Petronas Technical Standards: Human Factors Engineering - Valve Analysis
Petronas Technical Standards: Human Factors Engineering - Valve Analysis
PTS 30.00.60.13
DECEMBER 2012
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner.
PTS 30.00.60.13
December 2012
Page 2
PTS Circular
2012 - 1
This revision of PTS 30.00.60.13– Human Factors Engineering – Valve Analysis (December
2012) has been updated to incorporate PETRONAS Lessons Learnt, Best Practice and new
information issued by relevant industry code and standards.
The previous version of this PTS 30.00.60.13 (May 2004) will be removed from PTS binder/ e-
repository from herein onwards.
The custodian of this PTS is:
Name: M K Shrivastava
Tel. No: 03-2783 6508
Please direct any questions regarding this PTS to the above-named.
Document Approval
Revision History
PTS 30.00.60.13
December 2012
Page 3
PREFACE
PETRONAS Technical Standards (PTS) publications reflect the views, at the time of publication,
of PETRONAS OPUs/Divisions.
They are based on the experience acquired during the involvement with the design, construction,
operation and maintenance of processing units and facilities. Where appropriate they are based on,
or reference is made to, national and international standards and codes of practice.
The objective is to set the recommended standard for good technical practice to be applied
byPETRONAS' OPUs in oil and gas production facilities, refineries, gas processing plants, chemical
plants, marketing facilities or any other such facility, and thereby to achieve maximum technical and
economic benefit from standardisation.
The information set forth in these publications is provided to users for their consideration and
decision to implement. This is of particular importance where PTS may not cover every
requirement or diversity of condition at each locality. The system of PTS is expected to be
sufficiently flexible to allow individual operating units to adapt the information set forth in PTS to
their own environment and requirements.
When Contractors or Manufacturers/Suppliers use PTS they shall be solely responsible for the
quality of work and the attainment of the required design and engineering standards. In particular,
for those requirements not specifically covered, the Principal will expect them to follow those design
and engineering practices which will achieve the same level of integrity as reflected in the PTS. If in
doubt, the Contractor or Manufacturer/Supplier shall, without detracting from his own responsibility,
consult the Principal or its technical advisor.
Subject to any particular terms and conditions as may be set forth in specific agreements with
users, PETRONAS disclaims any liability of whatsoever nature for any damage (including injury or
death) suffered by any company or person whomsoever as a result of or in connection with the use,
application or implementation of any PTS, combination of PTS or any part thereof. The benefit of
this disclaimer shall inure in all respects to PETRONAS and/or any company affiliated to
PETRONAS that may issue PTS or require the use of PTS.
Without prejudice to any specific terms in respect of confidentiality under relevant contractual
arrangements, PTS shall not, without the prior written consent of PETRONAS, be disclosed by
users to any company or person whomsoever and the PTS shall be used exclusively for the
purpose they have been provided to the user. They shall be returned after use, including any
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and PETRONAS may at any time require information satisfactory to PETRONAS in order to
ascertain how users implement this requirement.
PTS 30.00.60.13
December 2012
Page 4
TABLE OF CONTENTS
1. INTRODUCTION ........................................................................................................ 5
1.1 SCOPE........................................................................................................................ 5
1.2 DISTRIBUTION, INTENDED USE AND REGULATORY CONSIDERATIONS ......... 5
1.3 DEFINITIONS ............................................................................................................. 6
1.4 CROSS REFERENCES .............................................................................................. 6
1.5 SUMMARY OF MAIN CHANGES ............................................................................... 6
2. GENERAL INFORMATION......................................................................................... 7
2.1 APPLICATION OF HFE PRINCIPLES IN DESIGN AND ENGINEERING ................. 7
2.2 GENERAL HFE PRINCIPLES RELATING TO VALVE SELECTION AND
LAYOUT ...................................................................................................................... 7
2.3 AIMS AND BENEFITS OF CONDUCTING A VALVE ANALYSIS.............................. 7
2.4 TIMING AND PROCESS ............................................................................................ 8
3. VALVES CRITICALITY ANALYSIS (VCA) ................................................................. 9
3.1 PROCESS DESCRIPTION ......................................................................................... 9
3.2 KEY STEPS IN THE PROCESS............................................................................... 11
3.3 RESPONSIBILITES .................................................................................................. 11
4. REFERENCES ......................................................................................................... 12
APPENDICES
APPENDIX A VALVE CRITICALITY ANALYSIS ................................................................... 13
APPENDIX B HFE DESIGN REQUIREMENTS FOR THE SELECTION, LOCATION
AND ORIENTATION OF VALVE OPERATORS/ACTUATORS ...................... 16
PTS 30.00.60.13
December 2012
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1. INTRODUCTION
1.1 SCOPE
This PTS PTSspecifies requirements and gives recommendations for applying Human
Factors Engineering (HFE) principles to the operation and maintenance of valves during
project engineering. It includes the following:
• A procedure for analysing and then classifying the criticality of valves for a specific
application;
• Guidance on selection of the appropriate type of valve operator/actuator;
• HFE design requirements for the location and orientation of manual valves.
