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Level 2 Hazards Identification and Task Risk Assessment (HITRA) Procedure

This document defines the Level 2 Hazard Identification and Task Risk Assessment (HITRA) procedure for USPL. It outlines: - When a Level 2 HITRA is required, such as for certain high-risk tasks or when deemed necessary by management. - Roles and responsibilities of the Level 2 HITRA leader and team members in conducting the assessment. - Approval levels for HITRAs with medium residual risk by the Terminal Manager and high residual risk by the District Operations Manager. - Requirements for all employees and contractors to participate in applicable HITRAs and follow identified risk controls.
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0% found this document useful (0 votes)
339 views31 pages

Level 2 Hazards Identification and Task Risk Assessment (HITRA) Procedure

This document defines the Level 2 Hazard Identification and Task Risk Assessment (HITRA) procedure for USPL. It outlines: - When a Level 2 HITRA is required, such as for certain high-risk tasks or when deemed necessary by management. - Roles and responsibilities of the Level 2 HITRA leader and team members in conducting the assessment. - Approval levels for HITRAs with medium residual risk by the Terminal Manager and high residual risk by the District Operations Manager. - Requirements for all employees and contractors to participate in applicable HITRAs and follow identified risk controls.
Copyright
© © All Rights Reserved
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USPL

Procedure No.: USPL-COW-490-001


Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 1 of 31

Level 2 Hazards Identification and Task Risk Assessment


(HITRA) Procedure

Document Number: USPL-COW-490-001

Document Location: DRM

Document Custodian: HSSE Manager - S&O


Renewal Date: 1/10/2022

Revision Reason for revision Sections / Documents Author Date


No. revised
1.0 Original all J. LaBrie 9/28/2009
Exemplar Exemplar Project all J. LaBrie 4/21/2010
Exemplar Exemplar Project Revision / Effective Dates C. Shubra 8/9/2010
and Section 8.2
4.0 Gap closure all K. Sun 07/08/2014
4.1 Investigation Revised paragraphs 3.7.5, K. Sun 1/10/2017
recommendations 8.2.D, 8.3.2, 8.3.10, and J. Varner
intro. to Appendix 2.
4.2 CoW Simplification all M. Anderson 05/01/2020
Updates

Document
Role1 Signature Title Date
Approvers
Head of Operations &
John D’Andrea Authorizer
HSSE
Juan Ortega Authorizer HSSE Manager
Chin Kim Authorizer EPIC Manager
Director HSSE and North
Dan Knapp Authorizer eMOC 1491 12/8/2016
America Rail
Clorinda
Authorizer eMOC 1491 Operations Manager 11/29/2016
Nothstein
Chin Kim Authorizer eMOC 1491 EPIC Manager 11/29/2016

1
Roles include: Authorizer, Approver
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
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Revision Number: 4.1
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1. Purpose and Scope


