andybz wrote:Let's look at the specific requirement to 'test the isolation' of an oil valve, which you say is like asking how will you know a tap is turned off?
If the valve is on a short section of open ended pipe, you are probably correct. But, if it is on a closed section of pipe or there is any chance of it seeing pressure upstream, it is a very valid question and entirely consistent with the requirements of HSG 253 'Safe isolation of plant and equipment.'
http://www.hse.gov.uk/pubns/priced/hsg253.pdf This is exactly what I mean about not knowing the work involved.
The valve in question (one of 10 in fact) is an isolation valve to remove a piece of equipment. The valve is IMMEDIATELY next to where the joint is broken.
There is NO way of checking the valve is sealing properly (some of these valves have NEVER been closed in 20 to 30 years, honestly) until you physically open the joint and see if oil comes out.
Hence why the standard procedure, industry wide, is to use drip mats, rags, buckets etc. under the joint when it opens.
So again, we come back to the consultant NOT understanding the process, NOT understanding the industry, NOT understanding the plant in question. But feeling free to criticise our working practices without any consultation with ourselves or the client.
Oh and feeling free to charge the client lots of money for work they obviously don't understand.
"The President of IOSH identified the tendency of risk assessments to be continually added to, and hence keep growing until they become unmanageable..."
Which is what has happened here. My RA went from 4 pages of relevant, significant hazard identification and controls, to 15 pages! Covering things like how to protect the public from dust getting on their cars!
And this is on a secure site with no public access!
I fully agree that HSE guidance, ACOP's, Regs etc are there for a reason.
However, they don't all fit every situation.
There are some good consultants, I've used a couple myself for more specific technical issues, and some who do ask for advice, clarification, offer suggested alterations to documents. I just wish more would...