This PTS shall apply to new facilities and modifications to existing facilities; it is not
intended to apply to existing facilities that are not being modified.
This PTS shall be applied as part of an overall HFE scope of work within a project, in
compliance with PTS 30.00.60.10
This PTS is intended for use during a project’s DEFINE phase, and is followed up in the
EXECUTE phase, in conjunction with the overall approach outlined in PTS 30.00.60.10.,
where it is best executed as part of the HFE Design Analysis.
NOTE: The term “ergonomics” is used by many organisations and can be considered synonymous with
Human Factors Engineering.
This PTS should be read in conjunction with the following PTSs in so far as they cover
additional aspects of valves:
• PTS 30.00.60.10: Human Factors Engineering in Projects
• PTS 30.00.60.12: Human Factors Engineering - Investment Justification Model
• PTS 30.00.60.18: Human Factors Engineering – Design and Procurement of
Skid-Packaged Units
• PTS 30.00.60.80: Standard Form – Human Factors Engineering – Valve criticality
ratings
• PTS 30.10.05.11: Plant Model Construction and Review
• PTS 31.38.01.11: Piping - General Requirements
• PTS 32.31.00.32: Instruments for Measurement and Control
• PTS 34.28.00.31: Steel Structures
1.3 DEFINITIONS
1.3.1 General definitions
The Contractor is the party that carries out all or part of the design, engineering,
procurement, construction, commissioning or management of a project or operation of a
facility. The Principal may undertake all or part of the duties of the Contractor.
The Manufacturer/Supplier/Vendor is the party that manufactures or supplies equipment
and services to perform the duties specified by the Contractor.
The Principal is the party that initiates the project and ultimately pays for its design and
construction. The Principal will generally specify the technical requirements. The Principal
may also include an agent or consultant authorised to act for, and on behalf of, the
Principal.
The word shall indicates a requirement.
The word should indicates a recommendation.
1.3.2 Specific definitions and abbreviations
2. GENERAL INFORMATION
This is one of a series of PTSs that support the implementation of Human Factors
Engineering on projects. This PTS is concerned with all valves. The HFE design
requirements (Appendix B) with regard to location and orientation are mainly applicable to
manual valves but also apply to motorised, mobile actuator or otherwise remotely operated
valves if their expected criticality is such that they may need rapid or frequent manual
intervention either to override and manually operate them, or to visually check their status.
Accesibility requirements of instruments and their associated valves are addressed in
PTS 32.31.00.32
The potential benefits from the proper application of this procedure include:
In Design:
• Reduced engineering hours (less re-work) thanks to earlier and more explicit
communications between Principal and Contractor on expectations regarding HFE and
general operability;
• More efficient approval cycle through application of an early and “right first time”
approach;
• More efficient and focused design and/or model reviews (2D and/or 3D CAD) with better
traceability of design requirements and trade-offs;
• Potential reductions in CAPEX through reduction of (permanent) steel structures as a
result of a tighter categorisation of Category-1 (Critical) valves.
In Operations:
• Improved ease and efficiency of working on the part of the Principal’s personnel (i.e. end
users in Operations);
• Reduced OPEX through reduced avoidance of modification costs to mitigate health
risks;
• Improved emergency response through quicker and more accurate identification,
access, operation and status feedback of valves;
• Fewer health problems (e.g. muscular-skeletal strain) due to operators having to adopt
awkward postures or require forces to be exerted that exceed their capabilities.
VCA
1 No Stop
Required?
