SAFETY MANUAL. Respiratory Protection Program TABLE OF CONTENTS 1. INTRODUCTION SCOPE DEFINITIONS PROGRAM...

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1 Page 1 of 17 TABLE OF CONTENTS 1. INTRODUCTION SCOPE DEFINITIONS PROGRAM RESPONSIBILTIES REFERENCES REVISION HISTORY ATTACHMENTS APPENDICES Rev. Issue Date Amendment Description Prepared By: Approved by: May-10 Review for Compliance and OE Readiness Lloyd Askham Jarvis Olsen 3 01-May-08 Address minor internal OE action findings Lloyd Askham Jarvis Olsen 2 01-May-07 Inclusion of breathing air quality requirements Lloyd Askham Jarvis Olsen 1 01-Jan-06 Completely re-written from Rev 0 Lloyd Askham Jarvis Olsen Page 1 of 17

2 Page 2 of INTRODUCTION Employees and contractors at the Q-Chem facility may handle, store, transport or observe hazardous chemicals from time to time. Chemicals are necessary as part of production process and maintenance activities and may also be found in the laboratory, warehouses and other storage areas throughout the plant. The purpose of this Program is to prevent occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, and/or vapours. Qatar Chemical Company Ltd. shall first attempt to determine the feasibility of using engineering control measures to control atmospheric contaminants. These controls shall include enclosure or confinement of the operation, general and local ventilation, and/or the substitution of less toxic materials. When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used. This program is intended to comply with OSHA 29 CFR : Respiratory Protection Standard. 2. SCOPE This program is applicable to all employees and contractors entering the Q-Chem Plant premises. Respirators must be provided by Q-Chem when such equipment is necessary to protect the health of the employee or contractor. Q-Chem must provide respirators that are applicable and suitable for the purpose intended. Q-Chem in this document refers to Q-Chem, Q-Chem II and RLOC. Contractors, outside of Q-Chem base load contractor (Q-Con), are exempt from the Medical Surveillance component, but are still required to complete the Respiratory Questionnaire before completing the fit test. 3. DEFINITIONS Air-purifying respirator means a respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element. Atmosphere-supplying respirator means a respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere, and includes supplied-air respirators (SAR s) and self-contained breathing apparatus (SCBA) units. Batch / Lot refers to breathing air cylinders filled in one operational run, typically defined as (1) day by OSHA. Breathing Air is air provided to a worker via a supplied air line or self contained tank meeting OSHA Type 1 Grade D specifications. Breathing Air Room An area set up in the fire station where respiratory equipment is serviced and maintained. Serviced full & masks are available for trade in of masks that have been used in the field. Page 2 of 17

3 Page 3 of 17 Canister or cartridge means a container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container. Certificate of Analysis (COA) is a guarantee by the manufacturer of breathing air that the air within the breathing air cylinders meets the OSHA Type 1 Grade D specifications. This requirement is required as every time a manufacturer mixes nitrogen and oxygen to produce breathing air there is a potential for changes to occur. The certificate gives the assurance that the breathing air being used by employees is safe. Hence, a certificate MUST be provided for each lot of cylinders produced. Emergency situation means any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant. Employee exposure means exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection. Escape-only respirator means a respirator intended to be used only for emergency exit. Being clean shaven is not a pre-requisite for using this type of respirator as their purpose is solely for the rapid egress from a potentially hazardous environment. Filter or air purifying element means a component used in respirators to remove solid or liquid aerosols from the inspired air. Filtering facepiece (dust mask) means a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium. Fit factor means a quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn. Fit test means the use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. High efficiency particulate air (HEPA) filter means a filter that is at least 99.97% efficient in removing mono-disperse particles of 0.3 micrometers in diameter. The equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters. Immediately dangerous to life or health (IDLH) means an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere. Mask Owners The Fire Station is responsible for the care and maintenance of all full facepiece masks belonging to Q-Chem. Negative pressure respirator (tight fitting) means a respirator in which the air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator. Oxygen deficient atmosphere means an atmosphere with oxygen content below 19.5% by volume. Page 3 of 17

