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Write a risk assessment for The project involves carrying out above- and below-water RT testing on one of the pipe welds on the offshore platform, bearing in mind that there are shift personnel on the platform (the matrix must comply with EGPC 6×6).

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For above-water and subsea RT of a pipe weld on an offshore platform, the task should be treated as a high-risk simultaneous operation requiring a formal task-specific risk assessment, radiography procedure, permit to work, and strict coordination with offshore operations, marine, and diving controls. The main hazards are uncontrolled ionizing radiation exposure to radiographers, shift personnel, divers, and vessel crews; unauthorized entry into the radiation area; dropped objects and work-at-height hazards above water; drowning and hypothermia risks; vessel or skiff transfer hazards; subsea entanglement, current, and loss-of-life-support hazards for divers; and failures in communication or emergency response. A competent person should periodically conduct and review a task-specific risk assessment for work over or near water, identifying hazards such as drowning and equipment overturning into water. Radiation work must be under a designated radiation safety officer who establishes operating and emergency procedures, ensures exposures are kept as low as reasonably achievable, verifies surveys are performed and documented, and can terminate operations if unsafe conditions exist. [1] [1] [1] [1] [4]

Hazard identification and typical EGPC 6×6-style risk assessment approach:

  • Ionizing radiation from the exposure device or X-ray set: credible consequences include fatal or serious overexposure if personnel or divers enter the beam or source-controlled area; initial risk is typically extreme/intolerable until engineered and administrative controls are in place.
  • Simultaneous operations with shift personnel present: routine platform movement, adjacent maintenance, crane operations, hot work, scaffolding, and vessel traffic can lead to inadvertent entry into the controlled area or disruption of barriers and communications.
  • Above-water offshore hazards: work at height, dropped objects, slippery decks, poor lighting, weather, wind, wave motion, and overboard risk.
  • Subsea hazards: diver entanglement, current, poor visibility, umbilical damage, hazardous mechanisms or pipe intakes, loss of communications, and inability to rapidly evacuate the diver from the radiation field.
  • Marine hazards: transfer by boat, skiff, or barge; collision or drift into exclusion zones; man-overboard; cold-water exposure; and rescue delay.
  • Confined or poorly ventilated adjacent spaces, if applicable: oxygen deficiency, flammable atmosphere, hydrogen sulfide, and restricted rescue access.
  • Human factors: night shift fatigue, miscommunication between radiography crew, control room, marine control, and dive supervisor, and failure to maintain surveillance.
  • Emergency scenarios: source fails to retract, X-ray fails to terminate, barrier breach, diver distress, man overboard, weather deterioration, or medical emergency during exclusion.

Using an EGPC 6×6 matrix, assess each hazard by severity x likelihood before controls and after controls. For radiation exposure to uninvolved personnel or divers, the inherent risk should normally be considered at the highest level because a single control failure can cause severe injury. The job should proceed only when residual risk is reduced to the organization’s acceptable level through layered controls: elimination of unnecessary personnel, isolation of the area, time-distance-shielding, verified communications, competent supervision, and emergency readiness. If residual risk remains high because the platform cannot be cleared, the dive spread cannot be isolated, or exclusion cannot be guaranteed, the RT should be postponed or an alternative NDT method considered. [1] [1]

Controlled area, exclusion zone, and radiation protection controls:

  • Establish a controlled area based on a pre-job radiation survey or calculated dose-rate boundary for the specific source strength, exposure geometry, deck layout, splash zone, and subsea geometry. The boundary must prevent any unauthorized person from entering a high-radiation area.
  • Post radiation warning signs at all access points and along any pathway leading to the area, including temporary barriers.
  • Maintain constant surveillance of the temporary job site and take immediate action to prevent unauthorized entry.
  • Use physical barriers, barricade tape, hard barriers where practicable, access control, and dedicated sentries at all approach routes, ladders, stair towers, boat landings, and subsea access points.
  • For subsea RT, define both a surface exclusion zone and an underwater exclusion zone. No diver should be in the water within the radiation exclusion zone during exposure unless the approved technique specifically demonstrates zero credible exposure to the diver and is accepted by the radiation safety officer and dive supervisor; as a conservative best practice, suspend diving during exposures.
  • Coordinate with marine control so that standby vessels, workboats, and crane barges remain outside the exclusion zone during exposure windows.
  • Apply ALARA: minimize exposure time, maximize distance, use shielding where feasible, collimate the beam, orient the beam away from occupied areas, and use remote exposure devices and remote monitoring.
  • Perform and document radiation surveys before first exposure, after any setup change, and after completion to confirm the source is shielded or the X-ray beam is off before re-entry.

