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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

Table of Contents
2

1.0

Purpose

2.0

Scope

3.0

Valve Status Register

4.0

Roles and Responsibilities

4.1 Offshore Installation Manager
4.2 Production Supervisor
4.3 Production Lead Technician (PLT)
4.4 Production Technicians

5.0

Control
5.1 OOP Control and Risk Assessment
5.2 Valve Identity
5.3 Key Transfer
5.4 Anomalies
5.5 OOP Process and Risk Assessment

6.0

Compliance and Assurance

6.1 Compliance Checking
6.2 Reviews
6.3 Audit

7.0

Reference Documentation

10

8.0

Abbreviations

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Distribution List

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6
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8
9

11
12
13

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Figure 1 Example of Control Sheet

Figure 2 Procedural Flowchart
Figure 3 Example of Compliance Schedule

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5

Note: Details of the amendment history of this document are maintained and available in the
Document Management System.

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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

Distribution List

Holders of Controlled Hard Copy

Copyholder

Location

01

Nexen Information Centre

Nexen House

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Copy

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Process Control of Safety Critical Valves/Blinds Procedure

1.0

ECN-OP-PRP-00079

Purpose
The purpose of this procedure is to set out the requirements for control of all safety critical
valves and blinds.

2.0

Scope

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The valves are of the manual type which, under normal circumstances, remains either
open or closed, otherwise, they might create a safety hazard. This includes valves fitted
with a key-operated interlock device.
Typical examples are:

Upstream and downstream manual isolation valves for Pressure Safety Valves (PSVs)
Downstream isolation valves for all PSVs. Status is Locked Open (LO), one to provide
a relief flow path if the PSV is online, but also due to the fact that pressure rating
specification change occurs immediately downstream of the PSV
Blowdown valves downstream isolation valves.
blowdown flow path

Status is locked open to ensure

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Spectacle blinds at drain points on high pressure systems, where a specification break
occurs downstream of a spectacle blind
Implementation of the procedure will ensure that the design integrity of the Installation is
maintained at all times and is not compromised in any way.

Valve Status Register

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3.0

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The basis of this procedure is maintaining a live Valve Status Register showing the
status of valves and spectacle blinds.

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The platform-specific Valve Status Register is a series of controlled documents called

Register Control Sheets each sheet is directly associated with a Piping and
Instrumentation Diagram (P&ID). A sheet exists for each individual P&ID where an LO/LC
valve or spectacle blind is noted. An example of a control sheet is shown in Figure 1.
The Register identifies the valves and blinds, show their normal state (either locked open
or locked closed) and whether they are in or out of their normal position.

The Register is retained in the Scott Central Control Room (CCR)/Buzzard Main Control
Room (MCR). The individual Master Control Sheets are available via the Company
electronic document management system.

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Process Control of Safety Critical Valves/Blinds Procedure

4.0

Roles and Responsibilities

4.1

Offshore Installation Manager

ECN-OP-PRP-00079

The Offshore Installation Manager (OIM) is responsible for:

Implementation of this procedure
Ensuring that checks associated with the compliance schedule are completed and
recorded

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Carrying out compliance checks as described in Paragraph 6.0 Compliance and

Assurance, and updating the installation Compliance Record
Discussing anomalies relating to valves, blinds and interlock keys with the Production
Supervisor
Ensuring the appropriate level of risk assessment is carried out before authorising outof-position (OOP) movements of valves/blinds identified in the installation Out of
Position (OOP) Authorisation Form

Production Supervisor

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4.2

Determining any action required

The Production Supervisor (PS) is responsible for:

Implementing action identified during discussion with the OIM

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Delegating his authority to the Production Lead Technician (PLT)to release operational
interlock keys and change over a PSV in a system where there are both duty and
standby valves
PLT and ensuring

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Issuing and controlling master interlock keys to and from the

appropriate entries are made in the sign-in/sign-out log book

Maintaining the Register of OOPs (both current and historical) and numbering new
issues. Archiving completed OOPs for 6 months from completion of work

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Carrying out compliance checks as described in Paragraph 6.0 Compliance and

Assurance, and updating the installation Compliance Record

Production Lead Technician (PLT)

4.3

The Production Lead Technician (PLT) is responsible for:

Taking custody of the Register of valves and blinds
Replacing used control sheets within the Register and replacing updated control sheets
from the master set available on the Intranet, on notification from the Onshore
Engineering Co-ordinator
Ensuring that all status changes are entered in the Register

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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