4 Page 4 of 17 Positive pressure respirator means a respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator. Quantitative fit test (QNFT) means an assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. Qualitative fit test (QLFT) means the respirator user conducts a pre-use respirator seal check to ensure no leakage of the facepiece. Respirator Mask Storage Cabinet A wooden shelf designed to accommodate respirator masks. SCOTT AV-2000 Red Extra Large (XL) Black Large (L) Green Small (S) SCOTT AV-3000 Red dot on inside seal of mask Large (L) Black dot on inside seal of mask Medium (M) Green dot on inside seal of mask Small (S) Self-contained breathing apparatus (SCBA) means an atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. Service life means the period of time that a respirator, filter or absorbent, or other respiratory equipment provides adequate protection to the wearer. Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. When a SAR is used in an IDLH condition, the individual must also carry an Escape Pack for the safe egress in case of disruption in the air supply. SCOTT AV-2000 [Mesaieed] means site approved full facepiece masks that can be used both as a respirator when fitted with a V-Bar adapter and cartridges or as a SCBA mask when fitted with a regulator. SCOTT AV-3000 [RLOC Only] means site approved full facepiece masks that can be used both as a respirator when fitted with a V-Bar adapter and cartridges or as a SCBA mask when fitted with a regulator. Scott Series Canisters or Cartridges means canisters / cartridges that are designed to provide protection in non Immediately Dangerous to Life & Health (IDLH) or HAZMAT situations. Canisters / cartridges are stored by the user but acquired from the material warehouse through stocked min/max PPE items. Tight-fitting facepiece means a respiratory inlet covering that forms a complete seal with the face. User seal check means an action conducted by the respirator user to determine if the respirator is properly seated to the face. V-Bar adaptor is an adaptor mechanism that fastens the canister filtration elements to the SCOTT AV-2000 or AV-3000 facepiece / mask. Page 4 of 17

5 Page 5 of PROGRAM 4.1. Respirator Selection & Use Respiratory protection is Mandatory when performing work in areas where the airborne pollutant concentration is at or above the Action Level (with the exception of Hydrogen Sulfide, H 2 S see attached Respirator Selection Table) Action Level is equal to 50% or ½ of the Occupational Exposure Limit, OEL (see attached OEL Table) Respiratory protective equipment for Mandatory use must only be used by persons with a valid fit test card or sticker. Fit test card or sticker is printed upon successful completion of the fit test The validity of the fit test and mask size is printed on the card or sticker Q-Chem makes use of the following re-usable respirators: Scott Aviation AV 2000 [Mesaieed & Ras Laffan] Scott Weld-O-Vista Welding Fume Respirator [Mesaieed Only] Scott Aviation AV 3000 [Ras Laffan Only] Scott Aviation Model 66 (XCEL) [Mesaieed] and; MSA OPTIMAIR 3000 Powered Air-Purifying Respirators [Mesaieed Only] In addition, the following disposable respirators are also available: N-95 general purpose respirator mask. FFP2 welding fume respirator mask. NOTE These facepieces have a variety of canisters that may be worn with them; hence, the canisters and facepieces are packaged separately. At the time of issue the appropriate canister is determined, based on the user s needs. Note: Do not use a respirator mask if is not stored in a sealed bag. The only exception to this is the same person using the mask multiple times in one shift Air purifying canisters or cartridges are not to be shared. Once an individual has finished using the canisters or cartridges, they are to be discarded in the appropriate waste container which has been provided and marked within the Environmental waste management program. Page 5 of 17

6 Page 6 of 17 Cartridges used for hexavalent chromium activities will be: Discarded at point of use in specially marked containers and disposed of by Environmental department. Initial mask decontamination will be performed at point of use before being delivered to the Fire Station A set of air purifying canisters are not to be used for more than one shift by any one individual. Replace the canisters after a 12 hour shift as a minimum (See Attached Respirator Selection Table for canister/cartridge replacement cycles). NOTE Air purifying canisters are to be replaced at any time if an individual detects any kind of odour while wearing the respirator mask or if breathing becomes difficult Storage Of Respirators Respirator mask cabinets have been installed in the following areas: Sulfur FIC North Off Site Product Warehouse Maintenance South Off Site Polyethylene FIC Incinerator FIC Central Control Room Central Control Room Maintenance MESAIEED Ethylene FIC Catalyst Activator Building NAO Polyethylene Train III Train III - Catalyst Activator Building 1-Hexene FIC Fire Station Q-Chem II - Central Control Room RAS LAFFAN Fire Station Laboratory Note: The mask cabinet or any of its individual storage compartments are not to be used for anything but the storage of respirator masks in sealed bags. Used masks must not be returned to the mask cabinet compartments After inspection, cleaning, and any necessary minor repairs, store respirators to protect against sunlight, heat, extreme cold and excessive moisture, damaging chemicals or other contaminants Respirators must be packed or stored so that the facepiece and exhalation valves will rest in a normal position and not be crushed. Page 6 of 17

