HEALTH AND SAFETY PROGRAM CONFINED SPACE ENTRY

Transcription

1 Page 1 of PURPOSE Axiall, Plaquemine Complex, has developed this program to minimize potential accidents, injuries, and to enhance employee protection. This policy establishes requirements for safe entry into confined spaces. Confined space entry procedures will ensure that all safety measures are taken prior to and during all confined space entries. 2.0 SCOPE The following confined space entry procedures apply to work areas which, by their nature, have limited openings for entry and exit or unfavorable natural ventilation which could contain or produce dangerous air contaminants and which are not intended for continuous employee occupancy. 3.0 DEFINITIONS Action Level--An airborne chemical concentration that is fifty percent of established OSHA Permissible Exposure Limits (PEL) or the American Conference of Governmental Industrial Hygienist (ACGIH) Threshold Limit Values (TLV). Attendant--A person who is stationed outside the confined space and is trained to monitor Authorized Entrants inside the space and on non-entry rescue equipment use. Authorized Entrant--An employee who has been trained and authorized to enter the confined space. Confined Space--Any space that meets the following criteria: (ref. OSHA (b) 1. Is large enough and configured so that an employee can bodily enter and perform assigned work, and 2. Has limited or restricted entry or exit, and (Such areas could include tanks, tank cars, vessels, pumps, boilers, manholes, fume tunnels, large pipelines, small vaults, basements, excavations, and other similar confined areas.) 3. Is not designed for continuous occupancy. Confined Space Classification-- a designation of a space based upon existing or potential atmospheric hazards associated with the entry. A confined space must be designated as an A, B or C based upon atmospheric testing prior to entry.

2 Page 2 of 49 Direct Reading Instrument A real-time air monitoring device used to verify suitable atmospheric conditions for confined space entry. Examples of direct reading instruments include: electronic multigas meters (i.e. MSA Sirius, RAE Systems MultiRAE, RKI Eagle 308), electronic single gas meters (i.e.biosystems ToxiPro) and colorimetric detector tubes (i.e. Gastec/Sensidyne tubes). Entry--The action by which a person passes any body part through an opening into a permit-required confined space. Entry includes work activities in that space and occurs as soon as any part of the entrant's body breaks the plane of an opening into the confined space Entry Supervisor--The person (such as Department Supervision or Area Technician) responsible for: 1. determining if acceptable entry conditions are present at a confined space where entry is planned; 2. authorizing entry; and 3. overseeing entry operations and terminating entry as required by this program. Explosion Proof-- Apparatus enclosed, in a case, that is capable of withstanding an explosion of a specified gas or vapor which may occur within it and of preventing the ignition of a specified gas or vapor surrounding the enclosure by sparks, flashes, or explosion of the gas or vapor within, and which operates, at such an external temperature, that it will not ignite a surrounding flammable atmosphere. Hazardous Atmosphere--an atmosphere that may place an employee at risk of death, incapacitation, or impairment of ability to self-rescue, or cause the employee to experience acute illness. Hazardous Cargo, Material, Substance or Atmosphere (Marine Dock)--Means: 1. Any substance listed in 29 CFR Part 1910, Subpart Z; 2. Any material in the Hazardous Materials Table and Hazardous Materials Communication Regulations, Department of Transportation, 49 CFR Part 172; 3. Any article not properly described by a name in the Hazardous Materials Table and Hazardous Materials Communication Regulations, Department of Transportation, 49 CFR Part 172, but which is properly classified under the definition of those categories of dangerous articles given in 40 CFR part 173; or 4. Any atmosphere with an oxygen content of less than 19.5%.