[1] [1] [1] Personnel monitoring, competency, and supervision:

  • All radiography personnel should wear assigned personal dosimetry during operations. At temporary job sites, use both passive dosimetry and a direct-reading dosimeter or electronic personal dosimeter.
  • Recharge or function-check direct-reading dosimeters at the start of the shift, read them daily, and record exposures.
  • If a direct-reading dosimeter is off-scale or reads above its range, stop the person from further radiation work until exposure is evaluated.
  • Only trained, authorized radiographers and assistants should conduct the work, under the oversight of the radiation safety officer.
  • Use a pre-job toolbox talk covering radiation boundaries, SIMOPS restrictions, emergency signals, source recovery actions, marine hazards, and stop-work authority for all affected departments, including operations, marine, and diving teams.

[1] [1] [1] [1] Permit to work and SIMOPS requirements:

  • Issue a dedicated radiography permit to work linked to the offshore SIMOPS plan, shift handover, and area authority approval.
  • The permit should define exact location, source or X-ray unit details, exposure times, exclusion boundaries, affected decks and compartments, adjacent work restrictions, communication channels, emergency contacts, and permit validity period.
  • Suspend or prohibit incompatible simultaneous operations within or near the exclusion zone, such as diving, over-side work, crane lifts through the boundary, hot work that interferes with barriers, and non-essential personnel movement.
  • If the RT location is in or adjacent to a confined or enclosed space, attach the relevant confined space or hot work permit and verify atmospheric testing, ventilation, isolation, standby arrangements, and rescue planning before entry.
  • If work is interrupted, conditions change, alarms activate, weather deteriorates, or the boundary cannot be maintained, stop work and revalidate the permit and risk assessment before resuming.

[3] [3] [6] [7] Emergency response expectations:

  • Prepare a written radiography emergency plan at the worksite covering source stuck out, damaged source assembly, loss of shielding, accidental exposure, barrier breach, medical emergency, man overboard, and diver emergency.
  • The radiation safety officer or designated competent person should control source recovery actions; non-essential personnel must remain outside the exclusion zone until the area is surveyed and declared safe.
  • Emergency communications must be tested before the job between radiography crew, area authority, control room, marine control, and dive supervisor.
  • For any accidental exposure indication, isolate the area, account for personnel, secure dosimeters, obtain urgent dose assessment, and arrange medical evaluation.
  • For confined or enclosed-space interfaces, rescue procedures must be written and available at the job site, with standby personnel and communications maintained.
  • For diving interfaces, ensure rescue-capable dive team members and equipment are present when exceptional hazards exist.

[1] [3] [3] [7] [5] Marine and diving safety controls for subsea RT:

  • Treat subsea RT as a combined radiation and diving SIMOPS activity requiring joint authorization by the radiation safety officer, offshore installation manager or area authority, marine control, and diving supervisor.
  • Before diving near any pipe intake, tunnel, duct, or similar installation, stop flow, lock out the intake mechanism, and do not restart until the diver is clear of the water.
  • Where divers approach hazardous mechanisms or intakes, use surface-tethered or surface-supplied diving equipment with effective two-way voice communication, as applicable.
  • If contamination is possible subsea, prepare an operational plan identifying contaminants, exclusion zones, contamination reduction measures, PPE, first aid measures, and emergency contacts.
  • For over-water work, provide approved flotation where there is drowning risk, inspect flotation devices before use, and have ring buoys and rescue craft immediately available.
  • Control vessel movements and personnel transfers during exposure windows; no boat should enter the marine exclusion zone without authorization.

[5] [5] [5] [4] [4] [4] If the RT setup involves enclosed spaces, caissons, flooded cells, or other restricted access areas, add these controls:

  • Survey the surrounding area for drifting vapors or connected-space hazards before entry.
  • Use a trained supervisor and direct-reading gas monitor for pre-entry testing and continuous monitoring where required.
  • Verify isolation, lockout/tagout, ventilation, communications, standby person, rescue equipment, and permit validity before entry.
  • If atmospheric conditions change adversely, entrants must exit and the permit must be reissued after reassessment.

