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Inter office Memo (CO/HSE/08 28" May’19 From: ED (HSE), CO, New Delhi For: ED (HSE), Mktg. HO, Mumbai, ED (HSE), RHQ, New Delhi CGM (HSE), PLHO, Noida ‘Sub: Painting inside the Pontoons of Floating Roof Storage Tanks As you are aware that recently a fatal accident took place at one of our Refineries while carrying out painting inside the tank pontoon in which the painter, who was carrying out the painting job sustained severe full body burn injuries and later succumbed to his injuries. To avoid occurrence of such accidents in future, guidelines for painting inside the Pontoons of Floating Roof Storage Tanks were prepared which have been approved by Dir (PL), Dir (M) and Dir (R ) and perused by Chairman (Copy attached for reference) Gist of recommendations comprising of following is also attached as Annexure-I: . Recommendations pertaining to pontoon manhole 2. Procedure for Painting inside Tank Pontoon 3. NOTE: The above procedure to be included in Tank M&I Manual of Divisions and Painting Manual of IOCL The guidelines may please be circulated to all concerned for strict implementation and necessary inclusion in Tank M&d Manual and Painting Manual. Y.K. Gupta®S9 ED (HSE), CO Encl: As above Cc: CH Sectt. Dir (R ) Sectt. Dir (M) Sect. Dir (PL) Sectt. Page 1 of 3 1. Recommendations pe: Annexure-I g to pontoon manhole * One manhole of minimum 20 NPS per pontoon floating roof tank is adequate as per clause C.3.5 of API 650 for new and existing floating roof tank as well. No additional manhole or opening is required. * Painting inside tank pontoon is done in new tanks. In tanks under M&d, the Painting is to be done where the same has been recommended by M&d. 2. Procedure for Painting inside Tank Pontoon L A. @ m mn mor Painting procedure: Painting inside tank pontoon is not a routine Job and is to be carried out only on recommendations of Inspection Department during M&d in case of existing tanks. In case of new tanks, also the same procedure of painting shall be applicable. .. Surface preparation only after tank is made gas free by hand tool cleaning/ scrappers / wire brush. . Sufficient exhaust ventilation should be provided through either air hose or air operated blowers. Confined Space Permit and Cold Permit specifying painting job to be issued and conditions of the permit to be complied with. . Painting job to be undertaken only during day time with natural light. Use of lighting arrangement should be avoided. However, if required, it should be flame proof type and limited to 24 V DC. All electrical cables / wires should be joint free and in sound condition. . Painting to be started as last activity after the Preparation of the surface is complete and other above precautions taken. During painting job in Pontoon, no hot work should be allowed in the vicinity. Also no job which has a potential to generate spark to be carried out. ‘Two coats of high build (HB) red oxide zinc phosphate primer to be used. . Addition of thinner is prohibited. . Application of primers inside the pontoon must be done by brush / rollers only. Ventilation should be continued even after completion of painting or coating applications to dissipate excess vapour concentrations till surface becomes dry and area is gas free. Continuous monitoring of concentration of flammable mixture through Portable detector and stopping the work whenever concentration of vapours stajqn Page 2 0f 3 exceeds 10% of LEL. This aspect must be included in Tool Box Talk and Job Safety Analysis. M, Retest the atmosphere 10 minutes after ventilation has been discontinued to confirm that the area is gas free. It should be ensured that empty / filled paint drums are not stored in the vicinity and stacked away from the working site. ©. It should be ensured that rags /cotton/ tools paint etc. are not left out inside the pontoon. P. After completion of activity of painting of tank pontoon, it has to be ensured that the pontoon manholes are properly closed. 2 Il. Painter Safety: A. Painter to come out from the tank pontoon for fresh air breathe after every 10-15 minutes and again re-start the job. . Stand-by person(s) should always be available outside the confined area and should have regular communication with the painter inside the pontoon box to identify that the painter is not in any sort of discomfort. C. The persons involved in the painting job should wear requisite PPE as mentioned in Page No. 27-30 of Guidelines on Personal Protective Equipment issued by HSE, Corporate Office, which are uploaded on Corporate HSE intranet website also. D. It is to be ensured that immediately after painting, painter will change his clothes and clothes used during the painting should be stored in a close container. After completion of job, these clothes should be disposed safely. E. Painter should not move from the painting site without changing:clothes not even for natural call. 2 Ill. Other Instructions A. Job Safety Analysis for tank M&d jobs should be done separately for each sub-activity. . Tool box talk should include safety information / precaution related to specific jobs plan to carry out. 2 3. NOTE: The above procedure to be included in: A. Tank M&I Manual of Divisions B. Painting Manual of IOCL Page 3 of 3

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