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UK and EU rules

HSG253 Safe Isolation Shutdown: UK and EU Rules

Short answer

HSE guidance HSG253 sets three isolation categories for shutdown work, positive, proved and non-proved, and says to plan intrusive maintenance for shutdown periods; COMAH 2015, the UK form of Seveso III, applies to sites by their dangerous substances. This page maps those rules to the work you plan.

How MaintWiz helps: Safe isolation depends on records that match the work. The MaintWiz shutdown module shows permits and isolations from ePTW on each work order and blocks closing a package while a permit or isolation is open. See the module · Get the permit register

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What MaintWiz adds:Permits and isolations from ePTWShown on each work orderPackage cannot close with an open permitApprovals by signed-in user

HSG253

What does HSG253 require for isolation during a shutdown?

HSE guidance HSG253 sets three categories of isolation for work on process plant, positive, proved and non-proved, says to minimize isolation needs by planning intrusive maintenance for shutdown periods, and requires the choice of method to rest on a risk assessment. 1

HSE says any intrusive activity could allow hazardous substances to escape, that adequate isolation is critical to avoiding loss of containment, and that isolation requirements should be minimized where practicable by planning intrusive maintenance for shutdown periods. 1 The three categories are shown below; the guidance says the methods within a category do not all give equal security and the choice should rest on risk assessment. 1

HSG253 isolation categories
CategoryMethodWhat it isHSE note
I: positive isolationPhysical disconnection (for example spool removal); double block, bleed and spade; single block and bleed and spadeComplete separation of the plant to be worked on from other parts of the system; valved isolation of an appropriate standard is needed while the positive isolation is installedA very high standard for vessel entry; good practice for confined space entry, toxic fluids and extended isolations
II: proved isolationDouble block and bleed (DBB); double seals in a single valve body with a bleed in between; single block and bleed (SBB)Valved isolation whose effectiveness can be confirmed through vent or bleed points before intrusive work startsMechanical security is greatest for DBB and lowest for SBB; as a general rule SBB should not be the final isolation for work on live plant with hazardous substances, unless a risk assessment accepts it
III: non-proved isolationDouble valve; single valveValved isolation with no provision to confirm that the valves are effective before breaking into the systemWhere possible, use double valve rather than single valve

HSE notes that all isolation methods can fail, even positive isolations, particularly during installation and plant reinstatement, and that human failure is a major factor in reliability. 1 It adds that a positive isolation is good practice for confined space entry, toxic fluids and extended isolations, and that physical disconnection should be used where reasonably practicable because removal of a spool is simpler to monitor than a correctly installed spectacle plate. 1

Proving

How does HSG253 treat proving and removing isolations?

HSG253 says to prove both the initial valved isolation and the final isolation of a positive scheme, not to rely on an isolation that cannot be proved, and to check vents or drains behind a blank before removing it. 1

A free Excel version is available: Isolation method and proving checklist (HSG253) (.xlsx).

Proving and removing isolations (HSG253)
TopicWhat HSE says
Proving a positive isolationThere are two stages of testing: prove the initial valved isolation and the final isolation; the procedure must specify the arrangements, the success criteria and the test pressure
When an isolation cannot be provedDo not rely on it; extend the isolation boundary or defer the work until shutdown, and consider a plant modification to add test facilities
Short-duration workA less secure method can be used only where the overall risk of using positive isolation, including installing and removing it, is greater than the risk of the less secure method
Removing a positive isolationHazardous substances can build up behind a blank or spade if a valve leaks; check vents or drains before it is removed, and stop work if a leak is found
PaperworkUse isolation certificates and similar documentation to record the isolation

See the permit to work guide for the isolation register and blind list.

The rows paraphrase paragraphs 132, 133, 166 to 168, 186 and 187 of HSG253.

Software

Can software support UK and EU shutdown safety?

Software cannot choose an isolation method, but it can keep the permit, the isolation points, the proof readings and the sign-offs in one record, so the evidence the guidance expects is easy to find.

About MaintWiz. MaintWiz is an industrial AI platform with IoT, SAP integration and predictive maintenance (PdM) capabilities. Its shutdown and turnaround module helps plants plan, schedule, execute and close out shutdown work.

What the shutdown module covers

As described on the MaintWiz shutdown maintenance product page.