[2] [2] [9] [9] [8] A practical residual-risk decision for offshore RT is: do not expose while uninvolved personnel remain inside the verified radiation boundary, while divers are in the water within the affected subsea zone, or while marine traffic can breach the exclusion zone. Compliance should be demonstrated through a documented risk assessment using the EGPC 6×6 matrix, a signed permit to work, radiation survey records, dosimetry records, barrier and signage plan, SIMOPS coordination record, toolbox talk attendance, and emergency arrangements. This aligns with offshore HSE expectations and the cited radiation safety requirements for signage, surveillance, dosimetry, supervision, emergency procedures, and safe conduct of industrial radiography. [1] [1] [1] [1]

9 source record(s)

Sources used for this answer

[1] General Industry Safety and Health Standards (MIOSHA)

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# APPENDIX C EXAMPLES OF PERMIT-REQUIRED CONFINED (cont.) ## B. ENTRY PERMIT REQUIRED Permits. Confined Space Entry Permit. All spaces shall be considered permit-required confined spaces until the pre-entry procedures demonstrate otherwise. Any employee required or permitted to pre-check or enter a permit-required confined space shall have successfully completed, as a minimum, the training as required by the following sections of these procedures. A written copy of operating and rescue procedures as required by these procedures shall be at the work site for the duration of the job. The Confined Space Entry Permit must be completed before approval can be given to enter a permit-required confined space. This permit verifies completion of items listed below. This permit shall be kept at the job site for the duration of the job. If circumstances cause an interruption in the work or a change in the alarm conditions for which entry was approved, a new Confined Space Entry Permit must be completed. ## Control of atmospheric and engulfment hazards. Surveillance. The surrounding area shall be surveyed to avoid hazards such as drifting vapors from tanks, piping or sewers. Testing. The confined space atmosphere shall be tested to determine whether dangerous air contamination and/or oxygen deficiency exists. A direct reading gas monitor shall be used. Testing shall be performed by the SUPERVISOR who has successfully completed the gas detector training for the monitor he will use. The minimum parameters to be monitored are oxygen deficiency, LFL and hydrogen sulfide concentration. A written record of the pre-entry test results shall be made and kept at the work site for the duration of the job. Affected employees shall be able to review the testing results. The most hazardous conditions shall govern when work is being performed in two adjoining, connected spaces. Space Ventilation. Mechanical ventilation systems, where applicable, shall be set at 100% outside air. Where po…

[2] Toolbox Talk: Working on or Near Water

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# WORKING ON OR NEAR WATER Last Review: 08/01/2025 Date Published: 05/12/2025 ## Working on or Near Water Construction work that takes place in or near water can be dangerous for both workers and the public. It is important to take specific precautions before undertaking such work. It is easy to forget that even standard construction tasks like culvert replacements, bridges, storm management ponds, large sewers, and ditches can pose a risk. A person can drown in just a few inches of water, especially if the banks are muddy and slippery. Exposure to cold water can lead to hypothermia, even on a warm day. ## HAZARDS OF WORKING ON OR NEAR WATER - Drowning-related hazards include rising floodwaters, fast currents, and deep water. • Cold water shock, incapacitation, and hypothermia. • - Movement of vehicles and machinery near the water's edge, particularly during maintenance work. • Potential unmarked edges and insecure banks. • Exposure to extreme weather conditions, direct sunlight, or cold temperatures. Hypothermia, heat stress, and cold stress. • Electrical hazards, such as using electrical equipment, tools, and machinery around water, can lead to electric shock. • Entanglement - lake and river vegetation or submerged discarded debris. • Falling from heights. Slippery surfaces. ## GENERAL SAFE WORK PROCEDURES FOR WORKING OVER OR NEAR WATER • A competent person should periodically conduct and review a task-specific risk assessment for work over or near water. All potential hazards involved in this work, such drowning, overturning mobile plant/equipment into water, and collapse in confined spaces, should be identified, listed, and addressed. as • Warning signs shall be posted on the project to warn the public and workers of the hazards around the water. • All workers must always be alert and aware of their fellow workers. • Remove slip-and-trip hazards near the water. If removal is impossible, ensure that the hazards are well-marked and that wor…