Ensuring that the operational compliance checks for valves and blinds are carried out,
as described in Paragraph 6.0 Compliance and Assurance, and updating the
installation Compliance Record
Using the Register of valves and blinds to determine when the position of an
anomalous valve or blind was changed, and by whom
Verifying that the movement of any valves and blinds is correctly recorded on the OOP
Authorisation Form

4.4

Production Technicians
Operations Technicians are responsible for:

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Issuing and accepting operational interlock keys to and from the Production Technician
and recording the transfer in the sign-in/sign-out log book. Note that authority only
exists for operational keys, as master keys are controlled by the PS

Ensuring that P&IDs are used at the planning stage to identify valves and blinds that
need to be repositioned and using this information to complete the first part of an OOP
Authorisation Form

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Completion of weekly compliance checks of valves and blinds by making comparisons

against the relevant P&ID and ensuring that the information entered on the Register is
correct and valve/blind status is clearly identified
Immediately bringing to the attention of the PS any anomalies where a valve or blind is
found to be in the incorrect position

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Ensuring that an OOP Authorisation Form is obtained before moving a valve or blind
Recording the movement of any valve or blind in the Register

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Accepting from, and returning operational interlock keys to, the PLT and recording the
transfers by signing the sign-in/sign-out log book

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Onshore Engineering Technical Authority, Process as a result of engineering changes

affecting the P&IDs and associated Register control sheets, the Onshore Engineering
Technical Authority, Process is responsible for ensuring that the master control sheet is
updated within the Intranet and requesting the PS to replace sheet(s) within the live
Register.

As a result of engineering changes resulting in the creation of a new P&ID and associated
Register control sheet, ensuring that in addition to the above, the PS is requested to add
the sheet to the compliance checking programme.

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Process Control of Safety Critical Valves/Blinds Procedure

5.0

ECN-OP-PRP-00079

Control
The essential aspects of the control procedure are graphically presented in Figure 2.

5.1

OOP Control and Risk Assessment

Any operation that requires the position of an LO/LC valve or blind to be altered must be
carried out only after an authorised OOP Form is obtained.

5.2

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The PLT and the Production Technician who is to manipulate the valve or change the
position of a blind must comply with the above requirement.

Valve Identity

All valves must have a tag attached. The tag will clearly identify the status of the valve ie
locked open or locked closed.

Key Transfer

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5.3

Unauthorised operation of the valve will be prevented by use ofadequate restraints

sufficient to secure the valve in the required position (mechanical isolation) and tagged.
The Production Technician will ensure that these controls are in place. When it is not
possible to comply with this part of the procedure, it must be brought to the attention of the
PLT so that an alternative means of identifying and securing the valve can be employed.
The PLT will make the PS aware of the situation and the remedial action taken.

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Where the operation of a valve involves the use of an interlock key, the operational
interlock key will be released to the Production Technician by the PLT and recorded in the
sign-in/sign-out log book under both their signatures. The return of the interlock key to the
PLT will also be recorded in the sign-in/sign-out log book under their signatures.

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Use of a Master interlock key can only be approved by the PS after carrying out a suitable
and sufficient risk assessment and an OOP Authorisation Form. The PS will then release
the key to the PLT and the transfer will be entered in the sign-in/sign-out log book under
both their signatures. The return of the master interlock key will similarly be recorded in
the sign-in/sign-out log book under both signatures.

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If an operational or master interlock key is found to have been released or removed

without correct authorisation, the PLT will examine the sign-in/sign-out log book to
determine when the key was released or removed, and by whom. The PLT will inform the
PS of the anomaly and take appropriate corrective action. Discussion will be held
between the OIM and PS to determine if further action is required.

5.4

Anomalies

Where a valve or blind is found to be in the incorrect position and cannot be identified by an
OOP Authorisation Form and an entry on the control sheet within the Register, the
Production Technician who discovers the situation will immediately bring it to the attention
of the PLT.
After a suitable and sufficient risk assessment has been carried out by the PLT, PS and
OIM, the Production Technician will return the valve or blind to its correct position then tag
and secure it.

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ECN-OP-PRP-00079

The PLT will try to determine when the position of the valve or blind was changed, and by
whom. The PLT will inform the PS of the anomaly and discussion will be held between
the OIM and PS to determine any further action required.

5.5

OOP Process and Risk Assessment

The Production Technician will ensure that an OOP Form details the correct valves/blinds
to be moved. If an Isolation Certificate has been written for the work, the certificate can
be attached to the form, rather than completing section 2, with the proviso that LO/LC
points are clearly identified on the certificate.

