Author unit / section:

HSE HID

Target audience:

Specialised Industries Division, Unit 3, Gas & Pipelines (SI3) regulatory and specialist inspectors

Purpose

To provide guidance to Inspectors on inspecting PE natural gas main and service installation standards and on enforcement policy. 

Background

1  The majority of new natural gas mains and service installations are PE and as the iron mains replacement progresses, over 3500 km of new mains are being laid annually, mainly by contractors to the gas distribution network operators.

2  Over the last year or so, Inspectors have found poor PE standards throughout the distribution networks. Usually these were dealt with on a case-by-case basis. However, inspectors continue to find poor standards and therefore the Gas & Pipelines Unit agreed that the inspection of PE installation standards should be a Unit priority for 2007–8. The Unit ran a PE Gas Systems Integrity Seminar in August 2007 to improve understanding of the main areas of concern, ensure a consistent approach and explore enforcement policy.

Scope

3  The scope of this guidance is limited to requirements for ensuring the safety of the PE installation. It does not include occupational health and safety risks during installation, for example the risk from gas during the safe control of operations procedure nor other risks such as construction and manual handling risks.

Legislation

4  The principal legislation governing PE installation standards are:

• Pipelines Safety Regulations 1996 (PSR), Regulation 9, Construction and installation;
• Gas Safety (Management) Regulations 1996 (GSMR), Regulation 3, Schedule 1, paragraph 4(a) – Particulars of technical specifications required in the safety case; paragraph 5 – Safety management and particulars of the arrangements he has made to comply with PSR. 
• GSMR Regulation 5 – Duty to conform with safety case.

PSR Regulation 9 – Construction and installation

5  PSR Regulation 9 states that:

The operator shall ensure that no fluid is conveyed in a pipeline (save for the purpose of testing it) unless it has been so constructed and installed that, so far as is reasonably practicable, it is sound and fit for purpose for which it has been designed.

6  The duty is therefore on the operator (not the installation sub-contractor) and only applies when gas is conveyed.

7  The duty is ‘so far as is reasonably practicable’. HSE expects, as a minimum, that operators should comply with good practice guidance. In respect of PE installations standards, these are covered in well-established industry procedures. And they are designed to ensure the installation remains sound and fit for purpose for 50 years or so. 

GSMR Regulation 3, Schedule 1, paragraph 4(a), paragraph 5.

8  The safety case should contain sufficient particulars on technical specifications and arrangements sufficient to show PE systems are installed to standards necessary to comply with the requirements of PSR Regulation 9. This may be covered by reference to an Engineering Requirements Manual and/or the mains and service laying manuals.

9  The safety case should include arrangements for ensuring adequate standards are met, employee and/or contractor competence, and monitoring and auditing health and safety performance. Poor installation standards may indicate wider failings in the operator’s management system, particularly at supervisor level.

GSMR Regulation 5 – Duty to conform with safety case

10  The conveyor has a duty to comply with the procedures and arrangements in the safety case.

Inspection check list

11  An Inspection checklist is at Annex 1. A template is available to record findings if required. 

12  .

13  The integrity of a pipe joint is affected significantly by its cleanliness, alignment and compliance with the correct fusion cycle. These failings are more serious on medium pressure systems where the risks are inherently greater than for low pressure systems.

14  .  

Enforcement policy and the application of EMM to PE installation standards

15  Enforcement decisions should be made within the framework of HSE enforcement policy [89KB] and the Enforcement Management Model (EMM) [135KB].

16  The paragraphs below discuss application of the EMM in helping Inspectors make consistent enforcement decisions. However, the EMM recognises it has limitations and cannot capture all the nuances and complexities of discretionary decision making in all circumstances. HID SPC/Enforcement /61 [117KB] provides guidance on the use of the EMM in HID, including its application to permissioning regimes. 

17  Inspectors should deal first with matters at a specific PE installation which, in their opinion, give rise to risk of serious personal injury. This could be as a result of a single failing (e.g. a misaligned joint) or combination of failings as described above. They should then consider how best to achieve sustained compliance with future PE installations. For this, Inspectors will need to consider two issues. Is the safety case good enough to control the risk? If it isn’t, the safety case will need to be revised. If the arrangements in the safety case appear satisfactory, then lack of compliance with the safety case will be the main issue. The enforcement options will vary depending on the situation found.

Risk of serious injury

18  EMM section 2 deals with risk of serious personal injury.

19  The Enforcement Guide states that where there is a risk of serious personal injury, then the initial enforcement expectation is a Prohibition Notice (PN) rather than an Improvement Notice (IN). A PN applies to activities which are being or are likely to be carried on and which will involve a risk of serious personal injury. Personal injury includes any impairment of a person’s physical condition (HSWA S53).

20  .

21  The PN should be served on the operator of the pipeline as they are the person who will convey gas and create the risk. It should not be served on the installation contractor.  

22  .

