PROCEDURE - TUMUT ISOLATION & LOCKOUT VPP OP-049 INTENT. Why. How

Transcription

1 VPP OP-049 INTENT This procedure defines the steps to be taken to isolate and lockout energy sources to manage the risks associated with working on mill plant and Why It is a regulatory and risk management requirement to make sure that when personnel need to access plant for the purpose of maintenance, cleaning or repair and certain operational tasks that the plant is stopped, isolated and locked and that safe systems of work are in place to ensure the work is performed safely. How 1. Key Principles There are some basic key principles underlying this lockout and tagging process, each in place to protect people working on plant from sources of energy associated with the plant: Assess plant and identify isolation points (considering the scope of work to be performed, the nature of and the sources and magnitude of energy sources) Stop/shutdown the plant or machinery in a controlled manner. Isolate, dissipate or restrain the energy sources; Lock out the plant or machinery with appropriately secured isolators Verify the isolation is effective Apply individual personal locks Perform the work Remove locks and isolators Verify plant and machinery safe to return to service Re-energise the plant 2. When is isolation and lockout required? Isolation and lockout is necessary whenever workers are performing service, maintenance or operational work around any piece of plant where the worker(s) could be injured by the unexpected release of an energy source or process contents. An example of situations when isolation and lockout is required includes: work where removal or bypass of guards or safety devices is necessary to perform work; when workers are required to place any part of their bodies where they could be caught by moving machinery; work on electrical (including High Voltage) work on mechanical with potential for movement or auto starting eg conveyors, motors, pumps, drives LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED - VERSION 16 PAGE 1 O version

2 clearing jammed mechanisms working on lines or vessels (including those containing chemicals and harmful contents) entering confined spaces working on natural gas lines working on or in close proximity to radioactive sources 3. Isolation Procedure 3.1. Assess and identify energy sources and Isolation points All energy sources likely to place people performing the work at risk, must be identified. Operations are responsible for ensuring all the isolation points are identified, listed and locked out. During this assessment the following things must be considered: The scope of work to be performed The nature of the involved, including adjacent systems The sources and magnitude of the energies involved. During the assessment operations will also determine the most appropriate methods of controlling the energy and the possibility that the plant might become re-energised or energy might re-accumulate whilst work is being conducted (eg static electricity). P&ID s, drawings, and or plant inspections must be used to ensure all isolation points are identified within an energy system. An isolation list including all isolation points will be generated (see Section 3.2) Energy/hazard sources may include: Electrical (power supply, static charges, batteries, capacitators) Mechanical (mechanical drives, moving and rotating ) Pressure (steam, compressed air, vacuum, hydraulics) Gravitational (counterweights, vehicle runaways) Potential (springs, structural strain) Thermal (hot or cold surfaces and substances, heat radiation) Noise Vibration Ionising and Non-ionising radiation (lasers, welding, electro-magnetic fields, microwaves) Hazardous substances or process chemicals. 3.2 Isolation lists Where there is a need to isolate plant and the Production Engineer will identify the plant and to be isolated. The plant and to be isolated and the isolation points will be determined using the relevant P&ID s, plant knowledge and a physical check of the plant. The plant, and isolation points will be listed on the Isolation list. Where an isolation list has already been developed for previous use then the Competent or Authorised Production Engineer shall review and ensure it is correct before use, and not automatically follow the developed list. An Isolation Officer must also sign the list to validate the isolation. Changes to the list must be authorised by an Isolation Officer. If an isolation list does not exist for that apparatus then Authorised Production Engineer will develop the list as described above, identifying all of the isolation points in sequence. Validation of a new isolation list is required by an Isolation Officer for that area. The Isolation Officer for that area must verify the isolation list is correct and sign the Isolation list. A Production Engineer shall ensure isolation of the system according to the isolation list and sign against each isolation point on the list verifying that each point has been isolated. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 2 OF 14