YES
PEFS
(P&IDs) Arrange
2
VCA Session
VCA Session
Review Valve
Classification and
3 Determine Criticality
Rating
Consider use of
4 MOV, RVO &
Mobile Actuators
Formalize requirements
5 and integrate in
BDEP/PS
Validate compliance
6 throughout EXECUTE
Phase
Steps in Figure 1:
1. HFE Screening - VCA requested?
The typical point at which a VCA is requested is during the HFE Screening session
(Project Team meeting to discuss HFE scope of work required). The VCA can efficiently
be conducted as part of an HFE Design Analysis activity, or alternatively as a
standalone work scope (see PTS 30.00.60.10). For skid-packaged units, the decision to
conduct a VCA for a particular unit will be dependent upon the outcome of the HFE skid-
package screening as described in PTS 30.00.60.18. Valves on skid-packaged units
PTS 30.00.60.13
December 2012
Page 10
shall comply with the HFE design requirements provided in Appendix B, whether a VCA
was requested or not.
2. Arrange and execute VCA session.
As soon as the PEFS (P&IDs) are available, the HFE Co-ordinator or Operations
representative in the Project Team arranges the session. On "minor" projects or where
an Operations representative has not yet been assigned to the project, the Piping and
Layout discipline or group may have to arrange the VCA session. At least the following
disciplines shall be represented at the VCA session as a minimum:
• Operations
• Maintenance
• Piping and Layout
For complex projects the following additional disciplines should also be considered:
• Human Factors Engineering
• Process Engineering
• Technical Safety
• Civil/Structural
For Vendor-supplied skid-packaged units that were identified requiring a VCA, the
Package Engineer will have responsibility for arranging the session, in consultation with
the HFE Co-ordinator or Operations representative.
3. Prepare valve list and determine criticality ranking
The VCA session shall prepare a listing or table of valve types identified on the PEFS
(P&IDS) and review the valve criticality criteria provided in Appendix A. It may be
necessary to modify the valve criticality criteria provided in Appendix A due to regional
or site specific requirements, e.g. extreme weather conditions that prevent the use of
auxiliary access equipment, thus resulting in permanent access being required. The
VCA session shall then determine and record the valve criticality rating for all the valve
types listed, utilizing the categories and classification criteria as agreed upon in the
session.
4. Consider use of MOV, RVO and Mobile Actuator.
After determining the valve criticality categories or ratings for all valves, any additional
valves requiring actuators (motorised or mobile) or remote operators shall be identified
and a method of operation selected on the basis of process engineering, economic and
HFE criteria (e.g. frequency and duration of operation, force required, speed of
activation required, etc). Guidelines for the selection of actuators for non-control valves
are provided in Appendix B.
NOTE: Depending on the availability of information on valve details and specific process conditions at the
time of the VCA session, this step may have to be postponed or reviewed during detailed
engineering as more information becomes available. Additional valves, requiring actuators, should
also be considered during HAZOP studies.
5. Formalize requirements
After completion of the VCA session the results shall be appropriately documented. The
associated access and location requirements for each valve type shall be included in the
BDEP/Project Specification and managed by the Piping and Layout discipline or group.
Deviation from the Project Specification requires the approval of Operations. Criticality
ratings of valves shall be included on PEFS (P&IDs), and if a 3D CAD model is being
used for design, Category 1 valves shall be coded therein (e.g. by colour coding 3D
shapes).
6. Validate compliance throughout the EXECUTE (Engineering, Procurement and
Construction) Phase and update VCA results and the associated access and location
requirements as necessary during design.
PTS 30.00.60.13
December 2012
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3.3 RESPONSIBILITES
ACTIVITIES PARTIES
Project HFE Process All PT HFE
Manager Specialist Engineer members coordinator
or
designate
1. Decide if a Valve Criticality Approve Consult Consult Execute Consult
Analysis is needed (part of
HFE Screening)
2. Arrange VCA session and Consult Consult Consult Execute
assure HFE competence
level through awareness
training, if necessary.
3. Prepare valve list, Consult Consult Consult Execute
determine and record
criticality ranking.
4. Consider use of MOV, Check Check Consult Execute
RVO and mobile
actuators.
5. Formalize requirements Approve Check Check Execute
and integrate in Project
Specification/BDEP
document.