  • Permits and isolations from ePTW shown on each work order, with a block on closing a package while one is open
  • Work order tasks with readings, limits and photos as proof of isolation steps
  • Readiness gates with signed waivers and sign-offs with the name and date
  • Preventive maintenance scheduling and instruments and calibration shared with the platform
  • Handover note and as-left summary on each work order
  • Approvals recorded against the signed-in user with the name and the time

COMAH

Does COMAH apply to shutdown maintenance?

COMAH applies to a site because of the dangerous substances it holds, not because of an activity, so a shutdown at a COMAH site happens under the site's major accident prevention policy and safety report, which cover operational control and management of change. 2

COMAH 2015 in brief (HSE description)
ItemWhat HSE says
What it implementsThe Seveso III Directive, except land-use planning, which is handled through planning legislation; it replaced COMAH 1999 and came into force on 1 June 2015
Who it applies toEstablishments with dangerous substances above the lower or upper threshold in Schedule 1; the upper threshold brings upper tier duties
General dutyTake all measures necessary to prevent major accidents and limit their consequences to people and the environment
Major accident prevention policyEvery operator prepares one; key areas include organization, hazard identification, operational control, management of change, emergency planning, and monitoring, audit and review
Safety reportUpper tier operators prepare one; it must be reviewed and revised if the plant or its operation is modified or new information affects the risk, and in any case every five years

HSE's page does not discuss maintenance explicitly; it refers to prevention measures such as safe plant and safe operating procedures and to the policy elements above. 2 Changes made during a shutdown are therefore a COMAH matter if they change the plant or its operation. See the execution guide for change control and the audit guide.

Whether your site is a COMAH establishment depends on Schedule 1 and your inventory; check with your safety team and the competent authority.

Seveso III

What does Seveso III require during plant maintenance shutdowns?

Seveso III is the EU directive on major-accident hazards; each country implements it through its own law, in Great Britain through COMAH 2015, and I could not retrieve the directive's text, so this page does not quote its articles on maintenance. 2

The Seveso III link
QuestionAnswer
Is COMAH the UK form of Seveso III?HSE says COMAH 2015 implements the Seveso III Directive, except land-use planning
What is the Directive?Directive 2012/18/EU on the control of major-accident hazards involving dangerous substances
Does this page quote the Directive?No. The text could not be retrieved in full, so no article is quoted; check each EU country's implementing law

For EU sites, read the national law that implements the directive and your site's safety management documents. A change or maintenance activity with major-accident consequences is likely to need review under your safety management system; confirm the requirement in the text that applies to you.

Terms

Which UK and EU safety terms apply to a shutdown?

The terms a UK or EU shutdown planner meets most are PSSR, HSG253, HSG250, HSG159 and COMAH, and PSSR means something different in the US. 3,1,4,5,2

UK and EU terms you will meet
TermMeaningRead more
PSSR (UK)Pressure Systems Safety Regulations 2000: written scheme of examination before usePSSR in the UK
PSSR (US)Pre-startup safety review under OSHA 1910.119(i)Start-up after shutdown
HSG253HSE guidance on the safe isolation of plant and equipmentThis page
HSG250HSE guidance on permit-to-work systems for the petroleum, chemical and allied industriesPermit to work
HSG159HSE guide to managing contractorsContractor management
COMAHControl of Major Accident Hazards Regulations 2015This page

Visuals

Save the UK and EU charts

Two charts to share with your safety team. Click either for the full-size image.

FAQ

Frequently asked questions

What does HSG253 say about shutdowns?

It says to minimize isolation needs by planning intrusive maintenance for shutdown periods, and to choose the isolation method by risk assessment. 1

What are the three isolation categories?

Positive isolation (category I), proved isolation (II) and non-proved isolation (III). 1

Should single block and bleed be used?

As a general rule not as the final isolation for work on live plant containing hazardous substances, unless a risk assessment shows it is acceptable. 1

Does COMAH apply to shutdown maintenance?

COMAH applies by dangerous substance inventory; shutdowns at a COMAH site fall under the site's prevention policy and safety report. 2

How does COMAH relate to Seveso III?

HSE says COMAH 2015 implements Seveso III, except land-use planning. 2

What is PSSR in the UK?

The Pressure Systems Safety Regulations 2000. 3 See PSSR in the UK.

Where is the permit guidance?

HSE HSG250 covers permit-to-work systems for the petroleum, chemical and allied industries. 4 See permit to work during a shutdown.

Is this page legal advice?

No. It summarizes HSE guidance and an HSE description of COMAH; read the source documents and ask your safety team.

Keep permits and isolations tied to the work

Book a demo and bring your permit process. We will show how ePTW permits and isolations appear on each work order.

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