HSE DIRECTIVE 3

WORKING AT HEIGHTS
 1. GENERAL
Purpose
The purpose of this directive is to ensure that
• all work at heights is carried out safely
• there are no accidents due to dropped objects
• all use of ladders takes place in a safe manner
• all scaffolding is erected, taken down and used safely
• work above the sea is carried out safely

Scope
This directive applies to all BP-operated installations and
contracted installations on the Norwegian continental shelf.

Contracted mobile installations which have a system that satisfies

the requirements in this directive, may use their own system
provided this has been clarified upon implementation.

By following this directive, all requirements in the “Working

at Heights” section in the “BP 8 Golden Rules of Safety” are
complied with.

References
• The Activities Regulations, section § 40 Use of work equipment
• Regulations relating to scaffolding, ladders and work on roofs, etc.
• Regulation relating to use of work equipment
The Norwegian Labour Inspection Authority’s regulations
• 088 Common model for work permits
The Norwegian Labour Inspection Authority’s regulations
• NS-EN 795 Protection against fall from heights.
Anchoring methodes.
• HSE Directive no. 1 – Work permits
• HSE Directive no. 11 Safe job analysis
• Use of Work Basket - ref. HSE Directive 4 Lifting Operations

Defintions
• Working at heights means all work carried out standing with
one’s feet two metres or more above deck level where there
is no fixed platform or approved scaffolding
• Work permit is a written permit to carry out a defined work
task at a given place onboard an installation under given
conditions and in a safe manner
• Safe Job Analysis (SJA) is a systematic and step-by-step
review of all elements of risk carried out prior to a specific
task or operation so that measures can be taken to remove or
control any elements of risk identified during the preparation
for or performance of the said task or operation
• First line MOB (Man overboard) preparedness includes
o the platform’s MOB crew standing by in case of an
emergency

or

o a standby vessel ready by the installation

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2. WORKING AT HEIGHTS
Use of safety devices
• all work carried out standing with one’s feet 2 metres or more
above the deck requires:
o fixed platform with handrail, or
o scaffolding with green scafftag, or
o use of approved safety harness secured in a suitable anchor
point which limits free fall to 2 metres from the footing,
normally by use of a fall block, and
o filled in and signed “Checklist for Work At Heights/Use of
Harness”.
• When moving at height outside a fixed platform, scaffolding
or ladder an approved safety harness with fallblock (or,
alternatively, a Y-line) shall be used. When relocating the
fallblock, the person involved must be secured with a support
line.
• When using fall arrest equipment
• at least one person shall be present in the area nearby at
all times in order to start rescue work and alert the necessary
persons in case of a fall
• prior to commencement of work, a realistic and safe rescue
plan shall exist. The plan shall take the time for a safe rescue
into consideration in order to be able to rescue a person
within sufficient time (i.e. prevent blood circulation injuries).
• There shall be a site specific instruction on how required
competent personnel are organized (for instance a rescue
team)

Securing underlaying area

• Tools and equipment shall, as far as practical, b e secured
with suitable means to prevent them from being dropped
• If there is a potential for dropped objects the underlaying
area shall be secured either with a guard person or roped off
in co-ooperation with the area technician.
• If dropped objects can damage pressurised equipment,
the area shall be physically protected or de-pressurised in
co-operation with the area techncian.
• Upon completion of work the area shall be checked to secure
that no potential dropped objects are left.

Inspection of fall arrest harness

• The user shall always visually check his/her safety harness,
- system and anchor point and also have it checked by a co-
worker. If there is any doubt contact the scaffolding foreman
or inspection re. anchor points.
• Defect harnesses or harnesses that lack the control tag
(yearly control) for approved lifting device shall not be used
and handed in for repair

Fall arrest line

• Anchor points for fall arrest harnesses shall as a guideline at
least hold 1000kg, and the point shall preferably be above the
user

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 • Fall arrest lines shall only be fastened in a D-ring on the
person’s back with the fall arrest harness
• When using fall arrest lines a fall block shall normally be used.
• Support lines (without shock absorber) must not be used as
fall arrest lines for safety harnesses as they are only intended
as extra support to be used together with safety harnesses
and support belt
• The compilation of the fall arrester equipment shall
be assessed based on the nature of work (e.g. take into
considerations like movements in the horizontal movements
and potential pendulum movement