• A Level 2 Hazard Identification and Task Risk Assessment (HITRA) is a
structured process to identify the hazards and specify actions to mitigate these
hazards for a work activity or task.
• The purpose of this document is to define when, how, and by whom a Level 2
HITRA is performed.
• The Permit to Work (PTW) Policy satisfies the requirements for performing
and documenting a Level 1 HITRA. A Level 2 HITRA is a more structured,
semi-quantitative assessment and is MANDATORY for certain tasks defined
in the Task Risk Category Table (TRCT) on the PTW (see Section 3.7)
• A Level 2 HITRA can also be performed when BP Management or people
involved with the planning and execution of work judge that there are hazards
or complexities associated with a task that requires more than a Level 1
HITRA (PTW).
• This procedure is supplemental to and to be used in conjunction with the
Permit to Work and Policies referenced in Section 7.
2. Roles and Responsibilities
2.1 The Leader of a Level 2 HITRA team
2.1.1 The leader of a Level 2 HITRA team shall be an Asset Operator,
Asset Operator Designee or has been trained and certified in this
procedure.
2.1.1.1 The Level 2 HITRA leader shall instruct the team
members in the Level 2 HITRA process and their roles.
2.1.2 Shall lead the team in performing a Level 2 Risk Assessment
according to the process described in this document.
2.1.3 Shall verify the team understands the assessment process.
2.1.4 Shall verify that the assessment team includes personnel with the
necessary knowledge and competence for the task and the
equipment involved.
2.1.5 Shall verify that the Level 2 HITRA includes a job site visit by at
least one member of the team prior to approval of the HITRA.
2.1.6 Shall allow all members of the Level 2 HITRA team the opportunity
to contribute and verify that the details of the assessment are
agreed to by all team members.
2.1.7 Shall verify that any hazards that were identified in projects,
subject to the Capital Value Process or recorded on a Project Risk
Register, are assessed in the Level 2 HITRA.
2.1.8 Shall verify that the details of the assessment are accurately
recorded on the Level 2 HITRA form.
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Procedure No.: USPL-COW-490-001
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2.1.9 Shall verify that the appropriate level of approval is obtained for the
Level 2 HITRA (see section 8.9).
2.1.10 Shall request a subject matter expert to participate on the Level 2
HITRA team if additional input is required.
2.2 Level 2 HITRA Team Members
2.2.1 Should have relevant experience and / or functional expertise in
the activity to be assessed (see Section 8.1).
2.2.2 Shall participate in the Level 2 HITRA process.
2.2.3 Shall assist in the identification of hazards and control measures to
reduce the likelihood of an incident/accident occurring.
2.2.4 Shall validate agreement with the overall Level 2 HITRA before
approval.
2.2.5 Shall include involvement from HSSE personnel.
2.3 Terminal Manager or O&M Team Leader
2.3.1 Shall review and approve the Level 2 HITRA for tasks that have a
Residual Risk Ranking of Medium and the risks are determined to
be reduced to ALARP (see Section 8.9).
2.4 District Operations Manager
2.4.1 Shall review and approve the Level 2 HITRA for tasks that have a
Residual Risk Ranking of HIGH and the risks are determined to be
reduced to ALARP (see Section 8.9).
2.5 All BP Employees and Contractors performing work for USPL
2.5.1 Shall participate in or review Level 2 HITRAs that cover the work
they will be performing
2.5.2 Shall implement, adhere to and follow all the risk control measures
identified in the HITRA.
2.6 Asset Operator / Asset Operator Designee
2.6.1 Shall serve or designate a trained and certified individual to serve
as Level 2 HITRA Leader.
2.6.2 Shall review the Level 2 HITRA each day to verify that the scope
covered on the Level 2 HITRA is appropriate, permits have been
properly identified, and that it has been properly approved.
2.6.3 Shall verify that the identified risk control measures are
implemented and communicated to the workforce.
2.6.4 Shall verify work monitoring occurs for work as specified on page 2
of the Level 2 HITRA form.
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Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
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3. Policy
3.1 Before beginning a Level 2 HITRA for Hot Work or Confined Space Entry that
requires an Attendant, an assessment shall be conducted to identify any
alternate means of performing work that does not require a Confined Space
Entry or Hot Work.
3.2 A Level 2 HITRA shall be completed and approved prior to issuing a PTW for
work tasks requiring a Level 2 HITRA. Refer to Section 3.7 or the TRCT for work
types requiring a Level 2 HITRA in DRM.
3.3 The Leader of a Level 2 HITRA shall be trained and certified in this procedure.
3.4 The Level 2 HITRA Team shall consist of at least two people having knowledge
and experience of the task and/or equipment to be used ad the expertise to
assess potential hazards of the covered tasks. (See Section 8.1).
3.5 A Level 2 HITRA is valid until the work covered by the Level 2 HITRA is
completed. The Level 2 HITRA does not expire when a PTW expires.
3.6 A Level 2 HITRA shall be reviewed to verify no changes are necessary each
time prior to the start of work shift.
3.7 A completed Level 2 HITRA shall be MANDATORY for work being executed as
described in the PTW Task Risk Category Table (TRCT). The TRCT is a living
document and a controlled copy is available in DRM for reference.
3.8 All Level 2 HITRAs shall be site specific.
3.9 A previously developed Level 2 HITRA can be used as a template but shall be
reviewed and approved by a HITRA team per this procedure each time it is
reused for a new job (see section 8.13).
Note: This team can be different than the team that previously developed the
HITRA.
3.10 The Level 2 HITRA shall be reviewed by the Asset Operator / Asset Operator
Designee each day to verify that the scope is appropriate, permits have been
identified, and that it has been properly approved.
3.11 Field copies of Level 2 HITRAs shall be kept with the corresponding PTW.
3.12 One of the HITRA team members shall make a site visit to identify any site-
specific hazards to be addressed in a new or previously developed HITRA. The
job site visit should be conducted during the planning process.
3.13 Hazards associated with the covered tasks identified during the site inspection
shall be incorporated into the Level 2 HITRA.
3.14 The Level 2 HITRA shall be kept together with the appropriate PTW on site and
be readily accessible to all persons performing the work. For Confined Space
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Procedure No.: USPL-COW-490-001
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Revision Number: 4.1
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Entry, the Level 2 HITRA shall be kept together with all the required forms that
are posted at the job site.
3.15 For a Level 2 HITRA covering a scope of work lasting several days, the original
may be reused each day or copies can be made for each separate day.
4. Prerequisites (General Requirements)
4.1 All BP employees serving in roles defined in this procedure shall be trained and
competent for their assigned roles.
4.2 All contractors who perform work within the scope of this procedure shall
understand their specific roles and responsibilities and the purpose and use of
the Level 2 HITRA form.
Note: Refer to the USPL Control of Work Training and Competency Matrix for specific
training requirements.
4.3 A PTW shall be prepared for the defined work scope. The PTW shall be used to
identify, document, and communicate specific hazards of the job site that are not
documented on the Level 2 Risk Assessment form.
5. Health, Safety, Security, Environment, Hazard Identification, and
Risk Assessment / Mitigation
5.1 This document does not require sign off by users of the procedure.
6. Equipment and Forms Required
6.1 Level 2 Hazard Identification and Task Risk Assessment Form, shown in
Appendix 4.
6.2 PTW Form
7. Supporting Documents / Related Procedures
7.1 USPL Control of Work Policy
7.2 Permit to Work Policy
7.3 Confined Space Entry Policy
7.4 Excavation Policy
7.5 Hot Work Policy
7.6 Lifting and Rigging Policy
7.7 Work at Heights Policy
7.8 Task Risk Category Table (TRCT)
7.9 USPL Standard Procedures Policy
7.10 USPL Work Management Process
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Procedure No.: USPL-COW-490-001
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7.11 USPL PPE Matrix