[3] Confined Space - Program

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# Confined Space - Program (cont.) ## What is a Confined Space Hazard Assessment and Control Program? (cont.) - Development of an emergency plan complete with training and equipment in case an unforeseen situation occurs. - An emergency response system. - Reporting and investigating incidents related to work in confined spaces. - Record and documentation control. - Program review whenever there is a change in circumstances or at least annually, to identify program weaknesses and make any necessary changes to the program. More information about confined spaces is located in the OSH Answers documents Confined Spaces - Introduction and Confined Space - Atmospheric Testing. ## What is an Entry Permit System? An entry permit is an administrative tool used to document the completion of a hazard and risk assessment for each confined space entry. Someone fully trained and experienced in confined space work should complete the entry permit. Some jurisdictions require a permit for all confined space entries. An entry permit is required for confined spaces where the hazard and risk assessment determined that the measures to control the risk involve the following: - atmospheric monitoring, - isolation, - lockout, - ventilation, - safeguarding devices, - respiratory protection, or - any other control that needs to be verified and documented in the permit as required by the assessment. Before entering a confined space, an entry permit should be completed. It should contain at least the following information: - The length of time the permit is valid for. - The name(s) of the worker(s) that are authorized to enter the confined space. - The name(s) of the attendant(s) (safety watch). - The name of the supervisor responsible for the work. - The location and description of the confined space. Confined Space - Program CCOHS

[4] Occupational Health and Safety Regulation (B.C. Reg. 296/97)

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# OCCUPATIONAL HEALTH AND SAFETY REGULATION (cont.) ## Hazardous mechanisms (cont.) WORKERS COMPENSATION ACT B.C. Reg. 296/97 # OCCUPATIONAL HEALTH AND SAFETY REGULATION Part 24 - Diving, Fishing and Other Marine Operations (b) locked out as required by Part 10 (De-energization and Lockout). ## Intakes, pipes and tunnels - 24.64 (1) If a diver is required to approach or enter the intake of any pipe, tunnel, duct, or similar installation the diver must be provided with the means to distinguish the specific intake from any others in the vicinity. (2) A diver must not enter the water until flow through the intake is stopped and the intake mechanism is locked out, and the flow must not be restarted until the diver has left the water. (3) If divers are required to approach a hazardous mechanism, a pressure differential structure, or the intake of any pipe, tunnel, duct or similar installation, the divers must use only surface-tethered diving equipment with effective two-way voice communication with the surface; if required to enter, they must use only surface supplied diving equipment with effective two-way voice communication with the surface. ## Exceptional hazards 24.65 Additional dive team members with independent equipment and capable of effecting rescue must be on the dive site whenever diving operations incur exceptional risk of entrapment of a diver or loss of the diver's life support system. ## Contaminated environments - 24.66 (1) Before diving commences in a contaminated environment, an operational plan must be devised that is available at the dive site and provides for (a) identification of the contaminants, (b) special clothing or equipment to be used, (c) potential adverse health effects to persons and special medical precau- tionary measures, (d) identification of the exclusion zone, contamination reduction zone and the support zone, and protective clothing and equipment to be used in them, (e) measures to be followed by pers…

[5] Confined Space Guide for General Industry

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# ATTACHMENT A # Hot Work Permit Sample (attach to Entry Permit) XYZ Company Date: <empty> Issue time: <empty> Expiration time: <empty> Location of permit space: <empty> Work tasks: <empty> Potential Hazards Authorized Workers O Toxic O Electrical Entrants: O Corrosive O Mechanical O Flammable/Explosive O Fire/heat Attendant(s): O Radioactive O Spills Fire/safety watch: O Energy release O Oxygen Enrichment - O Stored energy Procedures/Precautions: O Procedures O Communications O Entry permit O Ventilation O Training O CPR/first aid O Rescue plan O Sprinkler system in service O Charged fire hose O Surfaces wetted down O Shower/eyewash located Safety Equipment: O Hard hat O Eye protection O Hearing protection O Foot/hand protection O Protective clothing O SCBA O Respirator: <empty> O Tripod O Barricade/cones O Communication devices O First aid kit O Fire extinguisher O: <empty> Vessel Prep/Isolation: O Cleaning/purging O Ventilation O Signs/barriers O Lagging cloths/tarps O Lockout/tagout O Blanking/bleeding O Disconnect mechanical linkages O Secure moving parts O: <empty> O: <empty> O: <empty> Special Tools - O Low voltage - O Non-sparking - O Tools inspected for frayed/broken wires - O Lighting intrinsically safe Special Work Procedures - O Never bring gas cylinders or other large equipment into space - O Never block entry/exit with equipment - O Shut down during breaks or overnight - O Fire watch to remain 30 minutes after completion of hot work O Entry authorizer (name, title, date): <empty> Emergency contact: <empty> 52 2