3. USE OF LADDERS
Use
• Ladders may only be used for access or work of short duration

Which ladders can be used

• Ladders shall be in accordance with Chapter VI in the
Regulations relating to scaffolding, ladders, work on roofs, etc.
• Ladders must have rubber knots at both ends and have no
visual deformation
• Only single ladders may be used.
• Stepladders up to 3.5m, may be used on firm and even
foundations when there is no potential for fall to a lower level
/ sea. Maximum climb height in the ladder is 2m. The 2m
shall be clearly marked on the ladder
• In electrical switchrooms, ladders shall be of non-conducting
material

Inspection
• The user is responsible for checking the ladder before use
• Defective ladders must be discarded

Safety measures
• Ladders must be secured to prevent them from sliding or
tipping over when used, by a person securing at the bottom
until it is secured at the top.
• During movement in a ladder nothing must be carried in the
hands.
• During work in a ladder three-point contact must be
maintained (e.g. 2 feet and one hand) and fall arrest
equipment used when standing above 2 meters.

4. SCAFFOLDING
Approval of work
• Erecting/dismantling scaffolding higher than 2m requires a
Work Permit level 2.
• Erecting/dismantling scaffolding lower than 2m requires a
general platform/area Work Permit level 2.
• Erecting/dismantling scaffolding over sea requires approval
according to section 5 of this directive.

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Erecting/dismantling scaffolding
• Scaffolding shall be erected/moved and dismantled by
authorised scaffolders only
• Scaffolding shall be in accordance with Chapter III of the
Regulations relating to scaffolding, ladders, work on roofs, etc.
• A work platform (including access platforms) shall be secured
with handrails and kick plates and other required covering/
securing to prevent dropped objects. If this is not possible
the green scafftag shall be marked with necessary safety
precautions, such as use of harness and closing of
underlaying area.

Erecting/dismantling scaffolding over sea

When scaffolding is erected/dismantled over sea:
• the rules for Work over sea shall apply.
• a Toolbox Talk or Job Safety Analysis shall be performed.
• always be 2 scaffolders.

Scaffolding approval
• Approval of scaffolding for use shall only be performed by
authorised approval personnel. Ref. competency
requirements, section 1.
• Approved scaffolding is shown with a green scafftag with
date and signature. The scafftag must be at the scaffolding
entrance
• The scaffolding foreman must ensure scaffolds are inspected/
approved at least once every 14 days, as well as after
spells of strong wind or other conditions that may damage
the scaffolding

Use of scaffolding
• Only scaffolding having a green scafftag is approved for use
• Scaffolding must be used in accordance with limitations given
on the green scafftag.

5. WORK OVER OPEN SEA

Introduction
• Work over sea means work taking place outside permanent
railing where there is a risk of a person/persons falling into
the sea.
• Work in hydraulic basket in “moon pool” and on approved
scaffolding is not defined as work over sea when extra
barriers such as
• fall arrest equipment
• man-riding belt
• net
• Scaffolding build as a class 3 and certified as a class 2
scaffolding with extra heighten hand rail (railing). The
scaffolding shall be certified every week and inspected after
external influence e.g. strong wind

Note: use of fall arrest equipment, man-riding belt or net requires

independent securing. (not attached to the scaffolding).

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 Approval
• Work over sea requires an approved work permit level 1

Restrictions
Work over sea is permitted provided:
• The wind speed is maximum 30 knots, measured at a 10 m
level
• The wave height is maximum 5 m (corresponds to 3 m
significant wave height)
• Standby vessel in near-standby mode or MOB in extra
preparedness mode
• The MOB boat onboard or on the standby vessel is operative
and can be launched/retrieved in case a person falls into the
sea
• The light and view is good enough to perform the work and
rescue any person that may fall into the sea
• Consent has been obtained from the diving supervisor if
there is diving activity near the work site

Safety precautions
• When working over sea, a safety guard must be present and
monitor the personnel located over sea at all times. The
safety guard shall be familiar with and carry out tasks stated
in the Safety guard’s duties in connection with work over sea
• A life buoy with line and light shall be easily available
• The performing personnel shall be familiar with all
procedures, preconditions, risks and safety precautions
relating to the work
• Everyone working over open sea shall wear a life vest
• When working below the cellar deck, consider whether to
secure spills, overflow, etc. from e.g. fire water
• Consider the need for implementing measures to avoid
objects falling to lower levels or down on vessels.

