parties operating within BP’s sphere of influence accord with the

safety management system requirements. Any deviations from this SSOW or the Dive Safety

Management System must be justified through a risk management process.

4.1 Diving Technical Authorities

All new diving operation or diving safety related MoCs will require, prior to commencement /

implementation, approval to proceed from the AzSPU Diving Technical Authority or his

nominated Deputy. The function of the AzSPU Diving Technical Authority is based in Baku -

Azerbaijan.

In addition, the AzSPU seeks further advice and guidance from BP EPT Segment Diving

Technical Authority, based in Aberdeen. Besides technical competence on subsea operations,

the BP EPTG - Global Diving Group also provide independent auditors to verify diving

contractors compliance with AzSPU approved Diving and Subsea Operations Practices. If

required, BP EPTG (EPT Segment Diving Technical Authority) will provide preparation,

planning and support for diving and subsea emergency response and investigation of diving

related accidents.

4.2

Dive Contractors

Dive contractors are responsible to fully understand and comply with the requirements for

development of the safety management system. Other third parties not directly contracted by

the AzSPU but working within the BP sphere of influence must also comply with the SMS

requirements.

4.3

Management of the Diving and Subsea Operations SSOW

This custodian for this Safe System of Work is the Business Unit Central HSE Department.

Regular review, maintenance and management of document changes are the responsibility of

HSE through reliance on technical input from the technical authorities.

4.4

Dive Responsible Personnel and Company Authorized Representatives

Responsibilities for these individuals shall be thoroughly defined in the work scope specific

Dive Safety Management System. A BP authorized representative shall be on board all dive

support vessels or diving sites. The Diving Representative is accountable to ensure that all

diving operations comply with the safety management system. In addition, they must be

competent in their ability to provide overall HSE assurance in accordance with other AzSPU

standards.

SAFETY MANAGEMENT PROCESS

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 6 of 17

The intent of this SSOW is to describe the applicable processes for the management of diving

and subsea operations within the AzSPU. Prior to the commencement of any dive operation

the BP Technical Authority shall ensure that the dive contractor has an implemented Dive and

Subsea Operations Safety Management System (SMS), which is in full compliance with the

SSoW for Diving & Subsea Operations, the components of which are depicted in the following

figure, and shall include as a minimum the various elements described in this section.

COMPLIANCE

PLANNING

PERFORMING

MEASURING & IMPROVING

Communicating

Expectations

Roles &

Responsibilities

Site Rules

Competency

Assessment

Process

Risk

HSE Overview

NATIONAL

Assessment

REGULATIONS

Audit Plan

Operational

CLOSE OUT

Safety Briefings

Issues

REPORT &

BP DIVING &

MEETING

BP POLICIES &

SUBSEA

Information

BRIDGING

OPERATIONS

EXPECTATIONS

OPERATIONS

Validation

DOCUMENT

COMPLETED

PRACTICE

LESSONS

Permit to Work

Technical Issues

LEARNT

Process

Workscope

DIVING

& Procedures

INDUSTRY

STANDARDS

Progress

Commercial

Reporting

Risk

Assessment

Accident

Investigation &

Reporting

Emergency

Response Plan

Management

of Change

5.1

Compliance and Standards

To assure AzSPU and project groups that any work undertaken by a contractor supplying

diving or subsea services, direct or through third parties meets BP expectations, the diving

standards must be stated. The minimum compliance standards are of International Marine

Contractors Association

(IMCA) and the rules of the International Code of Practice for

Offshore Diving Operations, D014, and associated Guidelines.

The use of SCUBA Diving technology is banned on all BP worksites or on vessels,

marine units or inshore / offshore subsea structures which are contractually associated

with the execution of work to be performed on behalf of BP.

The diving and subsea contractor must maintain a full membership of IMCA. IMCA codes of

practices shall be applied including Former Dynamic Positioning Vessel Operators

Association, Association of Offshore Diving Contractors, and Diving Medical Advisory

Committee Guidance Notes.

5.2 Planning

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 7 of 17

5.2.1 Communicating Expectations

At the start of and throughout a diving or subsea project, it is essential that BP expectations on

policies, practices and procedures be communicated to all key personnel. The Dive SMS

must describe how this will be accomplished.

5.2.2 Roles and Responsibilities

The roles and responsibilities of all organizations and key personnel involved in the

emergency response, management and control of a diving or subsea project must be clearly

defined.