7.12 Diving Specifications (USPL STP 78-215)
8. Procedure for conducting a new Level 2 HITRA
The objectives of the Level 2 HITRA are to:
• Assemble a team of persons with knowledge and expertise of the covered tasks.
Where the expertise of the team members is not sufficient to complete the
HITRA, the use of internal or external specialists is recommended.
• Identify and examine the hazards associated with the covered tasks and perform
a risk assessment in a structured manner to identify credible potential
emergencies.
• Identify and implement mitigations which will reduce risks to ALARP and
receives the appropriate level of review and approval.
The procedure herein addresses each of these objectives. The process map shown
in Appendix 3 is a representation of the procedure.
8.1 Forming the Level 2 HITRA Team
8.1.1 The Level 2 HITRA Team shall be made up of the following:
• A minimum of two people.
• Consist of people (BP employees, contractor workforce, or other
external experts) having knowledge and experience of the task
and/or equipment to be used and the expertise to assess
potential hazards of the covered tasks. If the HITRA covers
multiple work types, the HITRA team shall include people with
knowledge and experience for each policy or procedure and
associated tasks.
• At least one member of the team with knowledge and
experience in the operation of equipment involved in the tasks
who can devise a set of risk mitigation controls which will reduce
risks to ALARP.
• At least one member of the team shall be a member from USPL
operations if work is being conducted on a BP asset.
• At least one representative from the workforce, either BP
employee or contractor, assigned to carry out the task being risk
assessed. In circumstances where a member of the workforce
who will be performing the work is not available, it is acceptable
to have another person on the team who is knowledgeable in
the task to be performed.
8.1.2 The Leader of the Level 2 HITRA Team should make
arrangements for the team to work as a group (the preferred
method is face-to-face but can utilize video or telephone
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Procedure No.: USPL-COW-490-001
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conferencing). It is important that sufficient time is allocated to


allow a thorough risk assessment to be performed.
8.2 Complete the Form Header
The Level 2 HITRA Leader in conjunction with the Level 2 HITRA Team members
shall complete the following on the Level 2 Hazard Identification and Task Risk
Assessment form (see form in Appendix 4):
Note: Appendix 4 is a blank Level 2 HITRA. Modifications to the form or new
versions of the form may be created and used as long as they contain the
minimum required elements as stated in the rest of Section 8 below.
8.2.1 Level 2 HITRA Title: Job Title – Asset Equipment –
Facility/Location (e.g. Install new 8” nozzle – Tank 250 – Wood
River Terminal).
8.2.2 Permit Type(s): (e.g. confined space, critical lift).
8.3 Identification of Permit Covered Tasks and Task Hazards
8.3.1 The team shall define tasks and hazards associated with covered
work.
8.3.2 At least one member of the team shall visit the job site to see the
physical layout of the area and potential job site hazards to be
addressed in the Level 2 HITRA. Particular attention should be
given to adjacent facility and equipment, process-related hazards,
and any Simultaneous Operations (SIMOPS) activities taking place
or planned to take place which can affect the activity under
assessment.

Information/Note: Other local informational manuals or documents are available that may help
identify task hazards or mitigations (if applicable).

8.3.3 The Leader of the Level 2 HITRA Team shall list each covered
task on the form. Any additional tasks can be listed at the team’s
discretion; however, all tasks listed shall be assessed in
accordance with this procedure.
8.3.4 Once the members are all familiar with the covered tasks to be
performed, the team shall list the known or potential hazards
associated with each defined task. The Leader of the Level 2
HITRA team shall facilitate this group discussion. The following
aspects of the tasks shall be considered when identifying hazards:
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Procedure No.: USPL-COW-490-001
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• Characteristics of the facility and systems directly involved (e.g.


pressure, noise, temperature, stability, voltage, H2S, toxic
chemicals, foam, wax, sludge)
• Sensitivity of the location within the facility or job site caused by
proximity of other critical assets or systems, (e.g. Heating,
Ventilation and Air Conditioning (HVAC) intakes, flare header,
control room, Natural Gas Liquid (NGL) separator, risers,
Emergency Shutdown Valve (ESDV), structural support
members, tankage)
• Critical activities necessary to perform the task (e.g. lifting,
draining fluid, inerting, isolation, flushing, entry into confined
spaces, working at heights, transport of materials, equipment
and wastes, use of power tools, hot work, grinding, bolting, use
of cables and hoses)
• Possibility of interaction between simultaneous activities within
the permit covered task or other unrelated tasks taking place
nearby (SIMOPS)
o If there is a SIMOPS issue and the work cannot be
rescheduled, hazards introduced from the SIMOPS shall
be assessed on the Level 2 HITRA form
8.3.5 The Leader of the Level 2 HITRA team shall make sure that each
team member is given adequate opportunity to express their views.
8.3.6 The Leader of the Level 2 HITRA team may designate another
team member to document hazards on the Level 2 HITRA form.
8.3.7 Hazards identified at the time of the job which are not associated
with the permit covered tasks such as environmental factors (i.e.
weather) that change from day to day shall be evaluated by the
ATW process or can be added to the field copy of the HITRA form
if a Level 2 assessment is warranted by the workforce (see 8.12).
8.3.8 Hazards that are listed and addressed on the Level 2 HITRA Form
are not required to be included on the ATW form.
8.3.9 Hazards that are listed and addressed on associated permits are
not required to be included on the Level 2 HITRA Form.
8.3.10 Hazards identified in the Capital Value Process as outlined in the
USPL Engineered Modifications / Small Project Policy (USPL-
PEM-001-001) should be reviewed for inclusion on the Level 2
HITRA Form.
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Procedure No.: USPL-COW-490-001
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8.4 Identification of Hazard Effects


8.4.1 Each hazard shall be evaluated to determine the Hazard Effect
and appropriate Hazard Effect level (D, E, F, G, H) using Figure 1 -
Hazard Effect Table.
8.4.2 Consideration should also be given to the possibility of cumulative
effects from the interaction of several different hazards.
This initial identification of hazard effects shall be done with the
assumption that there are no control measures or mitigations in
place except for the normal PPE required by the PPE Matrix. The
evaluation of hazard effects with control measures and mitigations
in place shall be done during the determination of residual risk.

