2012 may wind turbine safety rules v3

1

RenewableUK: Health and Safety Circular 01

Wind Turbine Safety Rules (WTSR) Version 3 Interim advice on requirement for counter signature on the Approved Written Procedure (AWP)

May 2012 | H&S Bulletin 01

Details RenewableUK have received notification that following an incident (May 2012) which resulted in an electric shock of a technician, that at least one organisation has modified their operating procedures under the WTSR’s (Version 3) to require a second signature on the Approved Written Procedure (AWP).

While we have been made aware of this incident we are still unclear as to the factual details surrounding it as investigations are still being conducted. It is therefore inappropriate to comment any further at this point in time on the specific issues relating to the incident.

However we have been made aware that some RenewableUK members have expressed concern that the requirement to “mandate” a second signature could not only compromise the operational integrity of the WTSR but also potentially create serious practical and safety concerns.

This safety bulletin provides interim advice to members in relation to the general scope and application of the WTSR and specifically whether a counter signature on the AWP is required. RenewableUK will provide further clarification as soon as further relevant details are made available to us.

General scope of WTSR’s The WTSR have been operational since late 2005 and they have been extensively and successfully rolled out across wind farms in the UK and Ireland. There is wide-scale buyin, including positive feedback from site technicians. The scope and application of the rules provides a robust platform for ensuring health & safety risks are properly managed. In particular RenewableUK in fulfilment of its strategic health and safety objectives consider that the WTSR, when implemented correctly and appropriately will:

• Represent industry good practice for safeguarding employees from the inherent dangers that exist from installed electrical and mechanical equipment in wind turbines; • Assist in the development and application of safe systems of work in a consistent manner; and • Provide a robust approach to demonstrating legal compliance with relevant health and safety regulations.

In order to ensure that the WTSR are implemented correctly and appropriately and are suitable for any particular set of circumstances, RenewableUK strongly advise, prior to the implementation or revision of the WTSR into an organisation’s own health and safety management systems (or if operated as a standalone system) that the WTSR and all the supporting guidance are fully taken into account by a competent person.

It is essential that the final structure, content and format of any rules applied which incorporate any part of the WTSR are overseen and signed off by a suitable professionally qualified competent person familiar not only with WTSR but also their practical application taking into account site and turbine specific arrangements and all other relevant circumstances.

Signature requirements under the WTSR Under WTSR Version 3 there is a requirement for an Authorised Technician (AT) to complete a Signature Checkpoint once he/she has established both General Safety and Safety from the System. There is not a requirement for a second/counter signature at the Signature Checkpoint. The reasoning and safety justification include but are not limited to: • The specific AWP for the Work Package would have been created, authorised and approved by a person with adequate expertise and knowledge of the rules; • The written procedures would have been checked and approved by the Authorising Engineer, for the relevant Wind Farm, as Approved Written Procedures;

Onshore /Offshore | Wind | Commissioning /O&M

2

RenewableUK: Health and Safety Bulletin

• The Operational Controller is informed at the start and end of each work period of the operational state of the Plant / LV Apparatus and the WTSR require them to be immediately informed of the details of any transfers of AWP’ to new Authorised Technicians; and • Each AWP includes appropriate Signature Checkpoints at key points for the Authorised Technician to confirm that all safety precautions up to that point have been completed correctly.

In addition, due to the competency requirements required to operate under the rules – the second person in many cases is unlikely to be deemed competent or authorised to “sign off” the AWP and in turn verify General Safety and Safety From The System. Allowing such a person to sign could compromise safety and the operational integrity of the agreed rules in force.

Limited circumstances could apply where a second signature is either required or where additional safety verification is required. These include but may not be limited to: • Handover of system control for cross boundary situations where a second signature would be required. (See the WTSR Support Procedure, P7); or • When AWP is transferred to a second AT where there has been no ‘face-to-face’ handover (see WTSR B2.3.4); or • If safety precautions are applied by a second AT and instructions given by the AT responsible for the work – the second AT may be required to countersign precautions applied as per local instructions.

Companies should review the circumstances, albeit limited, when a second signature may be required.

Recommendations

• Review of training and competence in relation to the scope and application of the WTSR; • Review of policies and procedures clarifying status, application and operation of the WTSR; and • Consultation and communication with employees, contractors and others as to the status, application and operation of the WTSR as operated on the specified site(s).

It may also be appropriate to review any relevant incidents and near misses where non compliance with AWP’s and the associated human factors may have been a contributing factor. In all cases professional advice by a suitably qualified competent person should be taken into account.

All tasks and Work Packages will have their own circumstances and thus all specific AWP’ require review and acceptance by a competent person.

Reference & Links RenewableUK • Health & Safety Guidelines (2010) – www.bwea.com/pdf/ HSGuidelines.pdf • Wind Turbine Safety Rules v3 – www.bwea.com/safety/ safety_rules.html HSE • Electrical safety – www.hse.gov.uk/electricity/index.htm • Electrical standards – www.hse.gov.uk/electricity/ standards.htm • Electricity at work – Safe working practices HSG 85 (2003) • Memorandum of guidance on the Electricity at Work Regulations 1989. Guidance on Regulations HSR 25 (2007)

Contacts

In the absence of any more details relating to the incident that led to this bulletin, it is inappropriate to make specific recommendations. In particular we do not know if the primary cause was a failure of the procedure or alternatively a failure to correctly apply an agreed safe system of work.

However it is advised that all companies/sites operating under the WTSR take the opportunity to review how effectively they are being implemented and operated.

This could include, but is not limited to: • Review and where applicable revise relevant risk assessments;

Ref: RUK/HS/001/2012/SB

Doc: Safety Bulletin

Issue: 01

Date: 29/5/12

Approved: Chris Streatfeild

Status: Open

Circ: All HS Lists

Pages: Two

The contents of this bulletin are intended to provide a simple and clear summary of an important and often topical health & safety issue relevant to the core membership base of RenewableUK. They are not subject to regular review or updating, and so the accuracy of a bulletin can only assumed to be relevant and up-to-date at the time of publication. Detailed professional advice should be obtained before taking or refraining from action in relation to any of the contents of this bulletin, or the relevance or applicability of the information herein.

Chris Streatfeild Director of Health & Safety Chris.Streatfeild@RenewableUK.com 020 7901 3017 Nick Radforth Chair, Operational Safety Rules Group Nick.Radforth@rwe.com 07795353663

RenewableUK Greencoat House Francis Street London SW1P 1DH United Kingdom

Tel: +44 (0)20 7901 3000 Fax: +44 (0)20 7901 3001 Web: www.RenewableUK.com Email: Info@RenewableUK.com