Level 2 Hazards Identification and Task Risk Assessment (HITRA) Procedure
Level 2 Hazards Identification and Task Risk Assessment (HITRA) Procedure
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
Level 2 HITRA Procedure
Revision Number: 4.1
Page: 2 of 31
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.
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: 4 of 31
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
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: 5 of 31
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
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: 6 of 31
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:
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: 8 of 31
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.
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)
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: 10 of 31
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
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: 12 of 31
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
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: 14 of 31
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?
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: 15 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
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.
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
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
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?
IMPLEMENT CONTROLS
EXECUTE TASKS