[6] Confined Space Entry Permit

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# Confined space entry permit Permit date: <empty> Work shift: [ ] 1st [ ] 2nd [ ] 3rd Expires: <empty> Time started: <empty> Permit space to be entered (name and location of space): <empty> Purpose of entry: <empty> ## Names of trained, authorized individuals Emergency contact information Entry supervisor: Emergency responder: Entry attendant: Contact person: Authorized entrants: Phone number: Authorized entrants: Time: ## Pre-entry checklist Do not enter this permit space until the following "needs action" conditions are corrected: <table><tr><th>OK</th><th>Needs action</th><th></th></tr><tr><td></td><td></td><td>Before entering the permit space, the supervisor or designee must notify the rescue team. IDLH conditions require at least one rescue team member located outside the space.</td></tr><tr><td></td><td></td><td>A minimum of two employees must be assigned to work involving permit space entry. One employee must remain outside the permit space at all times</td></tr><tr><td></td><td></td><td>The surrounding area must be surveyed to show that it is free of hazards such as drifting vapors from tanks, piping, sewers, or vehicle exhaust.</td></tr><tr><td></td><td></td><td>Those responsible for operation of the gas monitor have been trained.</td></tr><tr><td></td><td></td><td>Gas monitor calibration tests and functional test (fresh air calibration) have been performed this shift on the gas monitor. If so, by whom?</td></tr><tr><td></td><td></td><td>The atmosphere will be continuously monitored while the space is occupied, if required by entry procedure.</td></tr></table> <table><tr><th colspan="8">Pre-entry requirements</th></tr><tr><td>Requirements</td><td>Yes</td><td>No</td><td>N/A</td><td>Requirements</td><td>Yes</td><td>No</td><td>N/A</td></tr><tr><td>Lockout-tagout/de-energize</td><td></td><td></td><td></td><td>Hot work permit</td><td></td><td></td><td></td></tr><tr><td>Pipes(s) broken or capped or blanked</td><td></td><td></td><td></td><td>Fall …

[7] Cal/OSHA Regulations | Chapter 4 | Subchapter 7: General Industry Safety Orders | §5157. Permit-Required Confined Spaces, Appendix C - Examples of Permit-required Confined Space Programs

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# §5157. Permit-Required Confined Spaces, Appendix C - Examples of Permit-required Confined Space Programs. (cont.) ## B. ENTRY PERMIT REQUIRED (cont.) Space Ventilation. Mechanical ventilation systems, where applicable, shall be set at 100% outside air. Where possible, open additional manholes to increase air circulation. Use portable blowers to augment natural circulation if needed. After a suitable ventilating period, repeat the testing. Entry may not begin until the testing has demonstrated that the hazardous atmosphere has been eliminated. Entry Procedures. The following procedure shall be observed under any of the following conditions: - 1.) Testing demonstrates the existence of dangerous or deficient conditions and additional ventilation cannot reduce concentrations to safe levels; - 2.) The atmosphere tests as safe but unsafe conditions can reasonably be expected to develop; - 3.) It is not feasible to provide for ready exit from spaces equipped with automatic fire suppression systems and it is not practical or safe to deactivate such systems; or - 4.) An emergency exists and it is not feasible to wait for pre-entry procedures to take effect. - All personnel must be trained. A self contained breathing apparatus shall be worn by any person entering the space. At least one worker shall stand by the outside of the space ready to give assistance in case of emergency. The standby worker shall have a self contained breathing apparatus available for immediate use. There shall be at least one additional worker within sight or call of the standby worker. Continuous powered communications shall be maintained between the worker within the confined space and standby personnel. - If at any time there is any questionable action or non-movement by the worker inside, a verbal check will be made. If there is no response, the worker will be moved immediately. Exception: If the worker is disabled due to falling or impact, he/she shall not be removed from the confined …