6. Validate Compliance. Check Check Check Execute
PTS 30.00.60.13
December 2012
Page 12
4. REFERENCES
PETRONAS STANDARDS
Human Factors Engineering in Projects PTS 30.00.60.10
Human Factors Engineering – Investment justification PTS 30.00.60.12
model
Human Factors Engineering – Design and PTS 30.00.60.18
procurement of skid-packaged units
Standard Form – Human Factors Engineering –Valve PTS 30.00.60.80
criticality ratings
Plant model construction and review PTS 30.10.05.11
Piping – General requirements PTS 31.38.01.11
Instruments for measurement and control PTS 32.31.00.32
Steel structures PTS 34.28.00.31
AMERICAN STANDARDS
Applications Manual for the Revised NIOSH Lifting NIOSH 94-110
Equation
Issued by:
NIOSH (National Institute for Occupational Health and Safety)
395 E Street, S.W.
Suite 9200
Patriots Plaza Building
Washington, DC 20201, USA
http://www.cdc.gov/niosh/
PTS 30.00.60.13
December 2012
Page 13
Valves shall be categorized during the early DEFINE phase, when the PEFS (P&IDs) first
become available, based on their criticality.
Criteria for categorizing and rating valve criticality are provided below. The associated HFE
design criteria are presented in Appendix B. The exact valve classification rating criteria to
be adopted for any project, and the associated rules for HFE design and layout, shall be
reviewed and agreed upon prior to starting the analysis.
design by preserving sufficient space and access for personnel, tools, parts, and
equipment.
A.1.2.1 Category 2 Criteria
These are valves that meet any or all of the following criteria:
• Valves associated with equipment for which rapid intervention is unlikely to be needed;
• Valves with a low operating frequency (i.e. only every 6 months or longer).
A.1.3 Category 3 (C-3) Valves
Category 3 valves are normally non-operating valves that are used in particular
circumstances on an infrequent or rare basis (e.g. hot tap valves, hydrostatic test vent, high
point vent or low point drain valves located in pipe rack).
A.1.3.1 Category 3 Criteria
Permanent accessibility to these valves is desirable but not essential. No specific location
requirements are imposed.
The use of auxiliary equipment to gain access (e.g. mobile platforms, personnel lift, and/or
scaffolding) to these valves shall be indicated and allowed for in the design.
Portable ladders should not be used for accessing valves. Any proposed exception(s) to
this shall be subject to specific review and approval.
Height and reach distances to these valves when operated from auxiliary equipment shall
conform to the “Preferred” location as outlined in (B.3) of Appendix B.
B.1 INTRODUCTION
This attachment provides Human Factors Engineering (HFE) design requirements and
recommendations for the selection of valve operators/actuators and the location and
orientation of valves so that they are easy and safe to operate and maintain.
• Available staffing;
• Valve size;
• Access available;
• Operating environment (e.g., hazardous area or during upset condition);
• Extreme climate (heat or cold);
• Frequency of use, i.e. more than once every 6 months;
• Unreliability of infrequently used MOVs (typically MOVs are unreliable if not used on a
regular basis);
• Number of valves to be operated by same operator or group of operators (e.g.,
blending valves, switching reactors etc.), considering workload and potential time
constraints.
B.2.5 Gear operators
If a valve is not an MOV, or is not provided with a mobile operator/actuator or any type of
actuator to assist the operator, and if it requires forces greater than those stated in (B.2.1)
and (B.2.2), then it shall be provided with a gear-operated handwheel.
Table B.1 gives examples of valves that will usually fall in this category.
Table B.1 Examples of valves requiring gear operators (if not MOVs or otherwise
assisted)
NOTES: 1. The above are examples for guidance purposes. Valve torques can vary for different
manufacturers and shall be checked to ensure appropriate selection of gear operators
based on the maximum and sustained force requirements provided in (B.2.1) and (B.2.2).
2. Some Manufacturers provide gear operators with their standard offer.
• in hazardous areas (confined space, below water or where noxious fugitive emissions
may be present).
B.2.8 Mobile operators
The use of appropriate mobile operators (e.g. air drill or nut runner) may be considered for
gear operated valves requiring a large number (> 100) of turns, provided the following
additional requirements are adhered to:
• Mobile operator shall be matched with valve type to ensure no damage to valve
operation;
• Mounting point shall be accessible from a suitable (preferably permanent) standing
surface and have a stop or bracing point to absorb the reaction torque of the mobile
operator;
• To protect the operator of the mobile operator, a torque reaction bar and/or a suitable
mounting bracket shall be used at all times;
• Size, weight and portability of mobile operators shall comply with the appropriate HFE
requirements for lifting and hoisting (consult a regional HFE Specialist for more details).