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 HSE DIRECTIVE 3
WORKING AT HEIGHTS
ATTACHMENTS
Attachment 1:
Duties for the safety guard during work over sea

Attachment 2:
Checklist for work at height /use of harness
 ATTACHMENT 1:
DUTIES FOR THE SAFETY GUARD DURING
WORK OVER SEA
The Safety Guard shall be clearly marked with “sikkerhetsvakt”

Before commencing the work

The Safety Guard shall:
• participate in the work planning, including SJA / pre-job talks
• locate the nearest fire call point/telephone
• ensure that the agreed MOB function (Standby boat or the
installation’s MOB crew) is informed and operational
• establish and check radio communication with the work
place, SCR and MOB function. (Standby boat or the
installation’s Radio room when using the installation’s MOB
boat. Check that the radio in the MOB boad can communicate
with the Safety guard).
• ensure escape routes are known by involved personnel
• be familiar with the weather limitations for work over sea
• perform “comradeship check” upon fall arrester equipment
and life vest

During work
The Safety Guard shall:
• inform SCR and MOB function at start, interruption and
completion of work
• be located at a permanent deck of the installation and have
an unhindered view of the personnel working over sea
• not take part in work that may interfere with his/her duty as
safety guard
• monitor changes in weather conditions/visibility and light and
stop the work if the preconditions and limitations for the
work are exceeded
• monitor the work and surroundings and stop work should a
situation arise that calls for such action
• facilitate a good dialogue with the stand-by vessel regarding
light and weather conditions, if and when any limitations
should occur

Interruptions/ completion of work

The Safety Guard shall:
• inform SCR and MOB function
• secure equipment/workplace

If ”man over board”

The Safety Guard shall:
• notify colleagues CCR and MOB function
• activate alarm
• throw out a life buoy
• maintain visual contact with person in sea
• secure equipment/workplace

Alarm situations
The Safety Guard shall:
• notify personnel over sea and stop work
• secure that all personnel return to a permanent deck of the
installation
• secure equipment/workplace

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ATTACHMENT 2:
CHECKLIST FOR WORK AT HEIGHT / OVER
OPEN SEA / USE OF HARNESS
Revision pr. January 2008
Attachment 2 HSE Directive 3 – Working at Height

CHECKLIST FOR WORK AT HEIGHT/ OVER OPEN SEA / USE OF HARNESS

Sjekkpunkter N/A Yes No Comment

1 Are you using a full body harness with double latch self-locking snap
hooks and equipment with relief strap / foot strap?

2 Has a proper anchor point for the safety line been located?

3 Is fall arrest equipment in use that will limit the free fall to 2 meters or
less?

4 Has the fall arrest equipment been visually checked for:

- damage/wear or defects?
- control tag with the latest control date?

5 If a ladder is used, is the ladder free of visual damage and secured?

During securing of the ladder one person shall secure the ladder at
the bottom until the ladder is secured at the top.

6 Has the fall arrest equipment, system and anchor point been checked
by a colleague?

7 Is there a person in the work area that can initiate rescue, if a fall
should occur?

8 Are equipment / tools used at height controlled and adequately

secured against dropping? And not left behind finishing the work?

9 Are underlying areas closed off and pressurized/sensitive equipment

protected against dropped objects?

10 Are lighting, noise and weather conditions satisfactory for the task?

11 Are there any other risks and have they been evaluated and found
acceptable?

12 Have the involved persons completed a course in fall arrest methods?

13 Have all items on the checklist been answered YES without

comments?
If NO, the work shall not be started. Contact the line manager to find
alternative methods to perform the work.

ADDITIONAL COMMENTS

Note: Work over open sea also require the use of “Duties for the safety guard during work over sea” (attachment1)
Date: Area technician (work w/o WP):

Performing technician(s):______________________________________________________________________
Closure of work
14 Are all loose tools/equipment removed from the workplace?

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