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BP MAINTENANCE WORK INSTRUCTIONS – FREQUENTLY ASKED QUESTIONS

The following FAQ was last updated 30/3/2016. This material is guidance only. If any of the content contradicts with
requirements within the specific BP authorised work instruction, BP procedures, or legislation then the work instruction,
procedure, or legislative requirement shall override this document.

EVERYONE HAS THE OBLIGATION AND AUTHORITY TO STOP UNSAFE WORK

Q: What deems a person competent to monitor the gas detector after the person trained to
MSAPMOHS217A - Gas test atmospheres has completed the Gas Test Checklist?

A: This is documented within the Pre-requisites (page 3) of each Work Instruction


for which gas testing is a requirement. It states “Any person deemed responsible for
monitoring a gas detector during the work shall, as a minimum, have received instruction
from a person competent in the above course to inform them of the location of the gas
detector for monitoring, the alarm settings of the unit, and what to do in the event of an
alarm sounding. “

Q: Do contractors need to provide BP their gas testing qualifications? Some used to upload
these to KRS.

A: Unless told otherwise by BP Procurement (Kate Atkinson), contractors required to be


accredited should continue to follow any contractor accreditation
requirements. However, it should be noted that contractor accreditation requirements are
separate to Control of Work requirements. Control of Work requirements with respect to
gas testing competencies are detailed within the Pre-requisites (page 3) of each Work
Instruction for which gas testing is required:

• Any person conducting gas testing in accordance with this work instruction shall have
successfully completed MSAPMOHS217A - Gas test atmospheres
• Any person deemed responsible for monitoring a gas detector during the work shall, as a
minimum, have received instruction from a person competent in the above course to
inform them of the location of the gas detector for monitoring, the alarm settings of the
unit, and what to do in the event of an alarm sounding.
With respect to record keeping of the competencies in the Work Instruction, and any
additional competencies such as gas testing that are required within the work instruction,
the following Pre-requisite (page 3) exists in each Work Instruction:

• Persons performing the task shall be trained and competent in this procedure with training
records kept by their employer and available for audit on request.
The above clause will include requests for evidence of external gas testing qualifications
where these are required within the Work Instructions. This is aligned with current
practices where BP may ask for evidence of other competencies for work being
conducted by contractors for BP (e.g. high risk licences, confined space entry, etc.).

BP is planning to increase the verification of work being undertaken to provide assurance


that contractors comply with requirements and are managing the risks, irrespective of
whether the work is being undertaken under a WPCG Work Clearance, BP Work
Instruction, or BP Work Permit.
Q: Can I use a battery operated hand tool that has a spark within it under WI-MT-003 Use of
Battery Operated Hand Tools?

A: A Hot Work Permit is required for all hot work that involves the use of or creation of
flames, sparks or energy discharge inside hazardous areas. This type of work includes
burning, welding, grinding, air arcing, soldering, open flame, stress relieving, preheating
or any similar activity that creates an uncontrolled ignition source. A key word here is
uncontrolled. Some hand tools may have the potential for sparks within it. These may
be used under the work instruction (if not one of the examples listed above as requiring a
permit). It is considered that equipment that creates sparks in an uncontrolled way, e.g.
grinders and other similar tools, poses a higher risk of ignition (e.g. of any residual fuel in
the area) and therefore must be authorised by a Hot Work Permit.

The work instruction may only be used for spark potential activities. This type of work
includes battery-powered equipment (not certified for use in classified hazardous areas)
such as: electrical test equipment, cordless drills, inspection and survey tools, digital
cameras, hand-held instruments.

Note also this work instruction only applies to battery operated hand tools, and not to
mains powered equipment or other plant that may be electrically powered. Due to the
potential diversity of such equipment and the energy they may store or generate, at
present these are also considered higher risk than battery operated hand tools. Hot Work
Permits are required for mains powered equipment and any battery operated equipment
that is not a hand tool.

Q: What gases are the gas detectors testing for?