3 The isolation list is placed on the lockout board or in a plastic sleeve attached to a lock box once the isolations are completed. 3.3 Shutdown of Equipment If is operating, the person authorising the work shall verify that it is safe to shut down the. The plant shall then be stopped using established methods for that operation. The must be allowed to run down completely before commencing the isolation process. 3.4 Isolating Energy Sources Single Point, Single Person Lockout (Operations tasks only): Where there is a requirement to work on a piece of fitted with a single point of isolation and there is a single person work crew, then a personal lock may be used to lockout out the positive isolation point (where it is a full load current isolator, or cat 3 local isolator mechanism) Multiple Isolations (involving multiple points or multiple persons): Single point, multiple person or multiple point, single person or multiple points, multiple person isolations must follow the process described for system isolations. Operations must ensure the isolation of all energy sources and potential hazards to those working on the plant are completed before permission and access is provided to personnel to perform work, including work being performed by Operations personnel. Persons deemed competent in the specific isolations shall perform the actual isolation. Isolation of energy sources shall be achieved by physically interrupting the supply of energy. The means of isolation should be of a type that can be readily checked by visual inspection and it should act directly on the supply line. It should not act through control circuits or emergency stop mechanisms, (unless they are Category 3 Safety mechanisms). Specific personnel can only perform the following system isolations: Electrical Isolations: Electrical isolations must be completed by a qualified electrician or electrical engineer, with the exception of Local Full Current Isolators High Voltage (HV) Isolations: Isolation of HV must be completed in accordance with the sites High Voltage Procedure and by personnel as detailed in the HV procedure Radioactive isolations: Isolation of radioactive gauges or must only be completed by an authorised Radiation Safety Officer Natural Gas isolations: Isolation of all natural gas lines will be under the authority of the Pulp Mill senior management, including lines that run outside the pulp mill boundary. Permits to work on this system must be issued by the Pulp mill operations Plant isolators Plant and shall be fitted with isolators on the main energy supply sources to provide a positive isolation of the energy source. Plant that does not currently have isolators fitted should be assessed and based on risk, a determination by management should be made regarding installation of isolators. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 3 OF 14

4 3.4.8 Full load current Isolators (or Cat 3 Control Isolators) Full load current isolation switches can be used for isolations. Where they are provided and clearly identified, operations may isolate and lock on at these points. The plant to be isolated must first be stopped in a controlled manner via the operating system eg. DCS. When the piece of plant has completely stopped and all stored energy is exhausted a personal or system lock will be applied. (See 3.4.1) Isolation Equipment Equipment used to prevent re-energisation should be durable, securely fastened and sufficient enough to prevent easy or accidental removal (without the use of a key or a tool) Equipment used to restrain energy sources, (such as locking pins, chains, slings, blanking plates), must be able to ensure the magnitude of energy can be retrained, must be certified to an appropriate load rating, and must be inspected and maintained. Locks must comply with the following : Personal Locks: Colour of the lock must be RED Clearly marked with the identification of lock holder & contact details Must be of a type with single unique key System Locks: (Equipment) Colour of the lock shall be GREEN Lockset numbers shall be clearly marked on the locks Keyed alike LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 4 OF 14

5 Operations Locks Colour of locks shall be YELLOW Must be a single key Lockout Boards: These are central lockout locations. They contain: Lockout identification card: the title identifying the isolation Isolation list Operations lock (for isolations that will extend over long periods and work may not be continuous) Remaining system locks and keys Key locking device: This is used to hang unused locks for an area lock set and the key covered by a plate and sealed. Personal locks are then attached. Isolation list: A list of isolation points for a piece of. Isolation list also details the seal number, lock set number, number of locks in a lock set and the number of isolation points. Scissor clamps: A scissor type device which clamps onto a lockout point and is locked in place by a worker positioning a personal lock onto the lock holes. Used when more than one worker may be involved in locking out a system. Seal: A metal or plastic seal with an individual number imprinted on it and used to provide visual indication of the integrity of an isolation. It is attached to the key locking device or lock box to secure the remaining system keys and locks in place. The seal number is written on the Isolation list. Lock Boxes: Where it is not practicable for an isolation to be setup on an isolation lockout board and the isolation needs to be located in proximity to the field, then a portable lock box can be used. The lock box contains the same information as an Isolation board. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 5 OF 14

