Life Critical Procedures

Confined Space

8/8/06

Introduction
Summary of NIOSH Study of Confined Space incidents

Accident Type
Atmospheric Explosion or Fire Electrocution or Shock Caught In/Crushing Trapped in Unstable Materials

Events Injuries Fatalities

80 15 11 10 16 72 49 2 3 0 78 15 9 10 16

Basically, if things go wrong it is BAD!

Focus on Incident Prevention when Managing Permit Required Work
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Definitions
Attendant - The person stationed outside of a confined space who
monitors the authorized entrants

Authorized Entrant - The employee or contractor who is authorized by the site

leader to enter a permit-required confined space. An affected employee becomes an authorized employee when the work assignment includes servicing and/ or maintenance.

Combustible Material - Material that may readily ignite if

exposed to sparks, heat, open flames, electrical arch, friction or other ignition sources

Definitions Confined Space Entry Permit - Written or printed document that allows and
controls entry into a confined space

Entry - Is considered to have occurred as soon as any body

part breaks the plane of an opening into a confined space

Entry Supervisor (Equipment Owner/ Operator) - Person responsible for determining acceptable entry
conditions. The supervisor will authorize entry, oversee entry operations and will terminate entry if required.

Definitions Hot Work - An operation that can produce an ignition source

having sufficient energy to cause ignition where the potential for combustible materials, flammable vapors, gases or dust exists.

IDLH - Immediately Dangerous to Life and Health -

condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with a persons ability to escape.

Definitions Inerting
- The displacement of atmosphere in a confined space or line
by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.

Rescue
- An established emergency response procedure whereby
both the rescue personnel and all equipment are available at the incident scene so that rescue can commence within 5 minutes on the start of the emergency.

Rescue Team
- Employees trained, equipped and drilled to conduct a rescue
from a confined space

Definitions Rescue Service

- External persons, contractors, fire department, emergency
services, or others that are properly trained, equipped and drilled to safely conduct a confined space rescue.

Vessel Isolation
- Providing a positive means to separate and segregate a
vessel from process ventilation, product feed or drain lines to prevent a hazardous condition . This is accomplished by: Physical separation of couplings or flanges, with missalignment of the ends Installing a blank, or blind Utilizing a double block and bleed system

Classifying Confined Spaces

Confined Space - Space that is large enough that an employee can enter and
perform work - Has limited means for entry or exit; - Is not designed for continuous employee occupancy

Permit Required Confined Space - A Confined Space meeting one or more of the following:
Contains or has potential to contain a hazardous

atmosphere Contains a material that has potential to engulf an entrant Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls Contains any other recognized serious safety or health hazard

Types of Confined Spaces

Examples
Reactors Stills

Tanks
Receivers Boiler/Thermal Oxidizer Trenches/Sewers/Pits Excavations >5 ft.

Accountability
Site Leader - Must ensure the Confined Space Procedure is in place - Give authority to employees authorizing or acknowledging
permits to stop the work if safe conditions cannot be met or if unsafe conditions develop during the task.

Site Leader or Authorized Alternate - Must require department leaders to be responsible for
implementation of the Confined Space Procedure in their areas. - Must be trained - Must designate a trained entry supervisor to verify work is performed in confined spaces as indicated on the permit.

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Accountability HSE Department - Must evaluate workplace and

identify all potential confined spaces. - Provide training materials for the entry supervisor and authorized entrant training programs. - Review site permit compliance and procedures - Conduct annual audits of all completed permits and a field audit of an actual confined space entry.