23  However, Section 5 of the EMM gives the option to vary the initial enforcement expectation (IEE - see below). Dutyholder factors are shown in the EMM in Table 6 and in flow charts 3 – 6. Flow chart 3 deals with the situation when a PN is the IEE. With a PN, there is no option to lower the IEE of a PN. Strategic factors can qualify this decision subject to management review but it is likely only to confirm the decision.

24  The operator may decide to remedy the situation before the PN is served.

25  As discussed, the PN will deal with the risk at a specific installation but Inspectors should consider whether they need to take further enforcement action to secure sustained compliance. Inspectors should therefore proceed through the EMM as below.

Achieving sustained compliance

26  The GSMR safety case should define both the technical and managerial arrangements to ensure the PE installations are fit for purpose. Operators have a duty to comply with the arrangements set out in the safety case. Where standards seen indicate failure to comply with mains and service laying manuals in relation to controlling risks from the gas, or with associated management arrangements (e.g. ensuring suitable competence and supervision), then these should be addressed.

Step 1 – Risk Gap Table 2.2

27  Risk gap analysis can be used to consider possible enforcement action where a duty holder has failed to adhere to conditions in the permissioning (safety case) document. The first step in the EMM is to determine the risk gap which compares the actual risk (where the operator is) against the benchmark (where the operator should be). Failure of a PE pipe could foreseeably lead to multiple off-site casualties and therefore risk Table 2.2 should be used.  

28  In referring to Table 2.2, the benchmark where the duty holder should be is a nil/negligible risk of serious personal injury (in this case to members of the public). If the standards are right and adequate managements arrangements in place, a properly installed PE pipe should be safe (excepting third party damage incidents) for its expected lifetime of 50 years or more. A failure to comply with arrangements in the safety case (or if the arrangements described are inadequate in themselves) could lead to poor standards of future PE installations. There is then a risk, even though remote, of a leak which could lead to serious personal injury. Risk Table 2.2 would then put the risk gap at substantial. 

Step 2 – Initial enforcement expectation (IEE)

29  Section 4 of the EMM deals with risk gap analysis as a guide to initial enforcement action (IEE). There are three tables covering IEE:

• Table 5.1 - Health and safety IEE
• Table 5.2 -  Compliance and Administrative arrangements IEE
• Table 5.3 – Permissioning IEE

30  Table 5.3 is for use only with Explosives licences, Mines exemptions, Fire certification and COSHH exemptions. It should not be used for the GSMR regime.

31  Table 5.2 - Compliance and administrative arrangements is concerned with requirements which are not in themselves risk based e.g. safety case not submitted, failure to provide information required by permissioning regimes.  This is unlikely to be relevant in this initiative.

32  Table 5.1 should therefore be used to determine the IEE.

33  The standard required for PE installations can be considered as ‘Established’ as they are set out in well-defined, industry wide documents (i.e. the mains and service laying manuals). With a risk gap of substantial, Table 5.1 then gives an IEE of an Improvement Notice.  

Dutyholder and strategic factors

34  Section 5 of the EMM considers the factors which may vary the IEE. Inspectors should consider firstly dutyholder factors and then strategic factors as to whether the IEE should be varied.

Step 3 - Dutyholder factors

35  Figure 4 gives guidance on duty holder factors when the IEE is an Improvement Notice. With an intervention on this scale, then this chart should be used with caution as it is more relevant for factory type sites. For example, if we consider the ‘Inspection history’ decision gate, previous ‘poor’ history leads to prosecution. This may be appropriate with wide spread, long term failures in improving PE standards but this should not be used for isolated incidents where the conveyor is trying to improve standards. Indeed, at the early stages of this intervention, a letter with agreed improvement plan would be acceptable. An IN may be required if improvements are not made in time. 

Step 4 – Strategic factors

36  There are a range of strategic factors which may impact on the final enforcement decision (see EMM Table 7). Inspectors have to ensure the public interest and vulnerable groups are considered. The public would rightly expect a new gas network to be installed properly so that it is safe.

37  Because of the complexity of this initiative, there may be a need for management review to agree enforcement decisions.

Enforcement notices

38  The wording for a sample prohibition notice is at Annex 2. 

Further information

For further information, contact HID Gas & Pipelines Unit SI3D.

Annex 1 – PE inspection checklist

Documentation	Comments
Does the team have access to main and/or service laying manuals?	The manuals allow the teams to check on current standards on site. It is industry best practice to have them on vehicles.

Pipe handling	Comments
Coil dispenser used?	Safety of employees/contractors. Minimises the risk of damage to the PE pipe.
Coil unbanding carried out in a controlled manner?	Safety of employees/contractors
Pipes and coils stacked correctly?	Safety of employees/contractors and public