6 System/Plant Isolations and lockouts System isolation and lockout involves making safe single or multiple process systems or plant/machinery for work to be performed. System locks (from a set of locks), must be used for all plant isolation lockouts. System locks will be prepared and applied by the Authorised operator onto the isolation points listed in the Isolation list. System locks must be used for isolating, and spare system locks and keys must be attached to the key locking device on the lockout board and must be secured by a plate and numbered seal, in preparation for personal lock application. 3.5 Dissipating and controlling energy Dissipating Energy: After the energy sources are isolated, any stored energy in the should be dissipated. This can be achieved by measuring including: Opening valves to drain pipelines, pressure vessels and hydraulic accumulators Depressurising with potential to move and create a clamp or crush hazard (e.g. hydraulic systems) Opening access hatches and inspection covers Earthing electro static separators Discharging electrical energy stored in capacitors Releasing springs and Lowering counterweights The method of energy dissipation shall be selected to ensure that energy does not re-accumulate over time or during the course of work Restraining plant, material and energy sources: If internal sources of energy can not be dissipated, they shall be adequately restrained by measures such as: Inserting mechanical locking devices such as chocks, pins or sprags Securing items that can move such as fans and mechanical linkages with chains Closing cover plates on radioactive gauges Applying brakes 3.6 Verify Isolation The person authorising the work shall ensure competent persons verify that all hazardous energies have been effectively isolated, dissipated or restrained. This must be noted on the isolation list. Verification may be done by visually checking the energy controls, by reading gauges and meters, by attempting to start the plant or by other suitable tests. However, no attempt to start the plant shall be made if work has already started on the plant. If the scope of the planned work changes at any time, then re-assessment of the energy isolation may need to be conducted. In the event of a test demonstrating that isolation has not been achieved then isolation must not proceed until the isolation has been reviewed and approved by the Area Manager or their delegate. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 6 OF 14

7 3.7 Personal Lockouts Personal locks are applied to a system lockout on an isolation board/box and must be connected to a scissor clamp, to indicate persons working on the isolated and to prevent inadvertent operation of the apparatus whilst persons are working on the. They can also be applied to a single point of isolation for a single person, single isolation point, operational task. (Refer Section and 3.4.2) Personal locks must be RED in colour and individually keyed. All persons working on a system which is locked out are responsible for placing personal locks on the associated isolation lockout board/box. Each person is responsible for applying and removing their own locks. Prior to placing personal locks onto isolations the person should: Review the permit and identify the /system by the card identifying the lockout title. Check the seal is intact and that the seal number corresponds with the seal number entered on the isolation list. Apply a personal lock to a scissor clamp on the key-locking device. Sign onto the relevant work permit, indicating their lock number/details Swapping locks and keys is not permitted. Personal locks must be labelled with the persons name, phone number and where relevant contracting company. Visy employees and permanent contractors will be provided one personal lock and associated key. Temporary contractors must provide their own individually keyed locks that meet the following criteria: Individually keyed Red Lock Marked with printed legible information containing: the name of the person; the contracting company and a phone number that is to be used whilst person is on site. The locks must be approximately 38mm X44mm in dimension with a shackle clearance of approximately 38mm, to physically accommodate shackling to a scissor clamp or lockout device. 3.8 Operations (Yellow) Locks Where is being worked on and is going to extend over more than one shift or cease for some reason, but may not be continuous, then an Operational lock must be used to maintain the integrity of the isolation during the time between the working parties leaving and returning to the isolation point. Formal sign over of the Operations lock between (Area or Operations and/their delegates) will be via an attachment of a Identification tag on each yellow lock. For example a crew of maintenance personnel may be working on an isolated plant during a day shift and the work will take several days. Over the night shift there is no work on the isolated plant. To ensure the plant is not inadvertently de-isolated before the work is completed the Operations lock signifies the system is not safe to start up. The Operations lock communicates to all personnel that work is in progress and not yet finished, and that de-isolation cannot commence, even though no personal locks are in place (as the work crew may have finished for the day/shift) The key to the Operations locks can be stored in the Operational Control rooms (in a designated key box), and can only be applied and removed by the Operations Engineer or the level of operational management above them (or their authorised delegate). The same checks required for work that is completed within a shift must be verified before the Operations lock is remove, including: check the system and plant integrity ensure all work is completed LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 7 OF 14

