Hot Tapping - Need / Call to Action

Incidents Continue to Happen

• Incidents during hot tapping are sparsely reported or available.  
• The worst-case scenario during hot tapping is a burn-through during welding of the nozzle on a live piece of pipeline or equipment.  If the leaking fluid is flammable, it could immediately lead to fire and/or explosion with potentially catastrophic consequences.  
• Other fluids like steam and/or condensate, etc., at high temperature can cause serious injuries to personnel close to the hot tap location.

Maintain a Sense of Vulnerability

A Sense of Vulnerability is Healthy – Just because it has not happened yet (or here) does not mean it will not happen in the future!

• Is a sense of vulnerability a critical part of the mindset of every employee and contractor?
• Do you require consistency in practice from everyone in the organization?
• Do you have systems in place to determine if inconsistencies exist?
• Do people believe that “yes, it can happen here”?
• Do people believe that “yes, we have similar vulnerabilities”?
• Have you experienced similar incidents but without consequences (i.e., near misses)?
• Do you combat organizational overconfidence that can be stimulated by past good performance?
• Do discussions on potential vulnerabilities take place between operations and senior leadership?

Prevent Normalization of Deviation

Normalization of deviation is defined as…..

Signs of Normalization of Deviations – Does this describe your organization?

• If a deviation is absolutely necessary, are there defined steps that must be taken (i.e., a written variance procedure)?
• Do these defined steps (or variance procedure) require a detailed risk assessment and approval from multiple levels within the organization?
• Are your expectations clear that no one individual alone is permitted to determine whether a deviation is permissible?
• Do you allow operations outside established safe operating limits without a detailed risk assessment?
• Are willful, conscious, violations of established procedures tolerated without investigation or without consequences for the persons involved?
• Can employees be counted on to strictly adhere to safety policies and practices when supervision is not around to monitor compliance?
• Are you tolerating practices, or conditions that would have been deemed unacceptable a year or two ago? 
• Are all employees empowered to stop work for any situation deemed unsafe?

Evaluate Your Program

Do you audit your Hot Tapping program to ensure the program is yielding the intended results?

Do you routinely review the following items:

• Written Hot Tapping procedure?
• Hot Tapping permits?
• Roles and responsibilities of persons involved in Hot Tapping activities?
• Training and competency provided to persons involved in Hot Tapping activities?
• Hazard assessments performed before Hot Tapping activities are conducted?
• Job observations performed on Hot Tapping activities?

Have you audited your Hot Tapping permits and discussed the results of the audits?  Was there evidence that:

• Permits were not completely filled out?
• Permits were not signed?
• The permit writer was not trained?
• Permit conditions were not communicated within the subject work team?
• Work was not coordinated between work groups (permit writing group vs. group(s) that perform the work?
• Work extended beyond the authorized period of time?
• The work area covered by the permit was too large?
• Certain technical provisions of the permit were not followed?
• Gas detection was not performed properly or continuously?
• Emergency response measures were not in place?

Have you evaluated your Hot Tapping audit program?

• To ensure the quality of the audit process (i.e., protocols, sampling strategies, etc.)?
• To ensure the competency levels of the auditors?
• Does your Hot Tapping procedure reflect the desired intent and is this intent adequately detailed in procedural instruction?
  
  • Is the “goal” of your program to complete the permit or to use the permit as a tool to facilitate the execution of safe work?
• Does the execution of the procedure yield the intended results?  Are you evaluating your program for:
  
  • Procedural Compliance – are actions and tasks in compliance with procedural requirements?  (Paper Control), and
  • Program Health – is your system providing the intended results?  (Actual Execution)                                                                                                                    

• Do you know of any site or company incidents related to Hot Work?
  
  • Have you discussed the results and causes within your organization?
• Do you know of any site or company near misses related to Hot Work?
  
  • Have you discussed the results and causes within your organization?

Continually Improve Your Program

Are you considering improvements to prevent future incidents?  Here are some ideas you may want to consider:

• How frequently do you review Chemical Safety Board (CSB) reports, CCPS Process Safety Beacons, and other relevant incident communication having learning potential with all members of the organization?
• Do you track specific hot tapping -related metrics that can be used to determine program effectiveness and improve performance?
• Have you benchmarked your program against other programs in your industry?
• How often do your senior managers visit the field to watch hot tapping in action?
• Do you have a requirement to periodically update your program?
• Do your workers (those closest to the work), have an easy method to suggest improvements to your program?

Organizational Culture

A successful Hot Tapping program depends on the actions of individuals within the organization.  Do the values and behaviors of your organization determine the manner in which your Hot Tap program is managed and executed?

• Does management and supervision reinforce desired behaviors to ensure they become integrated into the group’s values?
• Are high standards of Hot Tapping performance clearly established?
• Is open and effective communication encouraged and supported?
• Has management established safety as a core value?
• Does management and supervision provide strong leadership?
• Has management formalized the safety culture emphasis and approach?
• Does management work to ensure employees maintain a sense of vulnerability?
• Are individuals empowered to successfully fulfill their safety responsibilities?
• Does management ensure open and effective communication exists?
• Does management support and foster mutual trust?
• Does management establish and enforce high standards of performance?
• Does management defer to expertise?
• Has management established a questioning / learning environment?
• Does management require timely responses provided to safety issues and concerns?
• Does management provide continuous monitoring of performance?