Information/Note: The initial assessment of risk shall be determined on the basis that
no specific control measures exist except for the normal PPE required by the PPE matrix and:
• The worst reasonably credible severity of the hazard effects, should anything go wrong.
• The probability of the hazard being realized and resulting in the specified hazard effect
This is in order that the full risk potential may be recognized. The effectiveness of the assessment
depends entirely on the team's ability to identify and evaluate all known hazards associated with
the task.

Figure 1 - Hazards Effect (HE) Table

Equipment
Hazard Effect Health and Damage,
Environment Privilege to Operate
Level Safety Business
Value Lost
Public outrage
>1000 bbl (fluids) Regional or prolonged
> 10,000 lb media coverage or severe
national coverage
Multiple (Flammable Gases) $100m -
D Actual or threatened loss
Fatalities > 200,000 lb $0.5 billion
of License to Operate for
(Flammable Liquids) Asset
> 200,000 lb (gas/vapors/solids) Likely to lead to change
of regulations
100 < 1000 bbl (fluids)
1000 < 10,000 lb
Localized or limited
Fatal Injury (Flammable Gases)
“interest group” outrage $5m -
E Permanent 20,000 < 200,000 lb
Significant enforcement $100m
Disability (Flammable Liquids) action against Asset
20,000 < 200,000 lb
(gas/vapors/solids)
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Procedure No.: USPL-COW-490-001
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1 < 100 bbl (fluids)


DAFWC
100 < 1000 lb
Hospitalization Prolonged local media $500k -
F (Flammable Gases)
Temporary attention $5m
2000 < 20,000 lb (Flammable Liquids)
Disability
4000 < 20,,000 lb (gas/vapors/solids)

0.1 < 1 bbl (fluids)


No DAFWC 10 < 100 lb Short term local media
No (Flammable Gases) coverage $50k -
G Hospitalization
200 < 2,000 lb Fines or other penalties to $500k
OSHA Asset
Recordable (Flammable Liquids)
400 < 4000 lb (gas/vapors/solids)

< 0.1 bbl (fluids)


<10 lb
(Flammable Gases)
Simple First Short term complaints
H <200 lb <$50k
Aid from neighbors
(Flammable Liquids)
<400 lb
(other hazardous vapors/solids)

8.5 Determination of Probabilities and Initial Risk Level


For each identified Hazard Effect and associated Hazard Effect Level, the
Probability (1 – 5) of the Hazard Effect happening shall be selected from Figure 2
Hazard Effect – Probability Matrix.
The following guidelines should be used for assigning probabilities:

5 Very Likely The hazard effect will almost certainly


occur
4 Likely There is a good chance the hazard effect
will occur
3 Somewhat Likely There is a small chance the hazard effect
will occur
2 Unlikely It would be remotely possible for the
hazard effect to occur
1 Very Unlikely The hazard effect will almost certainly not
occur
Assignment of probabilities for initial and residual risk assessments shall be by
consensus of the assessment team. The team should consider any site, district,
region, USPL, BP, contractor or industry reference information available along
with the combined experience of the team or any internal/external experts
consulted. Examples of reference information that can be utilized are as follows:
• Previous executions of same or similar job
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• BP Incident databases and reports


• BP Near miss databases and reports
• Contractor vetting database (e.g. ISNetworld)
• API or other industry safety incident data
• Workforce experience with this scope of work
• Previous risk assessments
The initial Risk Level shall be determined from Figure 2 and the risk level
represents the product of the Hazard Effect Level and the Probability of the Hazard
Effect being realized. The risk levels are: Low (L), Medium (M), High (H), and Very
High (VH).
Figure 2 - Hazard Effect vs. Probability Risk Matrix

Probability
1 2 3 4 5

IMPACT
Very Unlikely Unlikely Somewhat Likely Likely Very Likely
LEVEL

D 6 8 10 11 12

VH
E 5 7 9 10 11
Hazard Effect

9
F 4 6 8 H 10

G 3
5 7 M 8 9

H 2 L 4 6 7 8
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Figure 3 – Approval Level Matrix