A: As the gas testing associated with WI-MT-002 and 003 are with respect to the risk of a
flammable atmospheres rather than for a particular atmospheric contaminant that may
pose a health risk, the gas detectors will need to test for (as a minimum) LEL, and O2.
These fields are required on the Gas Test Checklist that is required to be completed in
support of the work instruction. If your company JSA/SWMS identifies other risks
requiring testing, e.g. CO from exhaust emissions (if applicable) then this would be still
required by your own risk assessment associated with the work. Such risks are
considered Task Hazards and are outside the scope of the work instruction. As such they
are not required on the Gas Test Checklist to ensure safe use of the equipment in the
hazardous area with respect to site and process hazards.
Q: In regards to the training, does it need to be “professional training”?

A: Training should be conducted in accordance with your BP Accredited company processes


to ensure that it is implemented sustainably and to a level sufficient to ensure that
personnel are competent in the work instructions. Verification by BP will be conducted to
confirm personnel in the field are competent and compliant. Contractors should have
their own existing verification/audit processes of their own work to ensure your own
workers are competent and compliant in not just this but other requirements of both your
own organisation, BP or local legislation. This should provide feedback as to whether
training implemented is adequate. BP does not mandate that all training shall be
conducted by a person with a Certificate IV in Training and Assessment, for example our
Issuing Authority training is presently not. However, the specific gas testing training
module is specified in the work instructions to which it is relevant (WI-MT-002 and 003)
shall be conducted by a registered training organisation (RTO) approved to deliver this
unit of competency. These can be found at http://training.gov.au/

Q: Do I still need a hot work permit?

A: If you are trained and competent in the Work Instruction/s relevant to your work, and you
comply with all the requirements including the scope, equipment, and controls (including
gas detection and the associated recognised training prescribed) then you do not need a
BP Hot Work Permit. A WPCG work clearance is still utilised to authorise the work and
communicate it to the site representative. NOTE: If you are not using the work
instruction, or you are not trained in it, or you want to vary some of the scope or
controls required, then you need a Hot Work Permit for all Hot Work in the
Hazardous area.

Q: If I am experienced in the use of a gas detector, do I still need the training prescribed?

A: Yes you do. This gives BP assurance of your level of competence. It is not practical or
sustainable for BP to directly review every single contractor’s experience, skills and
competence. This nationally recognised training provides BP assurance, and gives you
and your organisation the same level of assurance of your competency and the quality of
training provided to you. As it is nationally recognised, it is also typically transferrable to
other work for other organisations that you may service.
Q: Do I still need a Ground Disturbance Certificate or a Ground Disturbance Checklist?

A: You do not need a Ground Disturbance Certificate or a Ground Disturbance Checklist IF


you are trained and competent in the Work Instruction WI-MT-004, and comply with all
the requirements including scope, equipment and training. A Ground Disturbance
Certificate or a Ground Disturbance Checklist remains required for non-routine tasks
and any other tasks not within the scope of WI-MT-004, or if you wish to deviate
from any requirements of WI-MT-004, or if you are not trained in the work
instruction. Note if you are using battery operated equipment within the hazardous zone
to drill into concrete or use of a battery operated service locator under WI-MT-004 then
you also need to use WI-MT-003 and comply with all requirements including the external
gas testing qualifications.

Q: Why don’t I need a permit of certificate for this work anymore?

A: Permits are for non-routine work, or work that is not considered low risk. A separate
stream of work (low risk routine work) may be controlled with a documented risk
assessed procedure authorised by BP (i.e. a BP Work Instruction). BP has now authorised
the use of some work instructions for specific routine maintenance and construction
tasks that have been assessed as low risk if the controls required within the work
instruction are implemented, and the person is trained in the work instruction. Within
these work instructions the WPCG work clearance remains as the method to
communicate to the site representative and have them authorise the work at the work
site. A specific task may still be escalated to a Work Permit or Certificate if it is deemed
necessary to safely control the work. EVERYONE HAS THE OBLIGATION AND
AUTHORITY TO STOP UNSAFE WORK

Q: There is no cross reference from the Gas Test Checklist to my JSA. Why not?