5.2.3 Competency Assessment Process

A process for ensuring the competence of onshore and offshore personnel shall be adopted

and applied to key personnel involved in the emergency response, management and control of

a diving or subsea project.

5.2.4 Audit Plan

An audit plan for the diving or subsea operation shall be developed. As a minimum the

contractors’ management systems, vessels, plant and equipment shall be audited to BP and

IMCA International standards prior to work commencing. The audit plan should discuss how

ongoing assurance would be maintained throughout the scope of operations.

5.2.5 Information Validation

A system shall be in place to ensure that all information on the worksite is current and valid.

Key documents with the latest revisions should be listed in the bridging document. Though

non-mandatory, an Asset Information Dossier can be useful in providing relevant information

for the site including the following topics:

 Field description

 Work control systems

 Communications

 Simultaneous operations

 HAZID

 Generic risk assessment

 Documentation references

5.2.6 Work Scopes and Procedures

Work scopes and procedures must be clearly defined and reviewed by the BP technical

authority before work can commence. They shall be written with due regard to BP

expectations, policies and practices.

5.2.7 Emergency Response Plan

Response systems and callout procedures must be in place for BP, the diving and subsea

contractor, other offshore operators and other key parties.

5.2.8 Risk Assessment

All activities including work scopes, generic and specific procedures must be subject to a

formal risk assessment process during the planning phase. The process will identify any

requirement to change the work scope and procedures and/or any mitigating measures to be

applied. The process should employ the diving or subsea contractor's SMS with active

involvement from all parties whose acts or omissions could adversely affect the health and

safety of persons engaged in the project or could affect plant, equipment or the environment.

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 8 of 17

5.2.9 Management of Change

The diving and Subsea contractor must have a documented system to manage change. The

management of change procedure will define how change is implemented, who is authorized

to approve levels of change and how any appropriate risk-reducing measures are applied.

5.2.10 Bridging Document

No diving or subsea operation can commence until an authorized bridging document has been

issued. The bridging document is the interface between BP and other parties SMS’s. It

provides scope overview, operational detail for an emergency response and outlines how the

SMS requirements have been met. A separate bridging document will be required for each

phase of a diving or subsea project or major element of work. Key personnel and the AzSPU

Crisis Management Department and Incident Management Team must receive controlled

copies.

The contents of a bridging document should include but are not limited to:

 Project title and revision status.

 Circulation list and authorisation signatures.

 Project overview including dates and contract arrangements.

 Identification of the relevant work scopes and procedures.

 Identification and allocation of key personnel roles and responsibilities.

 Communication contact numbers for key personnel and worksites.

 Accident and incident reporting mechanisms.

 Management of change process.

 Emergency and contingency procedures including clarification of primacy.

 List of referenced documentation including revision status.

 Work control system.

 Audit status of key items of equipment.

5.3 Performing

5.3.1 Site Rules

Site rules that define the specific arrangements to manage and control diving and Subsea

projects safely shall be in place for all sites. These will include HAZID, work control system,

simultaneous operations, emergency response, and communications.

5.3.2 Risk Assessment

Formal onsite risk assessments, the review of generic risk assessments, job safety analysis

and personal risk assessments must be conducted for all elements of the project including

routine maintenance activities. The process should employ the diving and subsea contractor's

SMS with active involvement from all parties whose acts or omissions could adversely affect

the project.

5.3.3 Safety Briefings

Briefings on BP expectations, policies and practices are to be given to all personnel involved

in the project, including marine crew and third parties. A system of general safety briefings,

safety meetings and toolbox talks must be carried out and recorded. Appropriate site

orientation, induction and project specific training that includes site rules and emergency

procedures shall be undertaken to clarify roles, responsibilities and actions. All personnel

should attend the briefings and training, and a register should be maintained.

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 9 of 17

5.3.4 Permit to Work Process

In addition to the diving and subsea contractor or vessel permit to work system, when working

inside the sphere of influence of the BP AzSPU, the BP Permit to Work (PTW) system is to be

employed. A nominated competent person will act as the Performing Authority and will remain

onsite throughout operations. The PA is to be the Contractor’s Supervisor. The BP Worksite

Rep will facilitate the issue of WCC between the issuing Asset and the Contractor’s

vessel/spread. The BP Worksite Rep & Contractor’s Supervisors must be formally trained in

the BP PTW System.