7 Page 7 of Respirators placed at stations and work areas for emergency use will be stored in compartments built for that purpose, will be quickly accessible at all times and will be clearly marked Training Q-Chem respirator users will receive training on the contents of the Respiratory Protection Program (RPP) and their responsibilities under it RPP training is conducted via computer based modules & instructor-led sessions (practical implications) and will include: Q-Chem. Nature and degree of respiratory hazards. Respirator selection, based on the hazard and respirator capabilities and limitations. Donning procedures and fit tests; including hands-on practice (qualitative fit testing). Care of the respirators, e.g., need for cleaning, maintenance, storage, and/or replacement. Use and limitations of respirators Q-Chem respirator users completing the classroom training must then schedule themselves for fit testing and prove competence in donning a respirator For Contractors, the Designated Site Representative (DSR) must ensure training is provided to respirator users prior to being assigned duties requiring the use of respirators. The Training Department must coordinate classroom respirator training as required. Retraining (contractors) must be conducted annually through instructor-led / classroom sessions coordinated by the Safety & Compliance Training Coach The Training Department must retain all training records for all Q-Chem-approved respirator users The Industrial Hygiene Section maintains current fit testing records for all respirator users. Page 7 of 17

8 Page 8 of Fit Testing A fit test shall be used to determine the ability of each individual respirator wearer to obtain a satisfactory fit with any respirator. Both quantitative and qualitative fit tests may be performed Personnel must successfully pass the quantitative fit test before wearing a respirator. Voluntary Use of a Respirator: A fit test is not required for voluntary users or for escape-only respirators No fit testing will be performed on an employee who has facial hair which comes between the sealing periphery of the facepiece and the face, or if facial hair interferes with normal functioning of the exhalation valve of the respirator If a full-facepiece respirator is used, special prescription glass inserts are available if needed. Q-Chem maintains a stock of approved inserts; these can be obtained from the warehouse through the normal issuing process No respirator user is permitted to wear a respirator in a designated respirator work area until he or she has demonstrated that an acceptable fit can be obtained, i.e. passed the necessary quantitative and qualitative (pre-use in field) fit tests Respirator fit testing will be conducted at the following frequency / intervals: Initially upon assignment to a task requiring use of a respirator. Annual re-testing (upon successful completion of the respirator training). Whenever a different respirator face piece is used. If a change in the employee's physical condition could affect the respirator fit If the respirator subsequently becomes unacceptable (i.e., causes irritation or pain to the employee), the employee must be given the opportunity to select a different respirator facepiece and be retested Quantitative fit testing will be conducted by Industrial Hygienist or Technician and/or Fire Technician and the test results will be the determining factor in selecting the size of respirator for use by each individual respirator wearer The user will perform qualitative fit checks each time a respirator is donned (see Appendix for details). These checks are not a substitute for quantitative fit testing. Respirator users must be properly trained in the performance of these checks and understand their limitations. Page 8 of 17

9 Page 9 of Medical Screening The Medical Services Department, under the guidance of QP Occupational Health Physician, will initially, and periodically thereafter, make a determination as to whether or not an employee can wear the required respirator without physical or psychological risk In cases where an employee is not deemed fit to wear the required respirator, the employee, his/her supervisor, and the Industrial Hygienist will be formally notified of the restriction Specific medical tests and procedures will be determined by Q-Chem Senior Health Practitioner in accordance with QP Occupational Health Physician Medical Screening, using the Respiratory Questionnaire, will be provided for all persons required to wear a respirator. NOTE Voluntary Use of a Respirator Employees using respirators when not required under this program must read Appendix 2 Information for Employees Using Respirators When Not Required Under the Standard Maintenance & Care of Respiratory Protective Equipment The Fire Section will ensure that sufficient full facepiece masks are available for issue at any time: Only those persons trained and authorized may disassemble and repair breathing air equipment; this includes all full facepiece masks The maintenance of respiratory protective devices will include: A thorough visual inspection for cleanliness and defects (i.e., cracking rubber, deterioration of straps, defective exhalation and inhalation valves, broken or cracked lenses, etc.). Worn or deteriorated parts will be replaced prior to reissue. No respirator with a known defect is reissued for use. No attempt is made to replace components, make adjustments or make repairs on any respirator beyond those recommended by the manufacturer. Under no circumstances will parts be substituted as such substitutions will invalidate the approval of the respirator. Page 9 of 17

