Life Saving Rule
Life Saving Rule
SCHSE-SAF-GL-005
Acknowledgments
These guidelines aim to provide guidance and clarity on a range of topics relevant to
onshore and offshore oil and gas operations in EGYPT and on the Egyptian continental
shelf. The Guidelines cover a wide variety of topics, many of them related to health,
safety, and environment.
These guidelines and procedures fall under the OMS, while the process safety
standards and guidelines fall under the PSM Egypt domain. They are complementary
and supplementary to each other.
EGPC has appointed a Standardization Committee, as per EGPC Decree 22 of 2020, to
establish the OMS and code of practice documents.
All guidelines were endorsed by the committees and eventually approved by the
executive personnel of EGPC. All approved guidelines were published on the MOP HSE
portal and subsequently maintained in accordance with this guideline.
Approval
Name Title Date Signature
Gamal Fathy Head of MOP Supreme Committee
Revision History
Copyright
This manual is a property of MOPs four entities (EGPC, EGAS, ECHEM, and GANOPE).
It is nontransferable and must be surrendered on demand or upon termination of
employment to EGPC or holding companies. This manual cannot be used except in the
purposes it is issued for. It cannot be reproduced in whole or in part unless by the
approval of HSE supreme committee head, EGPC, EGAS, ECHEM, and GANOPE CEO
Assist for HSE and according to codes of practice document control procedure (SCHSE-
GEN-GL-001).
Disclaimer
No liability whatsoever in contract, tort, or otherwise is accepted by EGPC, EGAS,
ECHEM, and GANOPE or any of its companies, their respective shareholders, directors,
officers and employees whether or not involved in the preparation of the Manual for
any consequences what-so-ever resulting directly or indirectly from reliance on or
from the use of the Manual or for any error or omission therein even if such error or
omission is caused by a failure to exercise reasonable care.
Controlled Intranet Copy
The intranet copy of this document is the only controlled document. Copies or extracts
of this document, downloaded from the intranet, are uncontrolled copies and cannot
be guaranteed to be the latest version. All printed paper copies should be treated as
uncontrolled copies of this document.
Table of Contents
1. Executive Summary ................................................................................................ 6
2. Purpose and scope ................................................................................................. 6
2.1 Purpose ............................................................................................................... 6
2.2 Scope ................................................................................................................... 7
3. Abbreviations.......................................................................................................... 8
4. Definitions............................................................................................................... 8
5. Role and Responsibilities ...................................................................................... 10
5.1 Company Chairman and MD ............................................................................. 10
5.2 Company Line Managers and Area Authorities ................................................ 10
5.3 Company HSE Manager .................................................................................... 10
5.4 Contractor Supervisors ..................................................................................... 11
5.5 All Employees, Contractors, Subcontractors & Visitors .................................... 11
6. Life Saving Rules ................................................................................................... 11
6.1 Summary and Guidance .................................................................................... 13
7. Implementation the Life Saving Rules .................................................................. 28
7.1 Fundamental Requirements ............................................................................. 28
7.2 Helping People Follow the Rule. ....................................................................... 29
7.3 Continued Engagement and Integration .......................................................... 30
7.4 Investigating Breach’s to Life Saving Rules ....................................................... 30
8. Life Saving Rule Start Work Checks (SWC) ........................................................... 31
8.1 What the SWC cover and their Relation to the Life-Saving Rules .................... 32
8.2 SWC Key feature ............................................................................................... 33
8.3 SWC Implementation Requirements: ............................................................... 33
8.4 How to Use SWC Cards: .................................................................................... 34
8.5 SWC Cards Roles and Responsibilities: ............................................................. 35
8.5.1 Person Performing Work: ................................................................................. 35
8.5.2 Verifier: ............................................................................................................. 36
8.5.3 SWC Training: .................................................................................................... 37
9. References ............................................................................................................ 38
10. List of Appendix................................................................................................. 38
Appendix A: Life Saving Rules A4 Card ........................................................................ 39
Appendix B: Start Work Checks ................................................................................... 41
1. Executive Summary
IOGP Member companies recognize the value of providing clear, simple, and
consistent information regarding risks in the workplace and the proper use of
barriers and safeguards to protect the workforce. In 2010 IOGP published a set of
Life-Saving Rules to mitigate risk and reduce fatalities in the oil and gas industry
were derived from analysis data reported to IOGP.