Residual Risk Level Minimum Level of Approval

Very High (VH) 10 to 12 Unacceptable Risk

High (H) 8 to 9 District Operations Manager

Medium (M) 6 to 7 Terminal Manager / O&M Team Leader

Low (L) 1 to 5 Level 2 HITRA Leader

8.6 Identification of Control Measures and Mitigations


8.6.1 While identifying control measures and mitigations for hazards,
consideration should be given to the following:
• task
• people involved
• tools, equipment, PPE, and materials to be used
• working environment
8.6.2 The team shall work through the list of hazards to specify the
methods needed to control each of their associated risks. Control
measures over and above the normal PPE as required by the PPE
Matrix shall be recorded as the team considers control measures
necessary to achieve ALARP. The Hazard Effect - Probability Risk
Matrix should be used as a guide for this purpose. The hierarchy
of controls discussed below should be used as a guide so that a
full range of options are considered.
8.6.3 When specifying Risk Control Measures, any associated hazards
associated with controls to be implemented shall be identified and
addressed in the assessment.
8.6.4 The hierarchy of controls is a sequence of options which offer a
number of ways to approach the hazard control process. One
representation of this hierarchy can be summarized and illustrated
as follows:
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Most Effective
Eliminate the hazard
Eliminate a hazard and completely eliminate the associated risk, i.e., conduct
task else where, conduct the task during facility turn-a-rounds
If a hazard cannot be eliminated, continue to substitution:
Substitute the hazard with a lesser risk
Substitute something else (a substance, process, or practice) that has less
potential to cause harm
If the hazard cannot be eliminated or substituted, continue to engineering
controls:
Engineering controls
Use engineering controls to remove a hazard or place a barrier between the
workforce and the hazard
If the hazard cannot be mitigated with engineering controls, continue to
isolation methods:
Isolate the hazard
Contain the work environment or work process to interrupt the path between
the workforce and the risk, e.g., insert blind flange, guards or barriers, set up
temporary or permanent enclosures
If isolation methods are not feasible, use administrative controls:
Administrative controls
Reduce the risk by through training assuring competency of the workforce, the
use of specialist personnel, changing rosters, close supervision, establish
policies/standards or procedures such as permit policies
If this is not practical, then:
Personal protection equipment
When you can't reduce the risk in any other way, use personal protective
equipment (e.g. gloves, goggles,) as a last resort
Least Effective
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8.7 Determination of Residual Risk

Information/Note: The Residual Hazard Effect generally remains the same


as the Initial Hazard Effect when mitigations such as PPE, administrative controls,
and isolation are put in place, e.g. hearing protection mitigates a noise hazard but
the initial and residual hazard effect of noise are the same. The Residual Hazard
Effect may change from the Initial Hazard Effect when engineering, substitution and
elimination mitigations are used, e.g. an initial hazard effect for electrical shock
mitigated with a lockout can be eliminated as a residual hazard effect.

8.7.1 The team shall work to re-evaluate the hazard assuming that the
identified control measures and mitigations are in place by
repeating the process of determining the Hazard Effects, Hazard
Effect Levels, Probabilities, and Risk Levels.
8.7.2 Once the team has reached agreement that the risks are
considered to be As Low As Reasonably Practical (ALARP), the
Hazard Effect Level, Probability, and Risk Level shall be recorded
on the Level 2 HITRA form in the residual risk columns and “Y” for
“yes” entered in ALARP column.
8.7.3 After the residual risk level for each identified hazard has been
recorded, the highest risk level shall determine the minimum level
of approval for the Level 2 HITRA based on Figure 3 - Approval
Level Matrix.
8.7.4 If the Residual Risk Level is in the Very High zone (10 - 12), the
risk is unacceptable and the task cannot be performed without the
implementation of further, more rigorous risk control measures to
reduce the Risk Level to a lower level

Information/Note: When evaluating Residual Risk, consideration should also be given to the
possibility of cumulative effects from the interaction of several different hazards.

8.7.5 If the team concludes they need additional team members to assist
in the HITRA, the task shall be suspended. The HITRA Leader
shall then request the participation by a subject matter expert as a
team member.
8.7.6 As a final check, the team should ask itself the following questions
about the proposed task:
• Was the hierarchy of risk control measures (Section 8.6)
followed?
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• Have all necessary risk control measures been identified?


• Is there a need for engineering change to eliminate or reduce
risk?
• Is there a need to shutdown the facility in order to perform the
work?
• Is the residual risk acceptable?
8.7.7 If the team determines that the residual risks are ALARP for the
tasks to be performed, the team members shall sign the Level 2
Risk Assessment form indicating their completion of the Level 2
HITRA.
8.8 Specification of Work Monitoring Requirements
Even though all work is to be monitored by the Performing Authority, if special
monitoring over and above the norm is required, the Level 2 HITRA Team shall
• Determine the requirements (if any) for additional monitoring for the
execution of the tasks.
• Specify the frequency of additional monitoring, e.g., once per hour or
monitoring at specific critical phases or job tasks.
• Document the additional monitoring requirements on the Level 2 HITRA
form.
8.9 Approval of Level 2 HITRA
Refer to Figure 3 – Approval Level Matrix in Section 8.5. (Written approval
required which can be by signature, fax, email, or electronic signature).
8.9.1 If the highest Residual Risk Level is Low, the Leader of the Level 2
HITRA team shall approve the Level 2 HITRA.
8.9.2 If the highest Residual Risk Level is Medium, the Leader of the
Level 2 HITRA team shall submit the Level 2 Risk Assessment
form to the appropriate Terminal Manager or O&M Team Leader
for approval.
8.9.3 If the highest Residual Risk Level is High, the Leader of the Level
2 HITRA team shall submit the Level 2 Risk Assessment form to
the District Operations Manager for approval using proper protocol
with the Terminal Manager/O&M Team Leader and District
Operations Manager if applicable.
8.9.4 If the approver accepts the level of risk, he/she shall approve the
Level 2 Risk Assessment in writing to the Leader of the Level 2
HITRA team.
8.9.5 If the approver does not accept the level of risk, he/she shall work
with the Level 2 HITRA team and other appropriate personnel to
either change the tasks or modify equipment to reduce the
Residual Risk Level.
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 16 of 31