10 Page 10 of 17 Any repair to reducing or admission valves, regulators, or alarms will be conducted by either the manufacturer or a qualified trained technician Respirators shall be cleaned and sanitized after each use and filters and cartridges replaced. Replacement cartridges/ canisters are stored by the user but acquired from the material warehouse through stocked min/max PPE items Cleaning and disinfection of respirators must be done frequently to ensure that skinpenetrating and dermatitis-causing contaminants are removed from the respirator surface. Respirators maintained for emergency use or those used by more than one person must be cleaned after each use by the user Respirators will be cleaned and disinfected by the Fire Technicians following the OSHA approved respirator cleaning procedure Breathing Air Quality Compressed breathing air must meet at least the requirements for Type1 Grade D breathing air as per OSHA 29 CFR (i), to include: Oxygen content (v/v) of % Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less. Carbon monoxide (CO) content of 10 ppm or less. Carbon dioxide content of 1,000 ppm or less. Lack of noticeable odor Cylinders used to supply breathing air to respirators must meet the following requirements: Tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 173 and part 178). Cylinders of purchased breathing air brought onto the Q-Chem site by vendors or contractors must have a certificate of analysis (COA) that ensures the breathing air meets the requirements for Type 1 Grade D breathing air. The moisture content in the cylinder must not exceed a dew point of C (-50 F) at 1 atmosphere pressure Compressors used to supply breathing air to respirators must be constructed and situated so as to: Prevent entry of contaminated air into the air-supply system. Page 10 of 17

11 Page 11 of 17 Minimize moisture content so that the dew point at 1 atmosphere pressure is 5.56 C or (10 F) below the ambient temperature. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filters must be maintained and replaced or refurbished periodically following the manufacturer's instructions. Must have a tag containing the most recent change date and the signature of the authorized person to perform the change. The tag must be maintained at the compressor Oil-lubricated compressors must be fitted with the following: High-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. Electrochemical sensors must be calibrated on a monthly basis to ensure accurate readings in the range of use. Refer to the manufacturers instructions for further information on calibration procedures. If only high-temperature alarms are used, the air supply must be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm For non oil-lubricated compressors, carbon monoxide levels in the breathing air must not exceed 10 ppm All breathing air couplings must be incompatible with outlets for non-respirable worksite air or other gas systems. No asphyxiating substance must be introduced into breathing air lines Only breathing gas containers marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84 must be used Program Evaluation The Industrial Hygienist must audit the Respirator Program every three years, which includes the following: Investigating wearer acceptance of respirators. Inspecting respirator program operation. Appraising protection provided by the respirator. Cleaning and disinfecting procedure Fire Station Page 11 of 17

12 Page 12 of The findings of the respirator program evaluation will be documented and include the following: Plans to correct faults in the program. Target dates for the implementation of the plans Record Keeping Respirator fit-testing will be documented (Fit testing database located with Industrial Hygienist) and include the following: Type of respirator. Brand name and model. Method of test, test results and test date. Name of the instructor/tester. 5. RESPONSIBILTIES 5.1 Industrial Hygienist Acts as the respiratory protection program administrator Provide consultation on the selection and use of respirators Recommends the appropriate respirators and associated equipment for purchasing when determined necessary or warranted Manages the respiratory protection program and facilitates the three yearly reviews Conducts periodic audits to determine the effectiveness of the respiratory protection program Provide quantitative fit testing and training on the use of respirators Maintain fit testing database of all users Issue Fit Test Validation card or sticker Fire Section Assist Industrial Hygiene Section with quantitative fit testing and training on the use of respirators Properly clean, maintain, care for and inspect all respirators prior to issuing to endusers. Page 12 of 17

