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roshqse  
#1 Posted : 23 February 2015 13:27:55(UTC)
Rank: Forum user
roshqse

Hello folks.
I'd like some opinions on this please....
We have been instrcuted by clientg that our welder , when working atheight, on a scaffold must also wear a harness and fal restraint lanyard. i.e a short line.

The welder will be welding on a equipment filled with oil, and although there is very low likelihood, there is a risk of breakthrough of the thin walled equipment and subsequent oil loss being ignited.
The oil cannot be removed incidentally, and in any case would only heighten the risk of ignition.
Our welder does not want to wear a lanyard for reasons of mobility for the work at hand, entaglement risk of welding lines and lanyard, no risk of falling from height as the scaffold is proper and fitted with all neccessary toeboards, rails etc.
My personal concern is also one of escape in the event of a fire or oil loss. My concern is if he had breakthrough and oil loss which ignited, he would be in the firing line, so to speak.

The client is adamant that at height everyone must wear a harness etc. regardless of risk of falling.
So I am basically placing the risk of ignition and fire above that of falling.
Am I being reasonable? Overly concerned?

As an aside, this to me appears to be another case of people being put AT risk because of blind implementation of a rule which hasn't been thought through. But if we don't do it, we don't get the work.

Steve e ashton  
#2 Posted : 23 February 2015 13:59:47(UTC)
Rank: Super forum user
Steve e ashton

No - you're not being unreasonable - you are absolutely right. Another case of a client having a blinkered, opaque view of the reality of the world of health and safety at work. Unfortunately, unless you can convince the client to change his unreasonable insistence on a piece of nonsense - you must either accept his instruction (and hopefully get it well documented to protect your own employer in the event it all goes pear shaped) or - hold to your principles and refuse the work on the basis that your risk assessment shows the clients dictated method of work places your men at unacceptable risk. The latter is the morally courageous but commercially difficult option.
Steve
firesafety101  
#3 Posted : 23 February 2015 14:06:37(UTC)
Rank: Super forum user
firesafety101

Are you "hot" welding? If so have you considered the oil heating up and vapourising, that vapour will ignite more readily.

Is there a vent for the vapour to escape and is it away from your hot works?

You may have an explosion hazard there?

bob youel  
#4 Posted : 23 February 2015 14:07:49(UTC)
Rank: Super forum user
bob youel

Talk to the clients H&S bod [if that have one] to sort things out as welding, especially high quality welding, is completely different to 99% of other occupations where dexterity is concerned especially on a scaffold where the welder is blind when welding which is completely different to other trades and noting that 1 slip will ruin the weld irrespective other things that could happen so the client needs to consider poor quality and even fire over the risk of a fall [which sounds like a very small risk in any case in this situation]

I have come across such things many a time as the vast majority of clients and designers in CDM are looking at civil/building works as against engineering construction e.g. we always had scaffolder's on hand when high pressure welding took place should the scaffold need changing as the welders position changed especially when 'rooting' yet clients without knowledge could not understand the need and extra cost

Additionally few CDMC's, even H&S bods and CITB have a suitable understanding of engineering construction and its specific needs and hazards

listen to Steve e-a as he has good points and your MD needs to step up to the mark as well - it may be that your clients just needs educating
jay  
#5 Posted : 23 February 2015 14:30:57(UTC)
Rank: Super forum user
jay

The mandatory use of fall protection PPE (Harnesses & lanyards)despite working from "proper" scaffolds by some clients leaves a lot to be desired. Many of these are multinational Oil & Gas/Refining/Chemicals companies and they have equivalent of so called "life saving rules" and working at height is one of them! Unfortunately, they tend not to make any allowances.


http://www.shell.com/glo...iety/safety/culture.html




PIKEMAN  
#6 Posted : 23 February 2015 14:46:32(UTC)
Rank: Super forum user
PIKEMAN

I would agree that the fire risk outweighs the WAH risk - how can you fall off a properly built scaffold?

Having managed situations like this, I would advise consideration of emergency egress - if there is a fire, a ladder won't do, you might need stairs or ramp access. Remember -"WHAT STEPS DO YOU TAKE IN THE EVENT OF A FIRE ! ANSWER - "BIG ONES IN THE OPPOSITE DIRECTION! Corny but gold plated advice.
roshqse  
#7 Posted : 23 February 2015 14:56:20(UTC)
Rank: Forum user
roshqse

Thanks for the opinions folks.

Steve - " The latter is the morally courageous but commercially difficult option. " - particularly in this instance because the project is in Mexico! There is other work to be getting on with but this will be a showstopper unless we can sort something.

Firesafety - It's stick welding but still generates a lot of heat. We keep the plant full of oil for the reasons you say. No vapour, no pressure build up. There's no explosion risk.

Bob - It IS their H+S bod who wants this!

Jay - This is a multi-national and their rules , like you say, don't make a lot of sense.

Thanks folks, was just conecerend I was being overly cautious and getting wound up over nowt!
roshqse  
#8 Posted : 23 February 2015 14:58:27(UTC)
Rank: Forum user
roshqse

Thanks Pikeman. I'm thinking the only way to get round this is to make it difficult for them. By insisting on a staircase, alternative egress route etc.