8.9.6 After approval of the Level 2 Risk Assessment, the Leader of the
Level 2 HITRA team shall either make the completed Level 2 Risk
Assessment form available to the Asset Operator or follow District
procedures to file the HITRA for future use.
8.10 Implementation of Control Measures
The AO / AOD shall verify that the identified risk control measures are
implemented and communicated to the workforce.
8.11 Workforce Acceptance
The workforce shall sign the PTW form to verify they understand the scope of
work, hazards identified and associated control measures.
8.12 Additional Hazards and Changes to HITRA
8.12.1 Additional Hazards Identified
For additional hazards identified after approval, a Level 2 HITRA
Leader shall document the hazards on page 3 of the HITRA form
in the section titled “Changes and Additional Hazards and/or Risk
Control Measures”. The additional hazards shall be evaluated and
approved in accordance with this procedure.
8.12.2 Changes to Level 2 HITRA
For changes to page 1 or 2 of the HITRA form after approval, a
Level 2 HITRA Leader shall document the changes on the form
and the changes shall be evaluated and approved in accordance
with this procedure. Changes can include additional tasks, control
measures, monitoring requirements or general comments identified
after the original HITRA was approved.
8.12.3 Approval Signatures
Approval signatures for changes and additions shall be on page 3.
8.13 Use of a Previously Developed Level 2 HITRA
A previously developed Level 2 HITRA that is stored as an electronic file can be
printed and used as a template for development of a current up-to-date HITRA.
The development and completion of the HITRA shall be in accordance with this
procedure (see section 3.9).
8.13.1 Electronic Level 2 HITRAs that are associated with SPs shall be
referenced in the SP using the HITRA title and also linked to the
electronic file.
8.14 Revision of a Level 2 HITRA
8.14.1 The HITRA Leader shall request a revision to the electronic
version of the HITRA to incorporate changes and additions made
to the field copy when the changes and additions are expected to
be present each time the job is performed.
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 17 of 31

8.14.1.1 If changes are not typically expected to be present each


time the job is performed, the electronic version of the
HITRA does not need to be revised.

End of Procedure
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 18 of 31

Appendices
Appendix 1 - Definitions
As Low As Reasonably Based on the judgment and experience of the Level 2
Practical (ALARP) HITRA Team, the risk is at the lowest level that can
be achieved as reasonably practical.
Asset Operator A BP employee who is responsible for the operation
of the asset where work is being performed. The
Asset Operator shall be accountable for the asset
equipment being in a safe condition for the scope of
work to be performed. The Asset Operator or an
Asset Operator Designee (if used) is responsible for
completing the ATW form and monitoring the work to
verify ATW conditions are being met.
Asset Operator Designee A BP employee or contractor individual who is
authorized by the Asset Operator and approved by
the DOM to issue the ATW and / or permits on behalf
of the Asset Operator.

Credible Reasonable and believable


Hazard A source of potential danger that may lead to injury to
people or the environment
Job Site Within visual proximity of the work being performed.
Level 2 Hazards Identification A structured process to identify hazards and specify
and Task Risk Assessment actions to mitigate these hazards for a permitted work
(HITRA) activity or task
Risk The product of the probability that an identified hazard
will occur times the consequences of the occurring
hazard
Risk Control Measure A control is a precautionary measure taken to prevent
or reduce risk
Shall Shall is used where a provision is mandatory.
Should Should is used where a provision is preferred.
Simultaneous Operations Separate activities including product movement or
(SIMOPS) work tasks that have the potential to impact each
other.
Task An activity that forms part of the work scope – e.g. for
the removal of a valve the following tasks may be
identified: isolate the valve, verify system is drained
and depressurized, remove insulation, break
containment, remove the valve.
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 19 of 31

USPL US Pipelines and Logistics


Work scope The term used to describe the total/overall scope of
work activity – e.g. Replace a valve.
Workforce Any BP employee or contractor who is engaged in
performing work on behalf of USPL.
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 20 of 31

Appendix 2 - Hazards Identification Guide


This appendix is expanded from the BP Sources of Energy which are:
• Biological
• Body Mechanics
• Chemical
• Electrical
• Gravity
• Mechanical
• Noise
• Pressure
• Radiation
• Thermal
A - Hazards associated with plant and equipment
Category Type of Harm Examples of Hazards
Mechanical Trapping (crushing, pressing, Two moving parts, or one moving part and a fixed
drawing in and shearing surface
injuries) Conveyor belt and drive
V belt and pulley
Power press
Guillotine Scissors
Stapler
Using hammer
Hoist, crane
Impact (includes puncture) / Something that may strike or stab someone or can be
Mobile equipment struck against
Moving vehicle, machine, ship, aircraft – including
propellers and turbines
Drill, lathe
Pendulum
Crane hook or load
Contact (Cutting, friction or Something sharp or with a rough surface
abrasion) Knife, chisel, saw
Fan blade
Circular saw blade
Sanding belt
Abrasive wheel
Hover mower blade
Entanglement (rotating parts) Drill chuck and bit
Power take-off shaft
Pipe threading machine
Abrasive wheel
Ejection (of work piece or part Cartridge tool
of tool) Hammer and chisel
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 21 of 31

Category Type of Harm Examples of Hazards


Abrasive wheel
Abrasive blasting
Electrical Shock/burn/fire/ Electricity above 50v
Explosion DC electricity, especially batteries(Hydrogen gas)
Ignition sources when charging
Static
Batteries
Pressure Release of energy Compressed air
(Explosion/injection/ Compressed gas
implosion) Process fluid
Steam
Vacuum
Hydraulic system
Hydro Blasting
Stored energy Flying objects / Electrical / Springs under tension
Hydraulic / pneumatic Springs under compression
systems Turbine variable inlet guide vanes
Conveyor tension weight
Counterweight