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The PS will review the OOP request and carry out suitable and sufficient risk assessment.
At this point, the PS will answer the four questions covered within section 3 of the form.
System in which LO/LC points are contained does not constitute an HP/LP interface at the
LO/LC point? If the LO/LC valve is an HP/LP interface then a HAZAN must be completed.
Integrity of system boundary (isolation) in which LO/LC points are contained has been/will
be proven by pressure build up test? Although the plant may be isolated, the isolation
must be proved to ensure that no pressure ingress can occur. If integrity of isolation
cannot be proved or does not meet the criteria given by the fluid ranking table, then a
HAZAN must be carried out.

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All sources of internal energy, if applicable (compressors/pumps etc) will be isolated prior
to movement of LO/LC points? If sources of pressure are not isolated then a HAZAN
must be carried out.

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Sources of external pressure will not be introduced whilst LO/LC devices are out of
position? This applies to pressure testing etc where overpressure protection may not
exist or the spec blind may be open exposing lower rated pipe to system pressure. If the
above criteria cannot be achieved then a HAZAN must be carried out.

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Only if the answer to ALL four questions above is YES, thus assuring that risks are As
Low As Reasonably Practicable (ALARP), may the PS proceed without the requirement to
carry out a more formal risk assessment using a HAZAN.
An ESSoW Isolation Control Certificate (ICC) shall accompany ALL LO/LC valve
movements and identify each LO/LC valve.

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In circumstances where the associated isolation is considered not to meet with company
standard, a HAZAN shall be carried out and the appropriate checkbox in the ICC checked
NO. This ICC HAZAN shall be the required OOP HAZAN if the answer to any of the
above four questions is NO.

If a HAZAN is required, a HAZAN Team will be formed. Only if risks are deemed ALARP
will work be permitted to proceed.
Each OOP Authorisation form has a unique reference number.When LO/LC valves are
returned to normal position, collect all copies of the forms and retain the original in the
folder in the Production Supervisors office.
The PLT will then discuss the work with the Production Technician(s) and the team will
implement any control measures specified.

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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

The PLT will then initial the control sheet to verify that it is permitted to move the
valves/blinds to an out-of-normal position. The original copy of the authorised OOP Form
shall be inserted into the front of the Register. The second (blue) copy of the OOP form
shall be held by the OIM for the duration of the OOP movement and the third (pink) copy
held with the ICC in the isolation lock out box.
The Production Technician then signs the control sheet to confirm the valve has been
physically moved OOP.

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On completion of the work and after the valves and/or blinds have been returned to the
normal operating position, the Production Technician will initial the control sheet and
request verification by the PLT who will then initial the sheet to verify.
When all LO/LC valves are returned to their normal operating positions all copies of the
OOP form shall be collected and signed off by the PS. The completed OOP form shall
then be archived.

6.0

Compliance and Assurance

6.1

Compliance Checking

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The physical checking of valves and blinds will be carried out in accordance with a rolling
compliance checking schedule. The programme will schedule checks of different control
sheets each week thereby ensuring that the entire system is physically checked at least
once a year.

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Each week number shall be defined within a compliance checking programme (Ref 3).
The PS is responsible for maintaining the programme such that on notification from the
Engineering Technical Authority, Process that a new control sheet has been issued due to
modifications, he shall ensure it is included within the checking programme.

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Physical status checks will also be performed after completion of major maintenance work
on individual systems carried out during a shutdown.

Reviews

6.2.1

Production Team (Weekly)

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6.2

Every week, the Operations Technicians will complete a weekly compliance check. A
system with a defined amount of valves/blinds (defined on the checksheet) will have to be
physically checked on-site to ensure the valves and blinds are in their normal position as
per the Register and that they are securely locked and tagged. If they are OOP, they
must be marked up within the Register, including the authorised OOP Form. Any noncompliance shall be reported to the PLT and the results of the check recorded on the
Compliance Record Form, which should be passed to the OIM on completion.

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Process Control of Safety Critical Valves/Blinds Procedure

6.2.2

ECN-OP-PRP-00079

Production Supervisor
In accordance with the LO/LC Compliance Schedule ( Ref 3), every second week the PS
will review any live OOP Authorisation Forms within the Register and satisfy himself that
the work described within the form is still ongoing, the current status of the Register is
up-to-date and no activities are currently underway that have not been subject to the
controls specified within this procedure. The OIM will be informed on completion of the
check and any anomalies will be brought to his attention and appropriate corrective action
taken.