[8] Confined Space Guide for General Industry

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# ATTACHMENT C # Confined Space Entry Permit Sample (Enhanced Title 8 Version) Permit valid for 8 hours only. All copies of permit will remain at job site until job is completed. Date: Time: Site location and description: Purpose of entry: NATURE OF CONFINED SPACE HAZARD Oxygen deficiency (less than 19.5%) Flammable gases/vapors above 10% of lower explosive limit (LEL) Mechanical hazards Oxygen over 23.5% Toxic gases or vapors greater than permissible exposure limit (PEL) Electrical shock Materials harmful to skin Electrical lockout Engulfment Valve out/isolation Other(s) BOLD DENOTES MINIMUM REQUIREMENTS TO BE COMPLETED AND REVIEWED PRIOR TO ENTRY PREPARATION COMPLETED DATE TIME Lock out/de-energize/try-out Line(s) broken/capped/blanked Secure area (post and flag) Breathing apparatus Resuscitator/inhalator Cleaned, drained, washed, & purged Ventilation for fresh air Emergency response team available Employees informed of specific hazards Procedures reviewed with each employee_ Atmospheric test in compliance Hot work permit attached (if required) Continuous monitoring required Other(s) REQUIREMENTS COMPLETED DATE TIME Full body harness w/ "D" ring Emergency escape retrieval equip. Lifelines Lighting (explosion-proof) Protective clothing (PPE) Respiratory equipment Specify Communication equipment Specify Rescue equipment Specify Rescue Service Phone# <table><tr><th>CONTINUOUS MONITORING</th><th>PERMISSIBLE</th><th>RECORD MONITORING RESULTS/TIME</th></tr><tr><td>TEST(S) TO BE TAKEN</td><td>ENTRY LEVEL</td><td></td></tr><tr><td>Percent of Oxygen</td><td>19.5% to 23.5%</td><td></td></tr><tr><td>Lower flammable limit</td><td>Under 10%</td><td></td></tr><tr><td>Carbon Monoxide</td><td>25 ppm</td><td></td></tr><tr><td>Aromatic Hydrocarbon</td><td>1 ppm - 5 ppm</td><td></td></tr><tr><td>Hydrogen Cyanide</td><td>4.7 ppm (S)</td><td></td></tr><tr><td>Hydrogen Sulphide</td><td>10 ppm* 15 ppm**</td><td></td></tr><tr><td>Sulphur Dioxide</td><td>2 ppm* 5 ppm**</td>…

[9] Nevada Administrative Code, Chapter 459 - Hazardous Materials (NAC-459)

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# GENERAL PROVISIONS (cont.) ## NAC 459.664 Personnel requirements. (NRS 459.201) (cont.) NAC 459.719 subsection 2 of NAC 459.3555, any pathway leading to a high radiation area and any barrier, including a temporary barrier, that is intended to prevent unauthorized access to a high radiation Precautionary procedures: Posting of signs. (NRS 459.030) A registrant that engages in X-ray industrial radiology shall post (g) Section 34.123. with signs, in the manner set forth in area. (Added to NAC by Dep't of Human Resources by R137-01, eff. 5-30-2003) NAC 459.7234 Requirements for radiation safety officer. (NRS 459.030, 459.201) 1. A registrant that engages in the practice of X-ray industrial radiography shall appoint a radiation safety officer for the radiographic operation. 2. A radiation safety officer shall: (a) - Ensure that the daily operation of X-ray industrial radiography is conducted in accordance with the provisions of this chapter. (b) Establish and oversee operating and emergency procedures and procedures to ensure that the level of radiation is as low as is reasonably achievable. The radiation safety officer shall these procedures at least once each year to ensure that the procedures conform to the requirements set forth in this chapter. review (c) Approve and oversee all phases of the training program for radiographic personnel to ensure that they receive training in appropriate and effective protection practices. (d) Ensure that the required surveys are performed and documented in accordance with applicable regulations and that corrective measures are taken if the levels of radiation exceed established in this chapter. the levels (e) Ensure that monitoring devices are calibrated and used properly by personnel who are performing X-ray industrial radiography and the results of exposures to radiation are properly recorded and notices of those exposures are submitted on a timely basis. (f) Ensure that the radiographic operation…

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