The IOGP Life-Saving Rules are not intended to address all risks and hazards in the
oil and gas industry; they are meant to draw attention to the activities most likely
to lead to a fatality, and the life-saving actions over which an individual has
control. The Rules are intended to support existing company management
systems. They are not intended to replace company management systems,
policies, safety training programmes, operating procedures, or work instructions,
and in fact rely on this framework being in place.
This guideline provides simple tool to implement the rules in accordance with
the guiding principles and terms and conditions outlined in the Industry
Accepted Standard.
All Guidelines require the endorsement of the committees and eventually the
approval of the Executive personnel of MOP. All approved Guidelines will be
published on the MOP HSE portal and subsequently maintained in accordance
with this Guideline.
Shared Learning: 4 entities (EGPC, EGAS, ECHEM and GANOPE) will report,
share lessons learned and best practices through MOP HSE reporting
guideline (MOP-GEN-GL-12).
It is important for the entities (EGPC, EGAS, ECHEM and GANOPE) and its
companies implementing Life Saving Rules to integrate them into their Health
and Safety Management System. Entities should ensure the following:
Personnel on their worksites are authorized and required to intervene if
they are in doubt about the safety of an activity.
Systems and processes are in place to collect data related to Life Saving Rule
non-compliances and other safety related data (e.g. incident near misses)
to monitor the effectiveness of the implementation of these Life Saving
Rules
2.2 Scope
This document provides an introduction to the revised Rules, data analysis, and
implementation guidance. The Life-Saving Rules (LSRs) implement to everyone
and all operations under MOP OMS control. All employees, contractors and
subcontractors will be made aware of these LSRs and will be accountable to
comply with them.
The most critical part of Life-Saving rule that its globally standardized across the
oil and gas industry. This will lead to:
Enables better transfer of knowledge, experience and lessons learned.
Increases individual awareness ownership of critical safeguards that
prevent fatalities.
Is a step towards an industry-wide common safety language.
Improves clarity and allows consistent use by contractors and operators
doing similar work across the world.
To achieve the benefits of standardization and prevent workforce fatalities, all 9
Rules should be adopted as written and not be modified or substituted;
organizations should:
Adopt the IOGP Life-Saving Rules if they currently have no equivalent
program.
Transition to the revised IOGP Life-Saving Rules if using a different set of
rules or if using the previous set of IOGP rules.
Encourage joint ventures and partners to implement the revised IOGP Life-
Saving Rules.
Accept and encourage contractor use of the revised IOGP Life-Saving Rules.
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LIFE SAVING RULES GUIDELINE Rev.01
3. Abbreviations
4. Definitions
Verifier The role of confirming all SWC controls/safeguards are in
place and functioning after the person(s) performing the work
have confirmed their checks
Stop Work Authority The power given to workers to stop work and intervene if they
observe an unsafe activity (in the context of this document,
this includes noncompliance with an IOGP Life-Saving Rule or
Start Work Check action).
Frontline Worker Frontline workers are personnel who are directly involved in
operational and/or maintenance activities.
Frontline Supervisor Frontline supervisors are personnel who supervise workers
who are directly involved in operational and/or maintenance
activities.
Exclusion Zone Barricaded No-go areas where it has been identified a risk for
workers to be in the area due to potential harm from items
such as dropped objects or lifted materials.
Permit to Work This refers to the signed document used as part of a Permit to
(PTW) Work system for control of work. Based on IOGP Report 189 -
Guidelines on permit to work systems.