A: The existing WPCG Work Clearance Form must reference the contractor JSA, the work
instruction and the job number. The Gas Test Checklist also requires the Job No. to cross
reference to the WPCG form as the WPCG form itself does not have a number.
Referencing a WPCG form number would possibly have been better but that does not
exist. This way there is an auditable trail between the Gas Test Checklist and the WPCG
Form (via the Job No.); and direct cross referencing on the WPCG form of both the work
instruction and the JSA. Through this, all these documents (WPCG form, work
instructions, JSAs, and Gas Test Checklist) have an auditable trail to cross reference
between each other.
Q: With regard to the new Retail Work Instruction – Use of Battery Operated Hand Tools in
Hazardous Zone, it says that one of the pre-requisites is that the person carrying out these
works must have successfully completed MSAPMOHS217A. We have already completed
RIIWHS202D which includes a component on using a gas detector, and have also done
BA training with Fire and Rescue, are we able to carry out works under this new Work
Instruction without doing the MSA module?

A: No. You must complete MSAPMOHS217A as specified. The BA and Rescue training is
not relevant to gas testing. Also, the RII Confined Space Course, whilst a nationally
recognised unit of competency, is significantly different with respect to training in gas
testing.

Elements and Performance Criteria for each unit:

• RIIWHS202D - Enter and work in confined spaces only lists the following relevant
element:
2.2 Ensure that the atmosphere is tested and monitored for harmful elements

• MSAPMOHS217A - Gas test atmospheres requires

1. Prepare for gas testing. 1.1 Determine type of gas/atmosphere to be tested.

1.2 Select and calibrate equipment in accordance with procedures.

1.3 Determine gas testing regime/sampling pattern required.

1.4 Identify hazards from possible atmosphere contaminants.

1.5 Implement hazard control measures, including use of appropriate

personal protective equipment.

2. Test gas. 2.1 Use gas testing equipment to test gas as required.

2.2 Interpret and report readings.

2.3 Monitor gas on an ongoing basis as required.

2.4 Take required action(s) if readings are unacceptable.

3. Maintain equipment. 3.1 Clean and maintain gas testing equipment in accordance with

procedures.

3.2 Inspect and fault find monitoring equipment in accordance with

procedures.

3.3 Return gas testing equipment to required location and in required

condition.

3.4 Maintain records of tests and results in accordance with procedures.


Q: Does WI-MT-002 Entry of Mobile Plant into Hazardous Areas include the use of
generators?

A: No. Mobile Plant covered by this Work Instructions, does not include portable
equipment such as generators. (Powered) Mobile Plant is defined in the Model WHS regulations,
Victorian OHS regulations, and in a bulletin from the WA regulator (in lieu of no definition in their
regulations). This is as follows:

“powered mobile plant means plant that is provided with some form of self-propulsion that is
ordinarily under the direct control of an operator.”

The intent of not including all other plant in this work instruction is:

• Addressing efficiencies of the highest frequency, low risk routine maintenance activities
as the highest priority.
• The ability to quickly turn off the ignition source as there is an operator situated at the
controls when in operation (unlike some other equipment like a generator which may be
nearby but not within arm’s reach).
• Hierarchy of control: maintain the current incentive to locate this equipment outside the
hazardous area under the lower requirements associated with a typical WPCG work
clearance. This eliminates the ignition source from the hazardous area.

Q: What gas detectors does BP require?

A: BP does not mandate a particular make and model of gas detector. To be used to
conduct the gas testing associated with completion of the Gas Test Checklist is does need to be
rated for the hazardous area in which it will be used, within current calibration and “bump
tested” prior to use. AS/NZS 60079.29.2:2008 Explosive atmospheres Part 29.2: Gas detectors—
Selection, installation, use and maintenance of detectors for flammable gases and oxygen is
available to support your selection decision.