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Accountability The Entry Supervisor Must: - Complete a documented pre-job plan

including an Emergency Rescue Plan - Inform the work group of potential hazards - Ensure plant equipment and work area are properly prepared - Ensure plant equipment and work area is maintained in a safe condition during the entry - Formally approve the permit by signature before allowing work to proceed - Set permit conditions including PPE requirements - Ensure work is performed according to the permit

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Accountability The Authorized Entrant Must:

- Participate in pre-job planning meetings - Have approval from the Entry Supervisor before starting
permitted work - Review and understand the requirements outlined on permit - Understand potential hazards, including signs/symptoms and consequences of exposure that may occur in the confined space - Continue to work only if permit conditions do not change - Know how to use gas analyzers used in the space - Know how to use ventilation equipment - Communicate with the attendant as necessary - Exit the confined space immediately if:
An alarm condition exists Signs or symptoms of exposure are detected

Instructed by the attendant to do so

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Accountability
The Attendant Must: - Be familiar with the specific permit conditions - Understand potential hazards, signs and symptoms - Be aware of potential behavioral effects of exposure - Be stationed at the entrance of the space continuously - Only allow authorized entrants into the space - Only monitor one entry at a time - Communicate with the authorized entrant as necessary - Monitor activities inside and outside of the space in order to
detect unsafe conditions - Order an evacuation of the space if unsafe conditions are detected. - Know how to use gas analyzers - Know how to use ventilation equipment - Know rescue duties and how to summon rescue personnel
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Specific Duties
-Attendant Must Recognize Effects and symptoms of oxygen depletion
In general, oxygen deficiency leads to a loss of mental alertness and a distortion of judgment and performance. This happens within a relatively short time, without the person's knowledge and without prior warning. 21 14%

Increasing pulse rate, tiredness --------------------------------------------------- 14 11%

-Physical movement and intellectual performance becomes difficult 11 8%

Possibility of headaches, dizziness and fainting after a fairly short period of time --------------------------------------------------------Fainting within a few minutes, resuscitation possible if carried out immediately ----------------------------------------------------------Fainting almost immediate, death or severe brain damage 8 6%

6 0%

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20.9% v/v normal

16% v/v depletion

6% v/v fatal

Responsibility Operations and other Affected Personnel Must: - Be aware of permitted

work and stay out of the area - Ensure that no process changes will affect the permitted work - Inform the entry supervisor if an incident occurs or conditions change that may affect the permitted work activity

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Potential Hazards
Class A - Situations that are Immediately Dangerous to Life or Health
(IDLH) - IDLH Concentrations are listed in NIOSH Pocket Guide to Chemical Hazards - IDLH Atmospheres include:
Oxygen concentration <16% or >25% Explosive or flammable atmosphere >20% of LEL Toxic substances reaching IDLH values

Additional requirements for work in Class A - Verbal approval followed by written SM HSE approval is
required prior to entry into a Class A atmosphere

- Entry is limited to only individuals with life support equipment

- Standby at entry point of at least 2 additional employees

with life support equipment
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Potential Hazards
Class B - Situations with potential for causing injury and illness if

preventative measures are not used but are not IDLH. - Class B Atmospheres include: Oxygen concentration between 16.1% and 19.4% Oxygen concentration between 21.5% and 25% Explosive or flammable atmosphere between 5% and 20% of LEL Toxic substances concentrations greater than OSHA Permissible Exposure Level/ Threshold Limit Value but lower than IDLH values

Additional requirements for work in Class B - HSE approval is required prior to entry into a Class B

atmosphere - Indirect visual or auditory communication with the entrant is required

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Potential Hazards
Class C - Situations in which standard confined space procedures
apply - Class C Atmospheres include:
Oxygen concentration between 19.5% and 21.4% Explosive or flammable atmosphere less than 5% Toxic substance concentrations lower than OSHA Permissible

Exposure Level

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Hazard Types Toxic Vapors - A toxic atmosphere exceeds either the OSHA

Permissible Exposure Limit (PEL) or the Threshold Limit Value (TLV) - Ventilation must be used to remove any toxic atmosphere - Sources of toxic vapors may be:
Existing tank conditions Sludge or Scale Leakage of improperly isolated valves Materials taken into the space (i.e. solvents for cleaning)

- Chemical analysis is required prior to entry if a

hazard is suspected
Consider contents of the tank; Possible by-products of contents; Adjacent exposures

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Hazard Types
Oxygen Deficient Atmosphere - Oxygen less than 19.5% may not support life. Below 19.5%
requires SCBA to enter. - Oxygen deficiency may be caused by:
Chemical absorption Oxidation of metal Use of inert gas (by process requirement or by inerting for entry) Improper or inadequate ventilation during entry