For more details, refer to the HSE & PSM Definitions and Abbreviations guidelines
(SCHSE-GEN-GL-002).
Bypassing Safety Controls: Safety critical equipment must As a Supervisor: Safety critical
Obtain authorization before work correctly to keep you – I ensure safety critical procedures are
overriding or disabling safety safe equipment and procedures are not followed
controls: Safety-critical controls include: identified and communicated Intentionally
• I understand and use safety – Equipment (such as fire and to workers exceeding safe
critical equipment and gas detection controls, – I ensure workers are operating design
procedures which apply to isolation devices, relief valves, competent in the use and limits for process
my task emergency breathing limitations of safety critical equipment
• I obtain authorization appratus SCBA, Emergency equipment and procedures An ESD is
before: shutdown devices (ESD), – I confirm all proper bypassed without
– disabling or overriding explosion protection and authorizations are obtained authorization
safety equipment mitigation systems, guards, As a Worker: Someone else’s
– deviating from interlocks, In vehicle – I have the required training and lock is removed
procedures monitoring systems (IVMS), knowledge to safely perform without
– crossing a barrier Lock out/tag out devices, work authorization
Electronic logging device – I obtain authorization from my Gas or fire
(ELD), alarms and safety- supervisor or the person in detection are
critical monitoring equipment) charge if required to override bypassed without
whose purpose is to prevent a or disable a safety critical authorization
fatality or other major control Gas detection is
accident, limit the – I stop work and notify my not worn or is not
consequences of a major supervisor if a procedural turned on as per
accident, or whose failure deviation is required the work permit,
could cause or contribute – I do not cross barriers or hazard
substantially to a fatality or exclusion zones assessment or
other major accident. work procedures
– a gas test has been combustion engines, chemical work is addressed in the work Trapped vapours
completed reactions, batteries, etc. permit have not been
– gas will be monitored Be aware! Residual or stored As a Worker purged
continually energy in the form of trapped – I have the required training and Combustible gas
flammable gases and vapours knowledge to safely perform testing is not
may be present in equipment work conducted prior to
– I obtain a work permit for hot and during hot
work activities and obtain work activities
permission to bypass safety Smoking outside
critical equipment such as flash of designated
detection (fire eyes) areas
– I identify and remove or isolate
flammable materials such as
gases, liquids and solids
– I conduct testing for residual or
stored energy and only proceed
with work when the energy is
zero
– I conduct combustible gas
testing prior to starting work
and continually during the work
– I only smoke in designated
areas
Confined Space: A confined space, such as a As a Supervisor: The supervisor
Obtain authorization before vessel, tank, pipe, cellar or – I ensure confined spaces are does not confirm
entering a confined space excavation, can contain identified and workers are energy sources are
explosive gas, toxic or competent
• I confirm energy sources asphyxiating atmosphere or – I ensure a hazard assessment is isolated prior to
are isolated other dangers such as energy conducted entry by a worker
• I confirm the atmosphere releases, lack of oxygen, – I ensure energy sources are Testing and
has been tested and is exposure to hazardous isolated monitoring of the
monitored chemicals, things that can fall – I ensure an adequate atmosphere is not
• I check and use my on you or crush you, or that emergency rescue plan is in conducted or
breathing apparatus when you can fall from. Authorised place confirmed prior to
required access keeps you safe. As an Attendant: entry as per the
• I confirm there is an Energy sources may be – I have the required training and work permit,
attendant standing by pneumatic, hydraulic, knowledge to safely perform hazard
• I confirm a rescue plan is in mechanical, gravitational, work assessment or
place chemical, electrical, nuclear, – I control access to the confined work procedure
• I obtain authorization to thermal or any other energy space Breathing
enter that could cause injury – I conduct atmosphere testing apparatus is not
Organisations should and monitoring using inspected prior to
determine if any work appropriate donning
involving excavations or – equipment that includes, at a A confined space
trenches creates confined minimum, combustible gas, is entered without
