Confined Space Entry DOW RESTRICTED - For internal use only Presented by: Ricky Jones Doug Morris

Confined Space Entry

DOW RESTRICTED - For internal use only

Presented by:Ricky JonesDoug Morris

BACKGROUND

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• Dow EH&S Standards have been reviewed and the requirements have been reduced and simplified,

• hROH EH&S Standards have also been reviewed and the requirements between the Dow and hROH Standards have been harmonized into one standard,

• For Dow locations there are some requirement changes as well as additions. These will be reviewed in this Power Point presentation.

• December 31, 2012 is the deadline for implementation of the CSE Standard changes for Dow and hROH.

Green = Changes Red = Removed

Changes for CSE Standard

Summary of Changes for Dow U.S. Sites

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Regulatory Update • The US Occupational Safety and Health Administration (OSHA) Region VI has clarified that all

monitoring data collected for employees and contractors will be held for 30 years, • In the US, this clarification will result in changes to permit retention and/or recordkeeping,• Sites must maintain records of hazard monitoring, which includes O2, LEL, H2S, CO and any

other IH monitoring) to include the actual data points and the associated employees for 75 years,

• The CSE Permit has been updated with an Appendix,» CSE Permit - Appendix A must be retained for 75 years in the US, (Appendix A, last page

of the CSE Permit) The new record retention from OSHA for the monitoring data is 30 years plus length of employment. Instead of having to keep track of each individual,(remember there are multiple people for each CSE) Dow decided to keep it for 75 years, which will cover it for everyone.

» The SWP, CSE Operating Procedure, and the CSE Permit must still be retained for 1 year.

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• A best practice with respect to retention . . . create a separate binder in your Library for retention of Appendix A and associated paperwork, and another binder for your CSE Permits, Procedures, Rescue Plans and SWP’s.

• Redundant requirements with other standards have been removed,• Simplification of isolation, cleaning and clearing, hazard monitoring, and

ventilation requirements and placement of these specific requirements in a role that is associated with CSE, e.g. Safety Attendant, Permit Issuer, etc.

Addition of a Hazard Review Guidance Document (linked in the standard) for an alternate method of isolation when disconnecting (air gap), blinds/pancakes/spectacles, or double block and bleed are not practical.

Summary of Changes for Dow U.S. Sites

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• Requirement to complete 5 air changes per hour (ACH) prior to entry (previously identified in the FAQ section); Requirement to conduct hazard monitoring with ventilation air movers off for a minimum of

15 minutes, Addition of a Ventilation Guidance Document (linked in the standard)

• Allowance of subsequent non-routine entry to be approved by the Permit Issuer only when the job scope, craft type, and hazards remain the same as the initial entry permit, a Permit Issuer can issue a CSE Permit (one signature) after initial entry if the job scope, crafts and hazards remain the same.

• Introduction of a document that identifies the “Top Ten” things to look for when observing a CSE in the field.

Summary of Changes for Dow U.S. Sites

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• Removal of the requirement for Facility/Work Group Leadership to;Maintain lists of confined spaces,Maintain lists of authorized personnel (Permit Issuers or

Permit Approvers), andAnnually review and approve Confined Space Entry

Operating Procedures for each routine, repetitive confined space entry,

• Removal of training requirement for CSE Permit Approver

Summary of Changes for Dow U.S. Sites

Q & A

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Why was the requirement for the Delegation of Authority removed from

the CSE Standard?• Answer: TxOp adopted the Global CSE Standard thereby removing all the associated

“Freeport Only” requirements, which the DOA was one of those items. The DOA is now required by the TxOp T-10 General Administrative Standard, however, T-10 may be done away with in the near future.

What happened to the TxOp CSE Procedure template?• Answer: TxOp adopted the Global CSE Standard, there is a

Global CSE procedure template located within the Global document that TxOp will follow.

Is it the expectation that Appendix A be kept separate from the CSE

Permit (that is only kept for 1 year)?• Answer: Yes, the Confined Space Appendix A should be kept and filed separately since it

has a 75 year record retention requirement.

For the “Limits” section on Appendix A, where do we get the information

from? • Answer: Can be found on the MSDS or check with your Site IH partner, your QEA or

Dow’s OELs database.