Oxygen Enriched Atmosphere - Oxygen greater than 21.5% - Combustion is easily supported - Materials not thought combustible will flash and burn
quickly - Hot Work, electrical equipment and spark producing tools are prohibited in oxygen enriched atmospheres.
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Hazard Types
Flammable Gases or Liquids - Presence may cause flash fires or explosions - Confined spaces must be tested with a flammable gas meter
The space must be ventilated until tested to <5% of the LEL

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Reclassification of Confined Spaces

A Confined Space May Be Reclassified if: - All hazards within the space can be eliminated w/o entry - The atmosphere inside and surrounding the space will not
change - The atmosphere has been tested and is verified safe - Collecting atmospheric data does not require entry

Control of Atmospheric Hazards by Forced Air Ventilation Does Not Constitute Elimination of the Hazard for Purposes of Reclassification
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Safety Precautions
Signs
- All Permit Required Confined Spaces must be prominently posted

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Safety Precautions
Personal Protective Equipment - Entrants are required to wear
a full-body harness and rescue rated lifeline that is secured outside of the confined space

Hot Work - Follow Hot Work procedure

Note: Anything outside of scope

must be covered by an SOP.

Fire Protection - Fire extinguisher must be

positioned outside the confined space if potential fire hazard exists

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Safety Precautions
Tools used in Confined Spaces must: - Be clean and in good condition - Be grounded or double insulated - Have Ground Fault Circuit Interrupters (GFCIs), with the
GFCI remaining outside of the space - Intrinsically safe if a potential for a flammable atmosphere exists

Portable electrical equipment and lighting must: - Be operated at 12 volts or less (55V-UK) or; - If 110 volt, it may be used with a GFCI positioned outside of
the space

Portable ladders must be secured at the top and bottom if possible

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Confined Space Entry Requirements

The date and time must be listed on the permit Permits are valid for 1 shift Permit requirements must be initialed Atmospheric testing must be completed no more than 30 minutes prior to entry

- Mechanical Ventilation is required if natural ventilation does not

provide:
19.5% - 21.5% oxygen

A nontoxic atmosphere (<PEL and TLV)

Flammable gas less than 5% of the LEL

- Approval is required from HSE if mechanical ventilation is

impossible or ineffective

- Atmospheric analyzers are bump tested prior to each days entry and -

calibrated per manufacturers recommendation and documented. An attendant must be positioned at each entry point for confined spaces having more than one entry point. Open access points to confined spaces where no entry is to be made, barrier tape is to be installed across the entry and no attendant is necessary

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Confined Space Entry Requirements Entry preparation must follow the lockout procedure including isolation/ separation of hazardous chemicals to prevent the material from entering the confined space. If the confined space has an agitator or other mechanical devices inside, these devices must be locked out and physically secured Pre-Job discussions are required prior to anyone entering the vessel, must be attended by all persons entering the vessel, and the confined space hazards must be assessed or evaluated and the hazards mitigated. The hazard assessment must be discussed during the pre-job planning.

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Mechanical Ventilation

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Confined Space Entry Requirements

Communication maintained between Attendant, Entrant and Rescue Service - Alternate communication methods are required if supplied
air is used
Line of sight and hand signals - hand signals reviewed with team prior

to entry Radios Loud verbal communication if feasible

- An alarm is required to signal entrant evacuation

Air horn or other equivalent method All affected personnel must know work is to stop and evacuate

Entrants and attendants must be listed on the permit

- Entrants must sign in and out of the space

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Confined Space Entry Requirements

Barricades
- When making an entry, the area
around the space must be barricaded with traffic cones, barrier tape or other means.

- Barricades should prevent

unauthorized personnel from entering the area - Barricade tape is to be installed across the opening of confined space where no entry is made and no attendant is standing by.

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Confined Space Entry Requirements

Pre-Entry Safety Training - All Involved Employees
Informed of:
Permit Conditions
Atmospheric Test Results Potential Hazards Signs/Symptoms and

Consequences of Exposure Safety Precautions Emergency Procedures

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Confined Space Entry Requirements

Entry supervisor reviews the permit and inspects the work site - Verifies preparations - Verifies precautionary procedures - Verifies LOTO, isolations, air monitoring, pre-entry training,
communication, etc.