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Every fourth week, the PS will select at least five (5) LO/LC points at random and check
that the valves and blinds are in their normal position as per the Register and that they are
securely locked and tagged. If they are OOP, they must be marked up within the Register,
including the authorised OOP Form.
The results of both checks shall be recorded on the Compliance Record Form, which
should be passed to the OIM on completion.

6.2.3

Offshore Installation Manager

Audit

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Every month, the OIM shall check the compliance schedule completion against target to
ensure that the checks are being carried out and being documented. He will also review
any close-out/remedial actions completed, based on the findings of the compliance
checks. He will also check the Register within the CCR to satisfy himself that any live
OOP Authorisation Forms are still ongoing, the current status of the Register is up-to-date
and no activities are currently underway that have not been subject to the controls
specified within this procedure.

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Implementation of this procedure will be subject to a audit in accordance with the UK

Operations SESR Audit Procedure (ECN-HS-PMP-00043). The audit will examine the
consistency of valve and blind positions against Register entries, the status of valves and
blinds, the integrity and condition of locking devices and the general level of compliance
with the procedure. All changes to P&IDs over the period since the last audit shall also be
reviewed to ensure that the control sheets within the Register reflect the correct revision
relating to the associated P&ID. Checks should also be carried out to ensure that any
new P&IDs containing LO/LC points issued in the period have an associated control sheet
within the Register and are included in the compliance checking programme.

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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

7.0 Reference Documentation

Out of Position (OOP) Authorisation Form, ECN-OP-FOR-00080.

[2]

Compliance Record , ECN-OP-FOR-00081.

[3]

Add New Compliance Schedule Form reference ESSoW Procedure (Electronic Safe System
of Work), ECN-HS-PRP-00048.

[4]

Operations Integrity Assessment Standard, ECN-HS-STD-00378.

[5]

Operations Integrity Assessments Procedure (Inspections, Monitoring, Spot Checks &

Witnessing), ECN-HS-PRP-00442.

[6]

Operations Integrity Assessments Procedure (Audits & Reviews), ECN-HS-PRP-00443.

[7]

Mechanical Isolation of Fluid Systems Procedure, ECN-ME-PRP-00007.

Abbreviations
as low as reasonably practicable

CCR

Central Control Room (Scott)

HAZAN

hazard analysis

LO

locked open

LO/LC

locked open/locked closed

LPT

Production Lead Technician

MCR

Main Control Room (Buzzard)

OIM

Offshore Installation Manager

OOP
P&ID

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out of position

piping and instrumentation diagram

Production Supervisor

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PS

ALARP

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8.0

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[1]

pressure safety valve

PSV

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ECN-OP-PRP-00079

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Process Control of Safety Critical Valves/Blinds Procedure

Figure 1 Example of Control Sheet

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Process Control of Safety Critical Valves/Blinds Procedure

Ops Tech

ECN-OP-PRP-00079

Production Supervisor/OIM

Inform Ops Tech of any

planned work that may require
movement of LO/LC points

Requirement identified
for movement of
LO/LC valve/blind

Complete sections 1 and 2

of OOP Form and submit to
Production Supervisor

Review OOP Form and

answer the 4 questions

YES
Carry out HAZAN
(HAZAN Team)

YES

NOPRAS
required?

NO

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Carry out
NOPRAS

NO

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HAZAN
required?

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Risks are
ALARP

Carry out
TRIC

Lead Production Technician

Implement
control measures

Verify permission to
move valve/blind

Insert form in Register

and initial control sheets

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Valve/blind moved OOP

and control sheet initialled

On completion of work,
valve/blind returned
to normal position

Request LPT
verification

Initial control sheet

to signify verification

Production Supervisor
signs off OOP Form
and inserts copy into file

Remove OOP Form

from Register

ECSOPPRP00008_002.ai

Figure 2 Procedural Flowchart

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Process Control of Safety Critical Valves/Blinds Procedure

ECN-OP-PRP-00079

LO/LC Compliance Schedule

WEEK NO

OIM

PRODUCTION
SUPERVISOR

OPERATIONS
TEAM

TARGET

2
2
2

11

12

13

14

15

16

17

18

19

20

21

22

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26
27
28

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29
30
31
32
33

2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

40

41

42

43

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34

38

OIM to check
status of register

25

37

Production Supervisor to
physically check 5 valves in field

24

36

Production Supervisor to
check status of register

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35

Weekly Status PM
(Production Technician/
Lead Production Technician)

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10

ACHIEVED

44

45

46

47

48

49

50

51

52

2
ECSOPPRP00008_003.ai

Figure 3 Example of Compliance Schedule

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