BP presently supplies BP employee Issuing Authorities with the Impact Pro, manufactured by
Honeywell and supplied locally through ThermoFisher. If you are considering purchasing (or
hiring) your own gas detectors here are some points to consider, other than the obvious things
to check like hazardous area rating, alarms (visible and audible), and gas sensors in the unit:

If you are considering purchasing (or hiring) your own gas detectors here are some points to
consider, other than the obvious things to check like hazardous area rating, alarms (visible and
audible), and gas sensors in the unit:
• What calibration gas do you require? The Impact Pro has an advantage here over most
models as you can calibrate for LEL on methane and then change the calibration curve
electronically to octane (typically representative of petrol). On most models you should
choose a calibration gas bottle with a gas with similar LEL calibration curve to the
materials you wish to detect. This may be something like Pentane or Hexane which
have similar curves to Octane but are less readily available and likely higher cost in
comparison to methane. Methane (typically used) may not be representative without
using correction factors. The recently issued BP Work Instructions require 0% LEL. This
provides greater assurance to BP in the event contractors calibrate a unit other than the
Impact Pro with methane. When calibrated on methane the unit may read low (by a
factor typically between 1.5 and 3) if testing for presence of petrol vapour (e.g. octane).
We have not mandated in the Work Instructions with which gas the unit has been
calibrated or the use of correction factors on readings calibrated with methane (i.e.
0%LEL x 3 is still 0%LEL).
• Does it have a pump or ability to affix one? This is not mandatory for the Work
Instructions but would be needed for use with the initial issue of BP Work Permits at
times to test in vessels, pits and drains prior to BP authorised Issuing Authorities issuing
a Hot Work Permit or Confined Space Entry Permit. Or is it a “passive” unit than has no
such pump capability?
• How rugged is the unit? Impact Pro has shown it can withstand a lot. Impact Pros have
lasted over 10 years. Many cheaper units may only last a couple of years.
• Weight. They can vary. Impact Pro is mid-range. Others are significantly heavier, some
a smaller and much lighter.
• Servicing. Can you readily service yourself to change sensors when required by the
manufacturer? Again, an advantage it seems for Impact Pro where it has a design that
enables you to change the sensor cartridge more readily if you wish to do it
yourself. Most other units would need to be sent back causing some delays and
additional costs (possibly even the purchase of spare units to cover whilst the others are
being serviced).
• How easy is it to calibrate? (calibrate, not just bump test) What support do you get to be
shown how to do this? Or do you need to send it away to be calibrated every 6 months?
At what cost? Again, does this mean you would need to buy an additional unit to use
during the period you have sent it away?
• How long do sensors last? Often common duration across different models, but may
vary. Parts can be expensive and supply can be slow. Some units you simply buy a new
one when sensors expire rather than incur a similar cost for sensor replacement and
calibration.
• Can you bump test to confirm operation prior to use? This is required by the Gas Test
Checklists associated with BP Work Instructions, and Gas Test Certificates associated
with BP Hot Work Permits and BP Confined Space Permits. It is strong recommended
by AS/NZS 60079.29.2:2008 Explosive atmospheres Part 29.2: Gas detectors—Selection,
installation, use and maintenance of detectors for flammable gases and oxygen.
• If it can be calibrated, but cannot be bump tested, this type of instrument may be what
AS600079.29.2:2008 refers to as a “Small, hand-held apparatus” that “may be used for
leak-detection or spot checks,” rather than for use in a “multi-role mode so as to include
leak detection, spot checking and local area monitoring functions”. If they are unable to
comply with the BP requirement to be bump tested they cannot be utilised to perform
testing associated with BP Gas Test Checklists or Gas Test Certificates.
• If you can’t bump test or calibrate it then it may fundamentally be a “personal monitor”
rather than gas detector. Some of these you just turn on and it lasts for a year or two
without verification of accuracy other than a self-diagnostics without gas
injection. Some units such as those worn for H2S in some industries (like Bitumen
plants) are like this but these are typically not used to gas test the area prior to work, but
are supplementary confirmation of safe levels of exposure at the worker breathing zone.
Such instruments cannot be utilised to perform testing associated with BP Gas Test
Checklists or Gas Test Certificates.