B.2.9 Manual valves
Manual valves shall be operated by means of a circular handwheel or lever.
Handwheels and levers on all valves shall conform to the operational stereotype of
requiring to be turned in an anticlockwise direction for opening and a clockwise direction for
closing.
Valve handwheels should not be larger than 455 mm (18 in) in diameter. Larger
handwheels may apply more torque but will increase the force application required of the
operator and will also require more space.
Handwheels shall be designed with knurling, indentation, high-friction covering, or a
combination of these to facilitate the operator's grip for applying maximum torque.
Valve lever handles shall be as long as necessary to produce the necessary torque to crack
open and turn the valve but without exceeding the maximum cracking force. Handle lengths
normally range from 355 mm (14 in) to 915 mm (36 in) in length.
Valve lever handles may be of any shape (circular is preferred) but should have a circular
grasping surface for the final 180 mm (7 in) of their length. The grasping surface should be
between 13 mm (0.5 in) and 25 mm (1 in) in diameter and should have a non-slip surface.
Unacceptable
1300 mm
(51 in)
Preferred
455 mm
(18 in)
Acceptable
150 mm
(6 in)
455 mm Grade/deck
(18 in)
Max. horizontal distance from
obstruction or operator’s front
NOTES: 1. Distances or heights are measured to handwheel centreline. For gear-operated valves with a
handwheel provided with a spinner handle, maximum horizontal distance is measured to the edge
of the handwheel furthest from the operator.
2. Heights are to be to the maximum extension of valve stem for rising stem valves.
3. These dimensions are appropriate male and female personnel worldwide from 5th to 95th
percentile, except that the top limit for the “Preferred” choice location should be reduced by 100
mm (4 in) to accommodate male and female populations in regions such as West Africa,
Southeast Asia, Southern China, parts of Latin America, India and Japan.
4. For valves located below 455 mm (18 in), sufficient clearance of at least 1300 mm (51 in) should
be provided behind the operator to accommodate a bending or kneeling posture.
Figure B.1 Mounting heights for hand-wheel operated valves with vertical stems
PTS 30.00.60.13
December 2012
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Unacceptable
1830 mm
(72 in)
Preferred
610 mm
(24 in)
Acceptable
230 mm
(9 in)
Grade/deck
455 mm
(18 in) Max. horizontal distance from obstruction,
or operator’s front
NOTES: 1. Distances or heights are measured to handwheel centreline. For gear-operated valves with a
handwheel provided with a spinner handle, maximum horizontal distance is measured to the edge
of the handwheel furthest from the operator.
2. These dimensions are appropriate for personnel worldwide, from the 5th percentile of the female
population to the 95th percentile of the male population, except that the top limit should be set at
1755 mm (69 in) for 5th percentile males and 66 in (1675 mm) for 5th percentile females in regions
such as West Africa, Southeast Asia, Southern China, parts of Latin America, India and Japan.
3. For valves located below 455 mm (18 in), sufficient clearance of at least 1300 mm (51 in) should
be provided behind the operator to accommodate a bending or kneeling posture.
Figure B.2 Mounting heights for handwheel operated valves with horizontal stems
B.3.3.2 Lever operated valves
Valve levers shall be mounted in the locations as shown in Figures B.3 and B.4, depending
on valve stem orientation and maximum force requirements (B.2.1). No valve handles shall
protrude into walkways or work areas when the valve is in the closed position.
PTS 30.00.60.13
December 2012
Page 21
760 – 1300 mm
(30 – 51 in)
Grade/deck
NOTE: These dimensions are appropriate for personnel worldwide, from the 5th percentile of the female
population to the 95th percentile of the male population, except that the top limit should be reduced to
1145 mm (45 in) to accommodate 5th percentile females in regions such as West Africa, Southeast
Asia, Southern China, parts of Latin America, India and Japan.