Entry supervisor signs permit giving Authorization to Proceed Posting of the Entry Permit - Must be posted at the job site - Copy must be posted in control room, project office or
operational logbook while job is in progress

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Post Entry Procedures

Post Entry Review (after confined space entry is completed) - Conducted and documented on permit following entry - Verifies all persons accounted for - Work is complete - Confined space is secure

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Rescue Planning
Prior to Entry - A Rescue Plan must be developed and documented - Plan must be specific to the space being entered - Plan reviewed during pre-job discussion Rescue plan must include - How to summon team in a timely manor (appropriate for type
of space and hazards identified) - Methods of rescue for retrieval
Mechanical retrieval Manual retrieval (for horizontal entry points) Rescue team

- Types, availability and responsibility for Equipment required

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Rescue Planning
Rescue Planning Policies
- Attendant must never enter the space
Attendant must immediately call for rescue if an employee becomes

unconscious, sustains an injury or otherwise cannot self rescue. Attendant may perform non-entry rescue only after summoning rescue team

- Rescue Equipment
Mechanical lifting device required for vertical rescues >5 ft

Safety harness attached with life line near center of entrants back
Wristlets or anklets may be used for small openings Lifelines must be attached to fixed point outside the space

The Attendant Must Not Enter the Confined Space

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Types of Rescue Teams

Honeywell Rescue Teams - Onsite Company Employees
Trained, certified and equipped to perform rescues

Must participate in annual documented rescue drill

Must be notified prior to entry to ensure availability

- Outside Rescue Services

Local emergency services, fire department, contracted service Written document demonstrating agreement and training Team and equipment must be available within a timely manner Rescue must be able to start within 5 minutes of the emergency Must be familiar with and capable of rescue from sites spaces Must be notified prior to entry to ensure availability

Should participate in onsite annual documented rescue drill

Must be onsite during entry unless: Non-Entry rescue can be completed by Attendant Non-Entry rescue can be completed by Onsite Rescue Team

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Atmospheric Testing Procedures

Equipment Verification - Atmospheric analyzers require documented Checks
Verified per manufacturers directions Bump Test with Span Gas

Test verification results documented on Entry Permit

Bump check the Monitor daily to ensure proper operation

Equipment Requirements - Multi-gas analyzer is required

Capable of monitoring Oxygen and LEL at minimum
Additional capabilities required for toxic gases, Carbon Monoxide, etc.

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Atmospheric Testing Procedures

All confined spaces must be tested prior to entry, and monitored continuously during entry. Test must be completed in this order
1. Oxygen 2. Flammable Gas 3. Toxic Gases

Taking initial sample - Sample from a small opening - Position self upwind from opening Ventilation may be required to ensure pockets of contaminated air are eliminated.

Sample Oxygen First. Other Tests May Not Be Accurate if Oxygen Values are Low.
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Atmospheric Testing Procedures

Test all vertical levels of the space If horizontal area cannot be tested without entry - Tester must use supplied air - Rescue equipment must be
provided.

With long test probe, allow pump to run min. of 1 second per foot of tube Testing must be documented at least every 2 hours Retest required if entrant leaves for more than 30 minutes
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Training Requirements
All involved personnel must be trained annually Training Elements - Safe Work Practices - Confined Space Procedure - Entry Permit - PPE, tools, Hot Work, Communication - Calibration and use of gas meters - Duties (Entry Supervisor, Entrant, Attendant, Rescue) - Rescue Planning, Emergency Action - Chemical and physical hazards - Ventilation - Isolation and hazardous energy control - Rescue Equipment (harness, lifeline, mechanical extraction)

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Training Requirements
Rescue Team - In addition to other training requirement:
Trained on use of rescue equipment (winches, lifelines, etc.)

Current in First Aid, CPR, Blood borne Pathogens

Completed rescue drill for various types of scenarios Retraining is required Annually

Contractors - Must provide documentation of similar training if involved in

Confined Space Entry and follow requirements equally restrictive as Honeywell.

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