8 Equipment is clear of people, tools and materials. An identification tag must accompany each operational lock with the Area or Operational name and contact phone number listed on it. 3.9 Removal of Personal locks At the completion of work individuals must sign off the work permit and remove their own personal locks. Where a person has left site and failed to remove their locks the following steps will be taken: Effort will be made to contact the worker to return to site to remove the lock. where circumstances prevent the worker from returning to site, or where a worker cannot be contacted then the Senior Production Engineer will contact the Weighbridge to check the site access database to ensure the name of the worker is registered as having swiped off site The Senior Production Engineer will ensure the Lock Removal Checklist/Form (VP FM-0049) is followed and a physical check has been made of the area before removing the lock. If the worker is not able to be contacted his/her site access card will be cancelled preventing access to site and requiring them to present for approval for re-access. All lock removals completed under this section require the completion of a Lock Removal Checklist form. (VP FM-0049) and record the incident into Vault. In the event that a person loses their keys to their personal lock, then the Senior the persons manager or supervisor must be informed. The lock(s) must be destroyed and a new lock(s) and key(s) issued De-Isolation and re-energising plant/verify safe return to Operation Before removing the last isolation locks, the worker or group of workers involved shall: Check and ensure that the plant is clear of tools,, materials and persons; Check and ensure that all guards have been replaced, and the plant is fit for use. Restore and verify all safety devices that have been removed or bypassed After the last worker removes their personal locks, the Authorised Production Engineer must check the system and plant integrity prior to re-energising the plant and ensure all work is completed and is clear of tools and materials. Where an Operational Lock has been applied then the designated Operations Engineer shall remove Plant shall be restarted in accordance with standard operating procedures Variances Variations to isolation must be approved by the Isolation Officer for the area before the variation is implemented. Where a variance to an isolation is required: All permits issued to work on the system must be cancelled after all personnel have signed off the permit Personal locks must be removed from the lockout board The variance can then be made by an Authorised Production Engineer Changes must be written on the Isolation list and approved by an isolation officer Authorised Production Engineer will apply a red Variance sheet to the Isolation board to alert work crew members of the variation in isolation. The system lock sets and a new seal is reapplied to the key locking device A new permit is issued referencing the new isolation list and the work party reviews and signs onto the new permit Individual locks can then be reapplied once the details of the variation are explained and understood LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 8 OF 14

9 3.12 Out of Service Tags Where an item of plant, or machinery is defective or inoperable then an Out of Service tag must be used to advise potential users that the use of the apparatus would create an unacceptable level of risk. The tag should be applied directly to the operating controls or starting mechanisms, and preferably these mechanisms should be rendered inoperable (e.g. removal of key) Removal of the Out of Service tag can only be performed by the person who repairs or reinstates the to its safe working state, or by the person who applies the tag or by the relevant Operations manager once safe operation is verified. All instances where apparatus is faulty and tagged out, must be reported to the Senior Production Engineer immediately so that a work order can be raised for its repair. Incident reports must be raised in the event of damage so that an investigation into the cause can be conducted Work Extending over One or more shifts Where work extends over one day or shift, workers must remove all personal locks at the completion of the work day or shift and sign off the work permit. The system isolation and locks stay in place. An Operations lock must be used to maintain the integrity and provide information regarding the status of incomplete work where work is not continuous. Permits may remain open/active for a designated period extending over one or more shifts where the work is continuous, and this will be specified and recorded on the permit at the time of issuing the permit. The permit must be signed over to the incoming Supervisor of the new crew coming in, workers must apply their personal locks and sign on to the permit Working on energised In some circumstances, it may be necessary to work on plant when the source(s) of energy have not been isolated. Work such as adjustment, monitoring, fault tracing, may require the plant to be energised. In all cases if the plant can be isolated to complete the work then it shall be. Tasks that require plant to be energised must be identified and any such work on live plant shall only be carried out in strict accordance with a documented risk assessment with adequate controls to ensure the safety of the workers involved. Work on energised must be approved by the relevant Operations Senior Manager. Personnel who perform work on energised plant must be authorised in writing to perform this work. Relevant training must also be provided to ensure work is performed safely and in accordance with any relevant standards Maintenance of System Locks The Isolation Officers will be responsible for the maintenance and inspection of systems locks. Each set of system locks will have an identification tag attached indicating the total number of locks in the set and the lock identification number. When new system lock sets arrive on site, 1 key will accompany the lock set and the remaining keys will be provided to and secured in Stores. System locks will be stored in the control rooms in designated areas and must be regularly inspected and cleaned by operations or as required by the isolation officers. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 9 OF 14