5.3.5 Progress Reporting

A process of regular communications between the key parties shall be in place to report

project progress including safety operational and technical issues.

5.3.6 Incident Investigation and Reporting

An agreed system of accident, incident and near miss reporting must be implemented to

ensure BP reporting requirements are met. All health, safety, technical integrity and

environmental incidents including near misses shall be openly reported, investigated and

documented in order to analyse and learn from the incident. A multi-functional team with

independent participation and leadership from BP management will investigate major

incidents.

5.3.7 Operations Completed

On completion or suspension of operations the diving and subsea contractor is to inform BP of

the status of the project in accordance with the requirements detailed in the relevant contract

or third party agreement. Only on the acceptance by BP of the as-builts and close out

documentation produced by the diving and subsea contractor can final acceptance of the

works be achieved.

5.4 Measuring and Improving

In order to assess the performance of the project or a phase of work it is essential that a

measurement and improvement process is in place and the project details are recorded in a

closeout report. This will allow lessons learned to be carried forward to other projects or

phases of work. The items detailed below should form the structure of the closeout report.

5.4.1 HSE Overview

HSE data including a summary of accident, incident and near miss reports from the diving and

subsea contractors shall be collated. The conduct and culture of contractors and other parties

should be reviewed and issues raised in order to improve standards and compliance with

requirements. The information gathered from all levels of reporting is to be analysed to identify

and monitor trends and develop prevention programmes and actions.

5.4.2 Operational Issues

Information on all activities including, but not limited to, the following list should be reviewed,

recommendations raised and actions recorded in order to improve standards and compliance:

 Chronology of the project

 Positive and negative performance of contractors, personnel and plant

 Procedures and work processes

 Logistics and communications

 Project documentation

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 10 of 17

5.4.3 Technical Issues

As-built and closeout documentation must be used to revise BP documentation. Relevant

documentation must be updated immediately if the changes affect diving and subsea safety.

5.4.4 Commercial

An itemised outline breakdown of costs and expenditure (compared to budget/CTR values)

should be recorded for reference and audit purposes.

5.4.5 Closeout Reporting and Meeting

The closeout report and meeting are central to the measuring and improving stage. The

objectives of the closeout meeting will be to:

 Review the final closeout report and corrective action requirements

 Review the project and its final status

 Highlight any lessons learned

5.4.6 Sharing Lessons Learned

Lessons learned from the project or phase of work must be shared and where appropriate

distributed to the wider diving and subsea industry.

5.5 Additional AzSPU Safe Systems of Work

In addition to the applicable processes, other AzSPU Safe Systems of Work must also be

taken into consideration, as well as the Golden Rules of Safety.

The AzSPU authorization to dive procedures must also be completed to allow diving and

subsea operations to commence.

KEY DOCUMENTS/TOOLS/REFERENCES

The reference documents with which compliance is the minimum standard in conjunction with

this SSOW are:

International Marine Contractors Association (IMCA) International Code of Practice for

Offshore Diving and associated Guidelines

Oil & Gas UK Diving Guidance

Diving Medical Advisory Committee (DMAC) Guidance and Best Industry Practice

BP Control of Work Standards AZSPU-HSSE-DOC-00002-2

Procedure for Permit to Work AZSPU-HSSE-DOC-00060-2

Procedure for Task Risk Assessment AZSPU-HSSE-DOC-00063-2

Procedure for Deviations AZSPU-HSSE-DOC-00011-2

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 11 of 17

APPENDIX A - Standing Instruction

TECHNICAL DOCUMENTATION FRONT SHEET

Total pages: 2 including cover

Azerbaijan Business Unit

Standing Instruction

In addendum to Safe System of Work for

Diving and Subsea Operations

Approved Helmets

Rev

Date

Reason for

Prepared

Technical Authority

Technical

Checked

Engineering

Director HSE

Issue

Authority

Manager

24 July 03

Equipment

M.Sinquefield

H.Kuhlmann

R.McKay

K.Kennelley

G Campbell

approvals

Control Tier:

<<2>>

Revision Date: <<09 April 2010>>

Document Number: << AZSPU-HSSE-DOC-00017-2>>

Print Date: 2/1/2011

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/component/hssesms

Procedure for Diving & Sub-sea Operations

Page 12 of 17

Document Number:

Disk Ref.

Addendum to UNIF-HSE-PRO-272

Military reference books and manuals (2009-2023, Volume 4) - page 36