space conditions and ensure oxygen, H2S and carbon wearing the
necessary work authorisation monoxide and may include, but required
and controls. not limited to, benzene and breathing
other hydrocarbons, sulphur apparatus
dioxide etc. depending on the A confined space
hazard assessment is entered without
– I understand how to initiate first obtaining
and notify rescue personnel authorization
To protect people around – I have the required training and inspected prior to
suspended loads and any knowledge to safely perform the lift
mechanical lifting operation, work The lift is
access should be controlled – I ensure I am fit for duty conducted with
through physical barriers and – I follow the lift plan equipment that
exclusion zones. – I inspect the lifting equipment does not have the
When mechanically lifting and adhere to all certification proper
people (e.g. manriding, requirements certifications
manbaskets, personnel – I confirm the lift equipment is A lift is conducted
transfer, mobile elevated work fit for purpose and I operate beyond its
platform), organisations the lifting equipment below its working load
should provide equipment working load limits limits
which is designed and certified – I ensure line of fire hazards in A safe distance is
specifically for lifting people. relation to overhead power not maintained
A lift plan identifies the lines are identified, marked, from overhead
weights and dimensions, how and a safe distance is powerlines
the lift will progress, maintained The load is
communication requirements – I use tag lines to position positioned using
(signal personnel), and suspended loads worker’s hands
weather and ground – I adhere to barriers and instead of tag
conditions. exclusion zones lines, putting the
workers under the
suspended load
Barriers and
exclusion zones
are not
established
• I take action to secure supported excavations, – I correct any unsafe conditions equipment design
loose objects and report shifting cargo, moving where workers are in the line of which puts
potential dropped objects equipment). fire as dictated by equipment personnel in the
At all times individuals need to design, and seek engineering line of fire is
continually monitor their support to remedy identified
surroundings and position As a Worker: Hand tools and
themselves to avoid being in – I have the required training and other equipment
the line of fire. This includes knowledge to safely perform are not secured to
ensuring they are visible to work prevent dropped
vehicle drivers and equipment – I position myself to avoid objects
operators. moving objects, vehicles, Action is not taken
Individuals recognise when pressure releases and dropped when line of fire or
they create a line of fire hazard objects potential dropped
and put others or themselves – I adhere to barriers and objects are
in the line of fire. exclusion zones identified in identified
work permits, hazard
assessments and work
procedures
– I identify any unsafe conditions
where I am in the line of fire as
dictated by equipment design
and notify my supervisor
– I ensure my vehicle is secured
(in park, emergency brake on,
wheels chocked, etc. as
appropriate) to prevent a line
of fire hazard
when an extreme
weather storm
moves in and the
driver does not
stop and reassess
the journey
Before work starts, there are emergency response plans in place that have been
developed from a review of potential emergency scenarios, which have suitable
and sufficient resources available, and which are periodically drilled/tested.
Everyone is authorized to intervene or stop work without adverse consequences if
they are in any doubt about the safety of an activity.
Suitable personal protective equipment is provided and worn in accordance with
the requirements identified by the risk assessment and worksite policies.
Conduct a risk assessment of your organization’s activities and review historical
data related to fatalities and high potential events within your own organization
(both company employee and contractors) and determine how these align with the
Life-Saving Rules.
Develop a business case/change management programme and discuss with
leadership of both your organization and your contractors and subcontractors to
ensure commitment to implement the Life-Saving Rules.
Ensure implementation, use and compliance are owned by line-management (e.g.
maintenance, facilities, operations, etc.) and supported by HSE professionals.
Develop a communications and roll-out plan for the implementation of the Life-
Saving Rules (stakeholder mapping, communications plan, accountability, and
compliance strategy in consultation with legal, supply chain and human resources
departments).