In reality the risk of fire is VERY VERY small.. but it's still there and outweighs the risk of falling for the scaffold.
It's not like he's running up and down and climbing on things!
Donnison36946  
#9 Posted : 23 February 2015 15:56:25(UTC)
Rank: New forum user
Donnison36946

There seems to be three issues here, one is your welder’s concern about entanglement and ease of movement, another is the Client’s WAH rules and then there are your concerns about breaking through and causing and explosion or fire that you would have to escape from.
You need to risk assess all of them and come up with a combined safe system of work, that might allow you to remove the requirement to wear a harness.
Unfortunately I don’t see how your method (with or without harness) can be considered to be safe if you think there could be a risk of breaking through the vessel, which could result in a fire necessitating an emergency evacuating of the area!
If indeed your method of work needs you to take emergency escape action then this should all be thoroughly planned along with the client and the local Fire brigade!
I would suggest that a 'Petroleum Oil and Lubicants' Permit to work incorporating hot work are required as part of a safe sytem of work.
roshqse  
#10 Posted : 23 February 2015 16:30:01(UTC)
Rank: Forum user
roshqse

Donnison..
You're right, there are 3 issues. Actually 4 ..

The method of work we proposed the client accpeted.. until we got there! Then as usual moved the goal posts.

The method of working we have is safe. The equipment is FULL of oil and cannot ignite unless there is breakthrough and oil escapes, and even then the oil is difficult to ignite. Its not a high hydrocarbon. (We have had clients before who wanted the oil removed thereby leaving oil vapour inside.) Fire protection is in use, flammas cleared from the area etc. That's not the problem.

The site have issued a hot work permit and have NO issue with the welding and residual risk of fire. But they DO have an issue with a welder falling off a scaffold!
But can't actually explain HOW he could fall off the scaffold and don't have their own risk assessment.

The requirement and justification to remove the harness is the simple fact it is on a scaffold. There is NO need for the harness as far as we are concerened. It was US who specified a scaffold rather than a MEWP. (Which is what they suggested based purely on cost.)

The local fire brigade don't exist, its in middle of nowhere in mexico. And to be honest they wouldn't get involved even in this country. (I'm ex service.. been there done that).

Having done our risk assessment, both here and on site, the residual risk is the fire risk, no matter how small.
bob youel  
#11 Posted : 23 February 2015 18:19:46(UTC)
Rank: Super forum user
bob youel

Donnison's quote also needs looking at """Unfortunately I don’t see how your method (with or without harness) can be considered to be safe if you think there could be a risk of breaking through the vessel, which could result in a fire necessitating an emergency evacuating of the area!"""

Noting that this could be seen as a 'hot-tap' (as called in my day) situation e.g welding when lines are live - if nobody has any experience of hot-taps I suggest work is stopped unless an expert is called in

Put all your concerns on paper especially the area dealing with the clients H&S bod and your comments to your MD and the client

best of luck
David H  
#12 Posted : 23 February 2015 19:24:33(UTC)
Rank: Super forum user
David H

If the client thinks the W&H is the main risk then quote the Regs at them - risk assessment, rescue team etc.
That should push them to realise that the W&H is not the issue.

As for you - if you reckon the pipe is below retiral thickness and you could breach it - walk away till its degassed.

David H
Ian Bell  
#13 Posted : 24 February 2015 10:10:28(UTC)
Rank: Super forum user
Ian Bell

David H - there is little point in quoting the WAH regs - post #7 has indicated the work is taking place in Mexico, so UK regs mean nothing.

I would suspect that the Mexicans may well use American OSHA guidance, which tends to be more prescriptive than UK guidelines.
roshqse  
#14 Posted : 24 February 2015 10:14:52(UTC)
Rank: Forum user
roshqse

David, Bob, I have put it all in writing and we are negotiating with the client.

The WAH regs are irrelevant as the work is in Mexico. We are working under their Federal Regs regarding Safety. These aren't so clear cut as ours or prescriptive.

The rules being employed in this case are purely the clients internal rules.

The equipment is not a pipe under pressure or filled with highly flammable materials. And due to the nature of the equipment it cannot be emptied as this would involve specialist equipment, which is unavailable in the area, time we don't have and only intriduce a whole new raft of risks.
And even if we did it would only allow a vapour filled atmosphere to exist which could become flammable / explosive.

The safest method is to do it filled. (This is proven and common practice). THIS is the safest method, trust me, we've been doing this a wee while now!


Donnison36946  
#15 Posted : 24 February 2015 12:28:03(UTC)
Rank: New forum user
Donnison36946

Hi Roshqse
I can appreciate your problem and as such I felt I should respond to your comments, particularly “My concern is if he had breakthrough and oil loss which ignited, he would be in the firing line, so to speak”.
Obviously since then you have got a lot of good responses to your post which hopefully have been helpful to you in deciding how to eliminate or minimise all the hazards involved in carrying out your work.
Regards
mssy  
#16 Posted : 24 February 2015 19:17:13(UTC)
Rank: Super forum user
mssy

If the guy can't wear the lanyard as it would impede his escape, why not beef up the handrails and other safety features on the scaffold to make it more difficult to fall when not wearing fall protection?
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