Gravity Struck by Falling objects Overhead work areas / platforms


Work in attics
Closet storage
Items mounted or stored on ceilings or on walls
High rack storage areas (warehouse)
Hoist platform cage
Load carried by crane
Raised tipper lorry body
Thermal Burns / fires / scalds / Hot surface
frostbite Portable or fixed heater
Welding flame/arc
Refrigerant
Steam
Process fluid, heat transfer medium
Radiation Burns, cancer, sunburn, X Rays
Ionizing radiation melanoma, skin cancer  or  radiation
Neutrons
Ultra violet
Naturally occurring radio active materials (NORM)
Non ionizing Burns Micro wave
radiation Radio frequency
Laser
Infra red
Noise Hearing loss, tinnitus. Noise > 85 dB(A) continuous
Noise > 105 dB impact
Vibration Vibration white finger, whole Pneumatic drill
body effects Driving mobile plant
Using Jackhammer
Stability Crushing Inadequate crane base
Fork lift truck on slope
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 22 of 31

Category Type of Harm Examples of Hazards


Machine not bolted down
Mobile scaffold too high
Scaffold not tied
Overload/ Crushing Crane overload
Defective due to Chain sling
mechanical failure Eye bolt overload
Scaffold overload
Hopper overload
Structure overload, esp. extreme weather
FIRE/EXPLOSION Burns Timber stack
Combustion Paper store
Grease
Plastic foam
Increased Burns Oxygen enrichment
Combustion
Flammable Burns Petrol, diesel, avgas
substances (inc. Crude oil, natural gas
Highly and LPG
Extremely LNG
Flammable) Hydrogen
See also explosive Carbon Monoxide
below
Oxidizing Burns Organic peroxide, other oxidizing agents
substance Potassium permanganate
Nitric acid
Commercial explosive
Detonators
Gas explosions Burns, structural failure Flammable gas or liquid above its flash point in a
confined space
Similar in a congested area
Sudden failure of pressure system containing
flammable liquid (BLEVE)
Dust explosions Burns, structural failure Wood dust
Sulfur dust
Coal dust
Flour
Aluminum powder
HEALTH Skin, Eyes, Noise and Sulfuric acid, other acids – esp. hydrofluoric
HAZARDS Respiratory track effects Caustic soda, other alkalis
Corrosive/Irritating Ammonia, chlorine
materials
Sensitizing Sensitization, Fibrosis and Asbestos fibers
materials and cancers of the Lungs Silica dust
Particulates irritation/injury to eyes. Wood dust
Iron dust
Vapors Acute and chronic effects on Benzene
health Toluene
Acetone
Some solvents
Fumes Acute and chronic effects on Lead fume
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 23 of 31

Category Type of Harm Examples of Hazards


health (local and systemic Rubber fume
effects) Asphalt fume
Gases Acute and chronic effects on Carbon monoxide
health and death Hydrogen sulfide
Sulfur dioxide
Mists Acute and chronic effects on Oil mist, cutting fluids
health Printing ink mist
Detergents
Aerosols
Asphyxiates Acute and chronic effects on Nitrogen
health and death Carbon monoxide
Smoke
Argon
Health hazard by Burns to upper alimentary Corrosive liquids
ingestion tract
Poisoning Toxins
All harmful aerosols
Polluted water
Contaminated food and drink
Hazards by Cuts, abrasions Rough timber
contact Concrete blocks
Burns, Frostbite Molten metal
Also structural failure Frozen food
Cryogenic gases
ENVIRONMENTAL Sewage systems / Crude/Condensate & product sea & road
HAZARDS Groundwater / Soil transportation and storage
Biological / pollution/bio hazardous waste Storage of hazardous sludge/material in pits
Hazardous waste and sharps/influenza/malaria NORM waste (scales, sludge)
storage and Infectious and non-infectious diseases, parasites
disposal
Human Injuries, illness Shift work
Factors/Fatigue Work patterns
Driving
Poor ergonomically designed plant
Control/Alarm systems
Procedures

B - Hazards associated with materials and substances


Category Type of Harm Examples of Hazards
FIRE/EXPLOSION Burns Timber stack
Combustion Paper sore
Grease
Plastic foam
Increased Combustion Burns Oxygen enrichment
Flammable substances Burns Petrol, diesel, avgas
(inc. Highly and Extremely Crude oil, natural gas
Flammable) LPG
See also explosive below LNG
Hydrogen
Carbon Monoxide
Oxidizing substance Burns Organic peroxide, other oxidizing agents
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 24 of 31

Category Type of Harm Examples of Hazards


Potassium permanganate
Nitric acid
Commercial explosive
Detonators
Gas explosions Burns, structural failure Flammable gas or liquid above its flash point in a confined
space
Similar in a congested area
Sudden failure of pressure system containing flammable
liquid (BLEVE)
Dust explosions Burns, structural failure Wood dust
Sulfur dust
Coal dust
Flour
Aluminum powder
HEALTH HAZARDS Skin, esp. eye, effects Sulfuric acid, other acids – esp. hydrofluoric
Corrosive/Irritating Also lung effects Caustic soda, other alkalis
materials Ammonia, chlorine
Particles Lung effects Asbestos fibers
Silica dust
Wood dust
Iron dust
Vapors Acute and chronic effects Benzene
on health Toluene
Acetone
Some solvents
Fumes Acute and chronic effects Lead fume
on health (local and Rubber fume
systemic effects) Asphalt fume
Gases Acute and chronic effects Carbon monoxide
on health Hydrogen sulfide
Sulfur dioxide
Mists Acute and chronic effects Oil mist, cutting fluids
on health Printing ink mist
Detergents
Aerosols
Asphyxiates Acute and chronic effects Nitrogen
on health Carbon dioxide
Argon
Health hazard by ingestion Burns to upper alimentary Toxic, harmful, corrosive and irritant liquids
tract
Poisoning All harmful aerosols
Polluted water
Contaminated food and drink
Hazards by contact Cuts, abrasions Rough timber
Concrete blocks
Burns, Frostbite Molten metal
Also structural failure Frozen food
Cryogenic gases
ENVIRONMENTAL Sewage systems / Crude/Condensate & product sea & road transportation and
HAZARDS Groundwater / Soil storage
Biological / Hazardous pollution Storage of hazardous sludge/material in pits
waste storage and disposal NORM waste (scales, sludge)
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 25 of 31