Develop performance monitoring methods to determine the effective
implementation and ongoing use of the Life-Saving Rules.
Use the IOGP Life-Saving Rules roll-out and engagement materials.
these must be visible to the workforce, by, for example, ensuring physical
workplace conditions are present.
Everyone must be given the authority and be encouraged to stop work and
intervene if they observe a Life-Saving Rule (or indeed any other unsafe activity)
actually, or potentially, not being followed. Proactive intervention may be the
last opportunity to prevent injury or fatality.
are rare and should always follow their internal processes for dealing with such
matters.
The individual's attention should be drawn to the potential Life-Saving Rule he
breached. He should be informed of the applicable rule and the manner in which
he has been seen to breach it. He should be asked:
If he was aware of the rule
Why he breached it
If the rule has been discussed during the Tool Box Talk
If it is mentioned on the Work Permit
Details of the intervention should be made during the investigation and
submitted
Record names of the person seen in breach of the rule
Names of his immediate supervisor/contractor
Names of the persons making the intervention
Close the intervention by making sure the situation is safe and informing
the person seen breaching the rule that the event will be subject of further
investigation
Inform the Area Authority, Contractor supervisor (for contractor staff) and
HSE Manager
8.1 What the SWC cover and their Relation to the Life-Saving Rules
IOGP developed thirteen Checks, six of which directly relate to a Rule (Checks 1-6).
Seven (Checks 7-13) were developed to address particular aspects of a more
generic Rule, to combine multiple Rules into an activity, or for high-risk activities
that, historically, have been identified as a cause for oil and gas industry fatalities
or serious injuries.
The thirteen Checks are:
1) Confined Space
2) Driving
3) Energy Isolation
4) Hot Work
5) Safe Mechanical Lifting
6) Work at Height
7) De-isolation and re-energizing
8) Excavation
9) Man-riding
10) Work around mobile equipment
11) Energized/live electrical systems
12) Work near water
13) Rig floor tubular handling
Appendix B provide full illustration for SWC tool.
The Checks and the Rules are different tools: the Rules help with communicating and
drawing attention to the most critical and lifesaving actions a worker can have control
over. The Checks are a practical tool that assure the worker that the
control/safeguards described in the Rules are present and functioning before they go
ahead with task.
Because of this, the Start Work Checks must be directly relevant for the task about to
be performed, and therefore they cannot have a 1-to-1 relationship to the Rules, as
some of the Rules (e.g., Line of Fire) are generic.
Some of the notable continuities and differences between the Rules and the Checks
include:
The Line of Fire Life-Saving Rule reflected throughout the Checks, but more
obviously present in:
– Work around mobile equipment
– Work near water
Although there is a safe mechanical lifting SWC, a separate Check for Man-riding
has been created, as this is a unique activity and only applicable on drilling rigs.
Aspects of the Rules for Confined Space Entry, Line of Fire, and Energy Isolation
appear in the Excavation SWC.
Unique Checks for de-isolation and re-energizing, associated with reinstatement
after energy isolation, have been created to explain each step more thoroughly.
For activities that require a Permit To Work (PTW) to be completed, work
authorization will be confirmed using the applicable PTW system in place. Having a
robust PTW system has been identified as a fundamental requirement that should
be in place prior to an organization implementing the LSRs. Therefore, there is no
specific SWC for work authorization.
A leadership and frontline worker commitment that work does not start until all
individuals involved are aware of and can confirm they have discussed the
relevant SWCs
Everyone is authorized and empowered to intervene or stop work without
adverse consequences if they are in any doubt about the safety of an activity at
any time.
A pre-job assessment and safety discussion are conducted prior to starting a task.
Personnel are trained and competent for the work they conduct.
Equipment is fit for purpose, properly maintained, and in working condition.
Emergency response plans and resources are in place and periodically
drilled/tested to enable effective response.
