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Confined Space Entry

Confined Space Entry. Presented by: Ricky Jones Doug Morris. Changes for CSE Standard. BACKGROUND. Dow EH&S Standards have been reviewed and the requirements have been reduced and simplified,

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Confined Space Entry

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

  2. Changes for CSE Standard BACKGROUND • 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 DOW RESTRICTED - For internal use only

  3. Summary of Changes for Dow U.S. Sites 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 Amust 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. DOW RESTRICTED - For internal use only

  4. Summary of Changes for Dow U.S. Sites • 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. DOW RESTRICTED - For internal use only

  5. Summary of Changes for Dow U.S. Sites • 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. DOW RESTRICTED - For internal use only

  6. Summary of Changes for Dow U.S. Sites • 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), and • Annually review and approve Confined Space Entry Operating Procedures for each routine, repetitive confined space entry, • Removal of training requirement for CSE Permit Approver DOW RESTRICTED - For internal use only

  7. Q & A 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. DOW RESTRICTED - For internal use only

  8. Q & A (continued) 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.  DOW RESTRICTED - For internal use only

  9. Some CSE’s are easy to recognize DOW RESTRICTED - For internal use only

  10. Some CSE’s are NOT easy to recognize DOW RESTRICTED - For internal use only

  11. CSE Questions Is a Walk-In freezer a confined space? 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? Yes 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. DOW RESTRICTED - For internal use only

  12. Which of the following are responsibilities for a Safety Attendant for Confined Space entry? 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 DOW RESTRICTED - For internal use only

  13. 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. 35 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 “ __________________________________”. CSE - Do Not Enter Without Permit DOW RESTRICTED - For internal use only

  14. Appendix A – Filled out DOW RESTRICTED - For internal use only

  15. Appendix A – Filled out DOW RESTRICTED - For internal use only

  16. Which of the following is TRUE of hazard monitoring of Confined 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 DOW RESTRICTED - For internal use only

  17. 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 DOW RESTRICTED - For internal use only

  18. 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 DOW RESTRICTED - For internal use only

  19. 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 DOW RESTRICTED - For internal use only

  20. CSE REQUIRED DOCUMENTATION • 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 DOW RESTRICTED - For internal use only

  21. New Stuff DOW RESTRICTED - For internal use only

  22. Questions / Comments? The End DOW RESTRICTED - For internal use only

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