Electrofusion jointing	Comments
Are all fittings stored in bags ready for use?	Cleanliness of the fittings is important to joint integrity. Contaminated fittings should be discarded.
Is there any evidence of damage on the pipe (10% rule)?	Damage where the joint is made potentially affects the joint integrity.  Although current standards allow for a 10% loss to pipe damage, it is poor practice to lay damaged pipe regardless of percentage loss.
Is there evidence of proper scraping on the pipe to be jointed?	Preparation of the pipe is critical to joint integrity. NB Pipe scraping is not normally carried out on peelable pipe.
Are the pipe ends cut square?	Contributes to proper joint alignment. If the joint has already been made, this is difficult to check see but it is a good question to ask how the pipe was cut.
Has the pipe exposure tool been used to remove skin on peelable pipe?	Failure to use a proper tool may damage the parent pipe.
Does the team have access to mains and/or service clamps for various sizes of pipe? And have they been used?	Use of clamps is important to ensure correct alignment and joint restraint during the fusion cycle.  This is particularly important on larger diameter mains. A range of clamps for the pipes being installed should be available on the vans.
Does the team have access to mains and/or service clamps able to clamp bends?	As above. Most teams have access to straight clamps but few have access to bend clamps.
Is there evidence of marking on the pipe to assist in aligning the pipe into the socket?	If there are no markings evident, it is difficult for the teams to demonstrate correct alignment.
Is there any evidence of misalignment?	Serious misalignment is unacceptable.
Has the correct electro fusing time been allowed?	This ensures quality of the joint. If clamps have not been used to restrain the joint during the fusion cycle, then it will be difficult for the installation team to demonstrate this.
For tees, has the correct loading tool been used?	Correct loading is necessary to ensure the tee/pipe joint is made properly. Too much pressure can result in weld being expelled from the joint, too little pressure results in a poor weld.
Correct cooling time been allowed before the clamp is removed?	This ensures the quality of the joint. If clamps have not been used, they can’t demonstrate this.
Have the joint indicators risen evenly?	The pop-up indicators show whether weld melt pressures were generated. In themselves they are not reliable in determining the quality of the joint. However, if the indicators have not risen evenly, then the quality of the joint may be poor.
Is there any evidence of melt that has come out of the fitting?	Indicates a possible poor fusion joint.
Has the fitting been allowed to cool to the correct time, before removing the clamps?	Ensures quality of the joint. The teams should be clear on cooling times.
Are the proximity distances between fittings correct?
Are services laid at shortest length SFAIRP?	The design, construction and installation of gas service pipes, Approved Code of Practice and guidance, L81, paragraph 11, requires the service pipe to be designed ‘ …. in such a way that it is least likely to be affected by third party interference or subject to accidental damage’. The guidance in paragraph 16 states that ‘the route should be the shortest route possible, SFAIRP. There has been evidence of poor practice in industry of excavating a small hole and then squeezing in as many service connections as is possible, resulting in confused and congested services pipe runs. It can result in several service pipes running parallel to the main, increasing the risk of third party damage. The practice often requires several joints and elbows within a short distance to align the services to the main. A larger excavation allows greater flexibility to align the service directly on to the service tee.
Are squeeze off points far enough away from other fittings?	Squeeze offs too close can damage existing joints.
Have squeeze offs been re-rounded?	Removes stress within the pipe.
Is there a re-rounding tool available (sometimes same tool as a mains clamp)?	As above.
Have squeeze offs been correctly taped?	Additional squeeze off operations can affect pipe integrity.

Butt fusion joints	Comments
Was the first weld off the day, cut out and discarded?	Ensures plates are clean. For larger diameter pipes, often two welds are discarded.
Is the hot plate clean and smooth?	Ensures joint cleanliness.
Is the trimmer sharp and free of debris?	Preparation of joint face important.
Have joints been left in fusion machine until the end of the fusion cycle?	Ensures quality of the joint.
Are there any precautions taking to protect against adverse weather, e.g. a shelter, end caps to prevent wind chill?	Ensures quality of the joint.
Pipe roller supports used?	Contributes to joint alignment and joint closing force.
Have beads been removed with an approved bead removal tool?	The geometry of the beads are used to check the quality of the butt fusion and a proper tool should be used.
Have bead widths been measured using a bead gauge?	Confirms joint made properly.
Have beads been numbered and retained?	Audit arrangements.
Has bead checks been retained in a “project file”?	Audit arrangements.

Annex 2 – Draft improvement notice

….. hereby give you notice that I am of the opinion that the following activities namely:

The conveying of natural gas in a polyethylene pipeline

which are being carried on by you/likely to be carried on by you at: 

Location/network address/place of activity

involve/will involve, a risk of serious personal injury, and that the matters which give rise/will give rise to the said risks are:

[summarise the failings seen in the installation standard] such that there is a risk that the pipeline will fail, release natural gas and expose people, including members of the public, to a risk of fire and explosion

and that the said matters involve/will involve contravention of the following statutory provisions:

Pipelines Safety Regulations 1996, regulation 9 
Because

the pipeline has not been constructed and installed that, so far as is reasonably practicable, it is sound and fit for purpose for which it has been designed

and I hereby direct that the said activities shall not be carried on by you or under your control immediately/after [date] unless the said contraventions and matters have been remedied.

Add schedule if appropriate.

Exemptions
Law Enforcement (Section 31):	Paras 6, 12, 14, 20, 22 First exemption in Annex 1 checklist
Commercial Interest (Section 43):	Second exemption in Annex 1 checklist