Safety and Environmental

Considerations

The safe and environmentally friendly commissioning of any new asset should always be of the
highest priority and integral with every check-sheet and procedure written during the
preparation and execution of the commissioning process. The safety of personnel plus the
environmental implication must always be the first considerations of any commissioning
activity and as such the documentation therefore must address and satisfy all the safety and
environmental aspects at all times.
Whilst not aligned directly with safety, it is worthy of mention that good safe commis-
sioning procedures also give considerable consideration to the protection of newly installed
plant items during the commissioning phases and hence also have a high priority. A clear
understanding of the commissioning logic required to start especially package-type equip-
ment must be obtained from the equipment vendor, and their attendance at the initial
commissioning is usually a must and therefore has to be accounted for in the commissioning
cost.
Schedules must be considered and constructed in a way that sufficient time is allocated
to each and every commissioning activity, as in the heat and intensity of the commissioning
and start-up phases, this is the most critical time when safety implications can be neglected
and therefore need to be strictly adhered to and enforced.
As construction develops, commissioning systems and potentially individual items of
equipment will take place and introduction of energy to the plant will start. The various
process areas must be clearly identified and clear communication made with them all,
especially the construction and operations groups, prior to operation and testing of the
equipment to make known the change of status and the new safety implications to the
construction and commissioning site. Areas must be taped, barricaded or fenced off and
tagged appropriately, clearly identifying the nature of the activities about to commence in the
area. Sufficient commissioning staff must be made available to correctly inform adjacent
personnel and thereafter police areas that are being energized. All electrical items at field
devices and motor control centers (MCC) must be clearly labeled, locked out and tracked in
a safe-and-sound manner with an agreement clearly defined between the construction and
commissioning organizations, with regard to who is in control of the permitting and key
management systems; it can and does vary from project to project.
The commissioning team must undergo all relevant training required by the site to which
the project is being worked, hence permitting the team members to safely and diligently
discharge their normal duties during the commissioning and start-up activities.
Safe systems of work should be integral to all commissioning activities and procedures.
The utmost care will be given to avoid a loss of process containment or environmental inci-
dent. The commissioning organization should be robust enough to establish or contribute to
the development of safe systems of work at the work location if not already established. These
safe systems of work may include permit to work systems, confined space entry permits
and hot work permits. Information on the establishment of such safe systems of work can be

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found on governmental websites such as the Health and Safety Executive (HSE – UK) or the
Occupational Safety and Health Administration (OSHA) in the United States.
The commissioning personnel must make themselves familiar with all site regulatory
procedures and works instructions that they may have to consider during the execution of
their activities at a particular jobsite. These could include environmental impact assessments,
job safety analysis, major job reviews, job method statements, pre-task planning, safe and
unsafe acts audits, there are many others. The commissioning manager must ensure that the
commissioning team is actively involved with any audit regime that the project has instigated
for the purposes of safe construction and commissioning phases.
Discussions must take place between the contracting and site client personnel to ensure
no transgression or site violation takes place within the act of initially commissioning the new
facility; examples of these activities are opening process valves potentially from an existing
operating area, starting electrical equipment and manipulation of new graphic pages on an
existing control system. The findings from the discussions must be fully documented within
the commissioning manual and subsequent commissioning procedures and strictly adhered
to during the actual commissioning activities.
The commissioning team must uphold and actively enforce all site safety regulations
with regard to transportation, personnel movements and restricted areas, as well as the use of
personnel protective equipment. All implications from the above activities must be included
in the relevant individual commissioning procedures.
It is common for the commissioning team to be requested to attend various safety
studies; examples of these are Hazard and Operability Studies (HAZOP) in various company
formats, Safety Integrity Level (SIL) analysis of protection systems and Layer of Protection
Analysis (LOPA), to name but a few. It is advisable for the commissioning manager to become
familiar with the safety studies the team will participate in during the various project stages
and arrange formal training for those commissioning team members who are in need of the
specific guidance or refresher training if required.