10 3.16 Long term isolations For plant and, still in situ and operable, but out of the process, a long term isolation maybe required. Plant that is decommissioned (i.e. de-energised from an MCC or energy source) does not require a long term isolation. Long term isolations will be carried out as a normal isolation, with all relevant procedural checks in place. Long term isolations will be listed in a Long term Isolation Register that will be kept by the Isolation Officers for their areas. The following information shall be recorded: Asset number Type/model number Location Energy source Isolation mechanism Expected duration of isolation Lock description (colour/tag information) 4 Training All personnel involved in the execution of the plant and isolations and lockouts must have completed relevant training and refresher training on this procedure. A list of trained personnel will be kept in the sites training register. Training shall be categorised as: 4.1 Basic training (level 1): for all personnel who will or may potentially work under a permit or isolation. This level of training is undertaken at induction. 4.2 Operational (Level 2): for Operational personnel conducting isolations and lockouts and issuing permits to permit holders. Assessments will be undertaken to determine competency in isolating plant and in mill areas. 4.3 Records of competency training will be kept in training files 4.4 Refresher training shall be conducted every 2 years or whenever there are significant changes to the sites isolation procedures 5 Contractors Contractors who are required to work under work permits and on plant and, must be provided instruction on Visy s isolation and permit procedures and must comply with all of the outlined Contractors are responsible for correctly identifying, applying and removing their own personal locks from isolation points within the mill. 6 Documentation Completed Isolation lists and work permits must be filed and kept for a period of 1 month following completion of the works. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 10 OF 14

11 7 Compliance/Breaches All employees and contractors are required to comply with the of this procedure and the restrictions imposed upon them during the lockout. The following actions will result in disciplinary action: Removing another persons lock Energising and or operating that has an isolation lock or other isolation device. Working on that has been isolated or locked without signing onto the permit and applying their personal isolation device to the isolation Failing to isolate and lock out which leads to others working on energised When an employee or contractor is found to be in breach of the Isolation/Lockout procedures the following actions are to be taken. Notify the Senior Production Engineer on shift and/or the relevant Area Manager The Senior Production Engineer and/or the Area Manager are to ensure the notification process is followed and all relevant management are notified as per Visy Standard 402 Notify the person s supervisor. Enter the incident and investigation details into The Vault data base and if required an SSO is to be raised within 24 hours following the breach. If required ensure disciplinary action is recorded and actions are carried out in a timely manner. 8 Audits During peak periods of activity involving permits and isolations, formalised regular audits shall be conducted. Findings from audits will be collated and used in the annual review process to ensure that the procedures and their application are continually monitored and improved. Supervisors and area managers must also regularly check compliance with these procedures to ensure rigorous adherence. 9 Definitions Plant Isolation Isolation is the physical rendering safe of any energy source through disconnection, physical separation of energy, removal of source or physical blocking/blanking to allow personnel to work on or near plant or machinery without risk of exposure to the process or energy source. Production Engineer Person employed to operate an area of the mill production. Eg Fibreline Production Engineer Authorised Production Engineer A Production Engineer who has completed the sites required training and assessment process or has been given written authorisation by the Pulp/Paper Mill Manager. An operator can be authorised by an Area Manager but must meet the following criteria. Operator must be enrolled into the training program for the area Where relevant the operator must be competent in like Must have 12 months operational experience in the area Must have completed the site Isolation Lockout Training (level 2) A data base will be kept on H drive of Competent Authorised persons to sign isolation lists for each area. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 11 OF 14