13 Page 13 of Ensure all breathing air used on Q-Chem sites meet OSHA Type 1 Grade D specifications Inspect and act as approval authority for breathing air systems (compressors and / or cascade systems) brought onto the Q-Chem site by contractors / vendors (See Attachment 5: Breathing Air Quality Report Form) Only issue respiratory protective equipment to person s with a valid fit test card or sticker (check expiry date on card or sticker) Department Managers Ensure that all affected personnel follow this program Where feasible implement workplace (engineering or other) controls to eliminate the need for the use of respirators Supervisors / Designated Site Representative (DSR) Identify work operations and personnel that may require the use of respirators and forward information onto Training & Industrial Hygienist for training & fit-testing respectively Ensure that employees wearing respirators follow the respiratory protection program Ensure that only those employees who have a valid fit test are allowed to wear respirators Medical Services Provide medical surveillance for Q-Chem direct hire, seconded employees and Q- Con who are required to wear a respirator Provide Medical Screening, using the Respirator Questionnaire, to all persons required to wear a respirator End Users Adhere to the requirements of the respiratory protection program Complete all safety training, quantitative fit testing, and medical surveillance requirements and comply with documentation procedures Complete qualitative fit testing (pre-use) Follow guidelines on the proper use and limitations of respiratory protection Return used masks immediately to fire station after use. Page 13 of 17

14 Page 14 of Do not drop off masks to the fire station without fire station personnel being present Do not remove any masks from the fire station without the knowledge of fire station personnel Return new stock back to the respirator mask storage cabinet Ensure the plastic bags containing the masks are sealed properly Respirators used in hexavalent chromium activities will go through proper local decontamination and flushing prior to drop off and exchange at the fire station Notify Fire Section of any equipment problems etc Keep the mask cabinet and compartments free of any dust or other debris Training Department Provide training on the use of respirators Issue Safety Training Report for Contractors prior to Fit Testing appointment. Page 14 of 17

15 Page 15 of REFERENCES Occupational Safety and Health Administration s (OSHA) Respiratory Protection Standard 29 CFR OSHA 29 CFR Appendix B-1: User Seal Check Procedures (Mandatory) OSHA 29 CFR Appendix B-2: Respirator Cleaning Procedures (Mandatory) 7. REVISION HISTORY Revision 4 represents three year review plus inclusion of Fire & Safety Coordinator (FSC) responsibility for checking and approving breathing air systems brought onto the Q-Chem sites by contractors or vendors using Attachment 5 (also new inclusion into program). Revision 3 represents the review for inclusion of Q-Chem II and Ras Laffan Olefins Complex. Scott AV 3000 respirators were purchased for RLOC. QII will utilize the existing Scott AV 2000, which QCHEM is presently utilizing. Respirator size recognition for RLOC was included into the definitions. Addition of locations and number of respirator cabinets in each facility. Revised Respirator Evaluation Questionnaire. ATTACHMENTS Attachment 1 Respirator Selection Table Attachment 2 Respirator Medical Evaluation Questionnaire Attachment 3 Occupational Exposure Limits (OEL) Table Attachment 4 Breathing Air Quality Testing Standard Attachment 5 Breathing Air Quality Report Form APPENDICES Appendix 1 Negative and Positive Pressure Checks Appendix 2 Information for Employees Using Respirators When Not Required Under The Standard Page 15 of 17

16 Page 16 of 17 APPENDIX 1: NEGATIVE AND POSITIVE PRESSURE CHECKS NEGATIVE PRESSURE CHECK Applicability/Limitations: This test cannot be carried out on all respirators; however, it can be used on facepieces of air purifying respirators equipped with tight-fitting respirator inlet covers and on atmosphere supplying respirators equipped with breathing tubes which can be squeezed or blocked at the inlet to prevent the passage of air. Procedure: Close off the inlet opening of the respirator's canister(s), cartridge(s), or filter(s) with the palm of the hand, or squeeze the breathing air tube or block its inlet so that it will not allow the passage of air. Inhale gently and hold for at least 10 seconds. If the facepiece collapses slightly and no inward leakage of air into the facepiece is detected, it can be reasonably assumed that the respirator has been properly positioned and the exhalation valve and facepiece are not leaking. POSITIVE PRESSURE CHECK Applicability/Limitations: This test cannot be carried out on all respirators; however, respirators equipped with exhalation valves can be tested. Procedure: Close off the exhalation valve or the breathing tube with the palm of the hand. Exhale gently. If the respirator has been properly positioned, a slight positive pressure will build up inside the facepiece without detection of any outward air leak between the sealing surface of the facepiece and the face. Page 16 of 17

17 Page 17 of 17 APPENDIX 2: INFORMATION FOR EMPLOYEES USING RESPIRATORS WHEN NOT REQUIRED UNDER THE STANDARD Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard. You should do the following: 1) Ensure you are clean shaven before using any respirator; even disposable masks. 2) Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations. 3) Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you. 4) Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapours, or very small solid particles of fumes or smoke. 5) Keep track of your respirator so that you do not mistakenly use someone else's respirator. Page 17 of 17