Personal protective equipment is provided and worn in accordance with the
requirements specified by the risk assessment and worksite policies.
Verifier: Someone other than the worker confirming the SWC steps, who is an
experienced person familiar with the activity, and performs a peer-review of the
Check.
The person performing the work visually and/or physically checks the controls/
safeguards in each item, marking them as ‘checked’.
If the SWC is to be jointly completed by a work crew, each check item could be
confirmed by one individual only (e.g., the same crew member visually/physically
confirms all aspects described in one row and marks it ‘checked’, a second crew
member can take the next row and so on). Or an item could be done
collaboratively, with multiple crew members confirming aspects together, there
may be occasions where this is more practical.
To complete a SWC, all members of the work crew must agree the check items
are in place and fully functioning.
The verifier then performs a peer-review, going item-by-item and marking them
‘verified’.
If all items in a Check are confirmed and verified – the Check is marked complete
and work can start.
If any item cannot be confirmed or verified, the Check cannot be completed and
the person performing work or the verifier stop and seek help.
This process can also enable the crew to identify and discuss:
- Any steps or responsibilities that may be confusing
- Any factors that could make a mistake likely
- Any factors that may make the task difficult to perform
- How to resolve identified issues before starting the task
- When to stop work, what to do and where to seek help
The ‘person performing work’ confirms the SWC prior to starting work. If the control/
safeguard cannot be confirmed and verified (by a designated ‘verifier’) the worker
should stop and ask for help before starting the task. The Person Performing Work:
Knows the requirements of the Life-Saving Rules and the SWC
Confirms that the identified controls/safeguards are in place and functioning prior
to starting the task. This requires:
- Having the SWC form available during confirmation
- Physical confirmation that each control/safeguard is in place
8.5.2 Verifier:
The verifier plays an essential role in confirming all SWC controls/safeguards are
in place and functioning after the person(s) performing the work have completed
their confirmations. The design intent of the Start Work Checks is for the
verification to function as a peer review, a secondary confirmation of the LSRs.
The verifier role should be performed by someone other than the worker
confirming the SWC steps. The role of the verifier adds an additional layer of
assurance for controls/safeguards that prevent fatalities and serious injuries.
Organizations should assign the verifier role carefully. Considerations should
include:
- Demonstrated competence for the task to be verified, including an
understanding of the importance and functionality of the controls/safeguards
- Availability of an assigned verifier to engage with of the work crew prior to the
start of the task
- The best verifier is the person who has operational understanding of the task
and the effectiveness of the safeguards.
If a PTW is required, the verifier should not be the permit holder. The verifier role
does not replace the accountability of a permit holder or person in charge.
The Checks provided by IOGP include a column to mark each step as verified. IOGP
considers the use of the verifier role as a good complement to the effective use
of the SWCs. However, it is recognized that organizations may have alternative
effective methods to assure controls/safeguards prior to work execution.
Therefore, organizations may elect to modify this role to suit their business needs.
There may be situations where organizations may determine that the role of the
verifier may be performed remotely. Organizations should follow established
organizational requirements for verification of activities completed by lone
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LIFE SAVING RULES GUIDELINE Rev.01
worker(s). Where applicable, remote verification (e.g., phone, email etc.) can be
used to allow offsite verification in accordance with company processes.
Although the Checks themselves are simple to use, workers need to be trained
and competent in the work they conduct, the responsibilities and processes of
using the Checks, and have knowledge and training in the Life-Saving Rules.
Training in the SWCs should be delivered to the workers using the Checks and/or
verifying the work activity.
IOGP has made available basic training for the Life-Saving Rules and the use of the
SWC, including content, application, and human performance principles.
Implementing companies may wish to provide additional training in how the
SWCs fit into their management system and business processes.
Implementing companies may supplement training with additional coaching to
maximize the effectiveness of implementation within their organization for
employees and applicable contractors.
9. References
IOGP 459 IOGP Life Saving Rules