12 Isolation Officer As Tumut is a 24/7 operation the Isolation Officer can be an Area Engineer, Operational Engineer or a Competent/ Authorised Production Engineer and can be responsible for the following: Ensuring long term isolations are effective and maintaining the long term isolation register. Ensuring group isolations lists are correct Producing isolation lists and reviewing procedures Participating in audits as required Participating in incidents investigations of isolation breaches Appling Operational (yellow) locks to isolations that will extend past a working shift (Area Engineer or their Designee) Advised of and approved a variance made to an isolation in their area. Maintaining the system lock sets for their area. Work Permit: A document providing operational approval to enter into an area to perform work. Permit Holder: The person who receives and holds the work permit. The permit holder is typically the person who is responsible for supervising the work to be undertaken. Dissipate: Release and discharge of energy stored or contained in plant. 10 References VP OP-031 Work Permit Procedure VP WI-049 Isolation Lists VP FM-0049 Lock removal checklist/form Visy Code of Practice: Isolation and Lockout 2010 AS/NZ Pressure Equipment Operation and Maintenance AS/NZ Safeguarding of Machinery AS Padlocks Work Health & Safety Regulation 2001 Visy Standard V402 Incident Management LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 12 OF 14

13 Key Responsibilities Mill Manager Production Manager Pulp Mill & Paper Machine Manager Area Operations Senior Production Isolation Officer Maintenance Contractor Supervisors Production Contractors Isolation Methods Ensure Accurate transmission of information on the COP and make certain the COP and Site Procedures are implemented and followed. Ensure Accurate transmission of information on the COP and make certain the COP and Site Procedures are implemented and followed. Ensure Accurate transmission of information on the COP and make certain the COP and Site Procedures are implemented and followed. Ensure Compliance with Isolation Methods Ensure Compliance with Isolation Methods establishing and complying with isolation methods Ensure Compliance with Isolation Methods Ensure Compliance with Isolation Methods Compliance with Isolation Methods Compliance with Isolation Methods Authorised isolation Devices Ensure Compliance with site isolation Ensure Compliance with site isolation Provide isolation devices in accordance Provide Locks in accordance with key Provide Locks in accordance with key Responsible for performing isolations Use of locks in accordance with key Use of locks in accordance with key Use of locks in accordance Use of locks in accordance Competency and Training Ensure compliance Ensure compliance Ensure compliance and have input into the training material. and assessment process and verify training or competency level of employee prior to isolation training as required level 2 operator training program and verify training or competency level of employee prior to isolation level 1 isolation lockout and work permit training program. level 2 operator training program level 1 isolation lockout and work permit training program. LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED - VERSION 16 PAGE 13 OF 14 version

14 Key Responsibilities Mill Manager Production Manager Pulp Mill & Paper Machine Manager Area Operations Senior Production Isolation Officer Maintenance Contractor Supervisors Production Contractors Energised Equipment Ensure Compliance Ensure Compliance with key Ensure training has occurred for authorised individuals and only those authorised are to work on energised Ensure only authorised personnel are working on energised Ensure only authorised personnel are working on energised Supervise persons working on live energised Ensure only authorised personnel are working on energised Supervise persons working on live energised Ensure training has occurred for authorised individuals and only those authorised are to work on energised Ensure training has occurred for authorised individuals and only those authorised are to work on energised Comply with working on energised Comply with working on energised Audits and investigations Ensure audits are conducted and documented Ensure corrective actions from audits are reviewed and documented and where required implemented Ensure corrective actions from audits are reviewed and documented and where required implemented audits where required audits where required audits where required audits where required audits where required audits where required audits where required Isolation Plans and Procedures Ensure compliance Ensure compliance Ensure compliance Produce isolation plans and procedures as required by key Ensure employees comply with isolation plans and procedures Produce isolation plans and procedures as required by key Produce isolation plans and procedures as required by key Ensure employees comply with isolation plans and procedures Comply with isolation plans and procedures Comply with isolation plans and procedures Incidents and isolation Breaches Ensure system for investigation and breaches Ensure all breaches are investigated Investigate any breaches, incidents, issues and determine corrective actions Investigate any breaches, incidents, issues and determine corrective actions Investigate any breaches, incidents, issues and determine corrective actions Report all incidents and issues and participate in investigations Report all incidents and issues and participate in investigations Report all incidents and issues and participate in investigations Report all incidents and issues and participate in investigations Report all incidents and issues and participate in investigations LAST PRINTED 8/07/ :49:00 PM UNCONTROLLED WHEN PRINTED VERSION 16 PAGE 14 OF 14