COMPLIANCE AND HEALTH & SAFETY
Isolations should be taken seriously.
David George
David George, IEng, MIET, MInstRE, MIHEEM, TechIOSH, MAPM, ASET, is an experienced and qualified engineer and health and safety professional with over 25 years’ experience of engineering and high-risk safe systems of work. He has worked in a variety of industry sectors (including the NHS, the MoD, and commercial and industrial). He has served
extensively on MoD working groups relating to high-risk Safe Systems of Work, and was directly involved in developing, implementing, and training, personnel on them. This collaboration with the MoD also involved the development of technical documents and guides. He is one of the founder members of the IHEEM Mechanical Technical Platform. As an Authorising
Engineer, he has also directly developed site and system-specific Safe Systems of Work for many NHS, commercial, and industrial clients (in electrical, mechanical, petroleum, and confined spaces disciplines). This included their implementation, audit, and monitoring. He has also produced, organised, and presented, training courses on a variety of safe systems of work, facilities management, and engineering subjects.
Some others that need consideration are:
n The mechanical aspects of some confined spaces, such as isolation of cold-water storage tanks for the AP Confined Spaces (who may not have the mechanical and electrical isolation competence that an AP Mechanical has).
n The mechanical isolation of medical gas pipeline systems (covered in more detail later in this article).
n Low temperature hot water. n High-pressure cold-water systems (and what is ‘high’?). n Sterile service autoclaves, catering equipment, and lab equipment.
As regards procedures and guidance documents, there are a couple of existing documents within the NHS, SHTM 08-08 – Pressure systems: policies and guidance, and HTM 02-01 – Medical Gas Pipeline Systems, which are related to mechanical systems. However, both documents have their limitations in relation to formal SSoW. SHTM 08-084
sets out guidance intended to allow
NHS Boards to implement the PSSR requirements and procedures. It thus has its limitations as a full Safe System of Work document, so should not be considered as a complete SSoW.
Patient safety the key focus HTM 02-01: Medical Gas Pipeline Systems5
considers
patient safety, and not the safety of anyone actually working on MGPS. It says: ‘The purpose of the permit issued under this permit-to-work system is to safeguard the integrity of the MGPS, and hence, patient safety; it is not intended as a permit to protect the safety of individuals operating or working on the system.’ A mechanical SSoW may therefore also need to consider safe isolation of MGPS plant and equipment in conjunction with the AP MGPS. This will need a site protocol to be implemented to ensure co-operation and communication between the two disciplines. The Ministry of Defence (MoD) also has a Safe System
of Work document for Mechanical and Pressure Systems (JSP 375, Volume 3, Chapter 4). This was produced to get away from the old thinking of just ‘boilers and pressure systems’ in relation to PSSR. It was written to include mechanical systems based on risk assessment. However, as regards its use outside the MoD, be aware that the
46 Health Estate Journal May 2025
MoD places a caveat in Chapter 46 which excludes all liability of the Crown where the JSP 375 Volume 3 suite of documents is used for any other purpose outside the MoD. Therefore, the document cannot be used ‘as is’, but must be made specific to the non-MoD application. For example, the MoD management structure mentioned within JSP 375 does not exist outside of the MoD. What is not often understood is the MoD structure of
the Joint Service Publications (JSP) in general, and those relating to formal Safe Systems of Work in particular. There is a Chapter 2 – Common Requirements,7
which identifies
the generic activities, roles, procedures, and processes that are necessary to meet the requirements of the whole Safety Management System (JSP 375 Volume 3), and the subsequent chapters define the requirements specific to identified significant risk areas. The Chapter 2 document must be referenced whenever using JSP 375, Volume 3 main chapter documents, as they contain information that may not be present in the main discipline chapter. This is generally not followed by those who plagiarise Chapter 4 outside the MoD estate.
Need for a formal procedure So, that covers the requirement, but how do we get it in place? A formal procedure will inevitably be required. While developing this procedure, reference should be made to HSG 250 – Guidance on permit-to-work Systems.8
This describes good practice in the use of
permit-to-work systems, and will help people using these systems to ensure that risks have been reduced to a level as low as reasonably practicable. The formal procedure should also make reference to
HSG 253 – The safe isolation of plant and equipment.9 This publication (free from the HSE website) provides guidance on how to isolate plant and equipment safely, and how to reduce the risk of releasing hazardous substances during intrusive activities such as maintenance. It includes a methodology for selecting ‘baseline’ process isolation standards, and outlines preventative and risk reduction measures. The Combustion Engineering Association has produced its own guidance based on HSG 253, titled BG10 – Guidance on Safe Isolation of Plant and Equipment.10
I will cover isolations in another article, but among the essentials here are accurate and up-to-date schematics,
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