C - Hazards associated with the place of work


Category Type of Harm Examples of Hazards
Pedestrian Access Tripping, slipping Damaged floors
Trailing cables
Oil, grease spills
Water on floors
Debris
Wet grass
Sloping surface
Uneven steps
Changes in floor levels
Pedestrian Access Vehicle collision Poorly defined or un-segregated access routes – car
parks, loading areas, docks, warehouses.
Work at heights Falls Fragile roof
Edge of roof
Work on ladder
Erecting scaffold
Hole in floor
Obstructions Striking against Low headroom
Sharp projections
Stacking/Storing Falling materials High stacks
Insecure stacks
Inadequate or overloaded racking
Stacking at heights
Damaged racking
Work over/near liquids, Fall into a substance, Tank
dusts. drowning, poisoning, Reservoir
suffocation. Sump
Sewer
Work over water / containment pits / ponds
Emergencies Trapping in fire Locked exits
Obstructed egress
Long exit route
Lone working at height (crane, tower.)
D - Hazards associated with methods of work
Category Type of Harm Example of Hazard
Manual Handling musculoskeletal Lifting / Lowering
disorders and injury, Twisting
(hernia, back Climbing
Carrying
Pushing / Pulling
Hot / Cold loads
Rough loads
Live loads – persons
Repetitive movements Work related upper limb Keyboard work
disorders Using screwdriver
Using hammer and chisel
Bricklaying
Repetitive and forceful work
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 26 of 31

Posture Work related upper limb Seated work


disorders, back Work above head height
disorders and injury, Work at floor level
deep vein thrombosis. Awkward and confining postures, constriction of lower
limbs and lack or movement
E - Hazards associated with the working environment
Category Type of Harm Example of Hazard
Light (NB: Also Eye strain, arc eye and Glare, reflections
increases risk of contact cataracts Poor lighting
to other hazards) Stroboscopic effect
Arc welding
Lasers
Molten metal
UV radiation
Temperature Heat / hyperthermia, Work in near/above furnace, boiler, or oven
cold / hypothermia Hot weather
stresses Heat index
Cold room or freezer
Outdoor work
Cold weather
Wind chill factor
Work in rain, snow.
Confined spaces Asphyxiation, explosion, Work in tank
poisoning, Chimney stack
claustrophobia. Pit, sewer
Basement
Unventilated room
Vessel
Excavation
Pollution/Poor air quality “Sick Building Fumes
Syndrome”, headache, Odors
rhinitis, sore eyes Second hand tobacco smoke
nausea, tiredness.
Flora / Vector-Borne Skin irritations / bites Poison oak / poison ivy
and Zoonotic Diseases Reptiles poisonous and non-poisonous
Small and large mammals
Insects such as mosquitoes

F - Hazards associated with work organization


Category Type of Harm Example of Hazard
All workers Injuries and ill health to Work above or near others
employees by Use of harmful substances
contractors Welding
Injuries and ill health to Process fumes
contractors’ by Services (e.g. underground electricity cables)
employees Stored hazardous materials
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 27 of 31

Organization of Stress Work/demand overload or under-load (and


work/management monotonous work)
Lack of control over job
Lack of support
Poor work relationships
Lack of role clarity
Change
Work in public area Injuries and ill health of Trailing cables
public Traffic/ Plant / Rig /Ship movement
Road transport
Work above public
Drilling, storage, production near dwelling area
USPL
Procedure No.: USPL-COW-490-001
Revision Date: 05/01/2020
Effective Date: 06/30/2020
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 28 of 31

Appendix 3 - Level 2 HITRA Process Map

WORK REQUEST

Notes:
IDENTIFY WORK
SCOPE TASKS
1) The numbers next to the step are
the step numbers of the procedure

DOES
INITIATE ATW NO TASK REQUIRE LEVEL
2 HITRA?

YES

FORM HITRA TEAM 8.1

IDENTIFY TASK
HAZARDS
8.3

8.4
IDENTIFY HAZARD
EFFECT
For each hazard

IDENTIFY
PROBABILITY OF 8.5
HAZARD EFFECT

8.5
DETERMINE RISK LEVEL

RISK STILL IN
VERY HIGH ZONE?
YES

RISK IN VERY IDENTIFY RISK


HIGH ZONE? YES IS RISK ALARP? NO CONTROL MEASURES
TO ACHIEVE ALARP

STOP NO 8.6

RISK IN
HIGH ZONE? YES IS RISK ALARP?

APPROVAL FROM
NO YES DISTRICT OPERATIONS
NOTIFY MANAGEMENT MANAGER
NO RISK IN
MEDIUM ZONE?
YES IS RISK ALARP?

APPROVAL FROM
NO YES TERMINAL MANAGER /
O&M TEAM LEADER
RISK IN
LOW ZONE?
YES IS RISK ALARP?

APPROVAL FROM LEVEL


TOOLBOX MEETING YES 2 HITRA TEAM LEADER
8.10
& 8.9
8.11
APPROVAL TO PROCEED

IMPLEMENT CONTROLS

EXECUTE TASKS

NEW HAZARDS NOTIFY ASSET


IDENTIFIED?
YES STOP
OPERATOR
8.12
NO
Appendix 4 - L2 HITRA Form

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