Figure B.3 Mounting heights for lever-operated valves with vertical stems
Grade/deck
NOTE: These dimensions are drawn for North American males, and are therefore appropriate for other
regions such as Northern Europe, Australia, UK, and Central Europe. These dimensions should be
reduced to 1805 mm (71 in) for 5th percentile males in areas such as West Africa, Southeast Asia,
Southern China, parts of Latin America, India and Japan, and 1725 mm (68 in) for 5th percentile
females in West Africa, Southeast Asia, Southern China, parts of Latin America, India and Japan. To
accommodate the same international population of 5th percentile females, horizontal stem valves
should be located at least 1145 mm (45 in) above the standing surface, rather than 1300 mm (51 in)
as shown.
Figure B.4 Mounting heights for lever-operated valves with horizontal stems
Valves oriented with the stem in a horizontal position are preferred when the lever is
located between 150 mm and 760 mm (6 in and 30 in), or more than 1300 mm (51 in)
above the deck as shown in Figure B.4. However, the maximum height above the deck to
the valve tip should not exceed 1905 mm (75 in). The valve handle is not permitted to rotate
down from centreline if there is a walking surface directly underneath.
PTS 30.00.60.13
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Valves in a vertical section of the pipe e.g., located in a manifold or at battery limit, shall be
oriented with all the stems on the same side as shown in Figures B.5 and B.6, with a
75 mm (3 in) clearance maintained between the lever and any obstruction.
X X X = 75 mm (3 in) minimum
Grade/deck
Figure B.5 Manifold or battery limit valves with 75 mm (3 in) minimum gap between
lever-end and the nearest flange/obstruction
X = 75 mm (3 in) minimum
X X
Grade/deck
Figure B.6 Manifold or battery limit valves with 75 mm (3 in) minimum gap between
front face of lever’s outer surface and nearest flange/obstruction
PTS 30.00.60.13
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Vertical Horizontal
stem valve stem valve
LT LG
610 mm 610 mm
(24 in) max (24 in) max
Figure B.7 Required lateral reach distances (minimum and maximum) for level
instruments, gauge nozzles or valves on the side of a vessel;
lever/handle operated
B.3.4 Valve Maintenance Considerations
B.3.4.1 Access
The minimum distance between valve flanges and any obstruction shall be the bolt length
plus 25 mm (1 in) to allow access for hand tools and torquing of bolts.
Where standing room is required for maintenance access to valve flanges, the clearance
between a flange and a wall, structural steel, or guardrail shall not be less than 460 mm
(18 in).
PTS 30.00.60.13
December 2012
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Vertical Horizontal
stem valve stem valve
LT LG
610 mm 610 mm
(24 in) max (24 in) max
Figure B.8 Required lateral reach distances (minimum and maximum) for level
instruments, gauge nozzles or valves on the side of a vessel; hand-
wheel operated.
B.3.4.2 Valve mass and lifting aids
Valves with a mass less than 23 kg (50 lb) shall be located so that they can be lifted by one
person without risking injury through poor lifting posture. Valves with a mass less than
45.5 kg (100 lb) shall be located so that they can be lifted by two persons, provided the
valve can be lifted without having to reach over or around items between the persons and
the valve.
NOTE: The 23 kg (50 lb) limit is the lifting equation load constant in NIOSH 94-110. The recommended mass
limit assumes a single lift and optimum lift-height, lift-distance and body position. For any repetitive
type lifting or non-optimal body positioning, the lift height or distance, and other relevant handling
factors, a regional HFE Specialist shall be consulted.
For all valves in excess of the above weight limits and lifting heights that must be lifted for
repair, replacement or maintenance, permanent or portable assisted lifting devices (e.g.
‘chain-falls’, ‘lever chain puller/hoist’) shall be provided to aid the lifting or moving. If such
devices are provided, space for them and the personnel who use and manoevre them shall
be provided.
Assisted lifting devices provided to assist in lifting or moving equipment should be able to
be located (e.g. by means of pad eyes or beam clamps) directly over the item to be lifted so
the lift is vertical to prevent swinging loads when the items are raised or lowered. Two lifting
aids may be used simultaneously, one on each side of the valve, if a vertical lift is not
feasible.
Hoisting areas should be free of obstacles such as cable trays, HVAC ducting, structural
components, piping, and other equipment within a radius of at least 305 mm (12 in) at the
point of hookup to the device.
There shall be sufficient clearance above each valve to attach the lifting device and pull the
valve or valve operating mechanism, or to complete all maintenance tasks in place without
removing the valve.