Q & A (continued)

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On the MSDS it list an 8 hour TWA for exposure limits. What if I

have a 16 hour CSE, what limits do I document on Appendix A?• Answer: The 8 hour TWA, with the concurrence of your Site IH partner.

Will special paper be used for the Appendix A due to the 75 year

retention? • Answer: No, but be mindful of the length of time it needs to be kept when deciding where

to store your documentation.

Does the checklist (Appendix A) get filled out each time you fill out a

Confined Space Entry Permit? • Answer: Yes; for each CSE permit that is written, along with what monitoring is completed

shall be listed on Appendix A.

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Some CSE’s are easy to recognize

Some CSE’s are NOT easy to recognize

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CSE Questions

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Is a Walk-In freezer a confined space?

One of the safety attendant's responsibilities is to observe the integrity and proper use of PPE . . . what does this mean?

This means that the safety attendant needs to understand what PPE is required and what proper use and limitations are of the PPE. Examples to include wearing the proper suit to enter the confined space, while they are working, observe if they may have snagged their suit and caused it to tear, that the proper cartridges are in the respirator, that goggles are not fogged and putting the worker at risk, that the safety harness is put on properly, etc.

Yes

If the walk in freezer is used to store food and it has a handle on the inside then it is designed for occupancy and is not generally considered a confined space. However, if the walk in freezer is storing chemicals or if the design or use of the freezer could lead to possible engulfment, oxygen deficiency or exposures then it may be a confined space. Each situation needs to be evaluated against the definition of a confined space.

What about a rainwater trench with restricted access deeper than 4ft?

To approve the Confined Space entry

To secure needed equipment for the confined space entry team

To continually observe the integrity and the proper use of personal protective

equipment

To enter the Confined Space in an emergency as outlined in the emergency

and rescue procedure prior to the arrival of additional rescue help.

F

F

T

F

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Which of the following are responsibilities for a Safety Attendant for Confined Space entry?

What about Lunch Break ?

Question : If workers leave the CSE for lunch, what do they need to do upon returning?

Answer : If the confined space is left unattended during the break, then you shall monitor the same location you did for the CSE, initial your monitoring results as verification the monitoring was completed, before entry is allowed.

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CSE - Do Not Enter Without Permit

If an attendant is left in place (within ___ feet and has direct sight of the CSE entrance) during break or lunch, there is no need to re-monitor the air and when workers return, the attendant documents their entrance and they return to work.

As a good practice - when a confined space is left unattended, place a sign on the entry point that says “ __________________________________”.

Appendix A – Filled out

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Appendix A – Filled out

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Which of the following is TRUE of hazard monitoring ofConfined Space entries:

Be performed while ventilation air movers are operating.

Be performed only in the center of the Confined Space.

Be continuously performed.

Be performed inside the Confined Space at points that represent the breathing

air quality of the locations where the people will be doing their work.

F

F

T

T

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The Confined Space Entry Operating Procedure shall always include which of the following: (true or false)

Line or equipment opening information.

Hydro blasting procedures for clearing the Confined Space.

Emergency and Rescue procedures that have been

reviewed by the rescue team member.

A relief plan to address thermal stress

T

F

T

T

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Which of the following equipment may be used in a confined space?

Pressurized gas cylinders other than breathing air

Pneumatically powered equipment powered by inert gas supplies

Electrically powered equipment that uses a 115/220 volt power source with a tested GFCI that is located outside of the confined space

Electrically powered equipment that uses a 120/240 volt transformer

F

F

T

T

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Confined space entry permit shall be cancelled and all work stopped until a new permit is issued if which of the following occur ?

A lunch break is taken by the Confined Space entry team but the Confined Space remains attended.

The Safe Work permit is suspended

If the emergency and rescue procedures cannot be initiated due to an evacuation of the work area.

The Confined Space entry extends beyond an 8 hr shift.

F

T

T

F

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CSE REQUIRED DOCUMENTATION

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Can you name some or ALL of the required documentation required for a CSE?

• Safe Work Permit (SWP) • Confined Space Entry (CSE) Permit• Confined Space Entry Procedure• Confined Space Rescue Plan• Acceptance of a Red Tag Master

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New Stuff

Questions / Comments?

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The End