3 Page 3 of 49 High Voltage-- For the purpose of confined space entry this shall be considered greater than 12 volts Immediately Dangerous to Life or Health (IDLH)--Acute respiratory exposure that poses an immediate threat of loss of life, immediate or delayed irreversible adverse effects on health, or acute eye exposure that would prevent escape from a hazardous atmosphere. Low Voltage-- For the purpose of confined space entry this shall be considered 12 volts or less. Lower Explosive Limit (LEL)--The concentration of an airborne compound below which a flame will not propagate if the mixture is ignited. Concentrations less than the LEL are not flammable because there is too little fuel to support combustion. Marine Chemist--The holder of a valid certification card issued by the National Fire Protection Association (NFPA), in accordance with the "Rules for Certification of Marine Chemists." The Marine Chemist is qualified to determine whether inspections, alterations, or repairs of marine vessels, which may involve hazards covered by this program, can be undertaken with safety. Marine Chemist Certificate--A written statement issued by a Marine Chemist in the form and manner prescribed by this program. It states the conditions that the Marine Chemist found at the time of inspection. Non-permit Required Confined Space A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. Permissible Exposure Limit (PEL)--OSHA's established time-weighted average (TWA) concentration or ceiling concentration of an airborne chemical contaminant that may not be exceeded. Permit--An authorization and approval in writing that specifies the location, classification (A, B, or C), and type of work to be done. It also certifies that all existing hazards have been evaluated and necessary protective measures have been taken. Permit Required Confined Space a confined space that has one or more of the following characteristics: 1. Contains or has a potential to contain a hazardous atmosphere. 2. Contains a material that has the potential to engulf an entrant.

4 Page 4 of Has an internal configuration such that an entrant could be trapped and suffocate by inwardly converging walls or by a floor which slopes downward and tapers to a small cross section. 4. Contains any other recognized safety or health hazard. Threshold Limit Value (TLV)--The American Conference of Governmental Industrial Hygienist's (ACGIH's) established TWA airborne chemical concentration in which most people can work consistently for 8 hours a day, day after day, with no harmful effects. Paul will verify definition 4.0 RESPONSIBILITIES 4.1 Health and Safety (H&S) 1. Trains Axiall employees on specific duties for monitoring confined spaces. 2. Trains proper application of the confined space permit procedure to Georgia Gulf: a. Department Supervision; b. Authorized Entrants; c. Attendants; d. Area Technicians; and e. Confined Space Rescue Team. f. Entry Supervisors 3. Provides additional training to Confined Space Rescue Team members that allow them to implement proper confined space rescue procedures. 4. Assists in development and maintenance of entry procedures for all confined spaces at the Axiall's Plaquemine Complex. 5. Assists in development of preplanned rescue procedures for all confined spaces and train the Confined Space Rescue Team in the procedures. 6. Informs contractor personnel during initial hazard communication/safety orientation of Axiall's Confined Space Permit Program prior to performing work at the plant. 7. Ensures that confined space permit procedures are reviewed at least annually.

5 Page 5 of Maintains confined space records. 9. Ensures that only trained Authorized Entrants enter permit- required confined spaces. 10. Ensures that only trained attendants monitor confined spaces. 4.2 Entry Supervisor 1. Entry supervisor must work in the unit where the confined space entry is taking place. 2. Learns, understands, and follows Axiall's Confined Space Permit Program. 3. Determines if acceptable entry conditions are present at a confined space where entry is planned. 4. Authorizes entry. 5. Oversees entry operations and terminates entry as required by this program. 6. Identifies all confined spaces in their area of responsibility. 7. Authorizes written permits to enter a confined space. 8. Ensures all employees involved conform to the confined space permit requirements. 9. Designates an Area Technician for initial confined space atmosphere testing. 10. Notifies CSRT of confined space entry and document rescue plan for entry. 11. Uses preplanned rescue procedures for all confined spaces in their area of responsibility. 12. Notifies H&S if toxic atmosphere readings are above OSHA's PEL or ACGIH's TLV and entry is required. 13. Ensures hazard control per Ensures that Pre and Post Entry conferences are conducted and documented. 15. Ensures preplan is followed prior to work permit issued.

6 Page 6 of Shipping Supervision 1. Learns, understands, and follows Axiall's, Plaquemine Complex, Confined Space Permit Program. 2. Retains the service of a NFPA Certified Marine Chemist to perform Area Technician duties for confined space work in vessels, ships, or barges at the marine dock. 3. Follows all other responsibilities for Department Supervision. 4.4 Contractor Maintenance Hopper Car Repair Area 1. Learns, understands, and follows Axiall's, Plaquemine Complex, Confined Space Permit Program. 2. Follows all other responsibilities for Department Supervision related to HSP202-Confined Space Entry, HSP317-Control of Hazardous Energy, and HSP200-Safe Work Permitting 4.5 Area Personnel 1. Learns, understands, and follows Axiall's, Plaquemine Complex, Confined Space Permit Program. 2. It is the responsibility of the respective unit management to obtain and document user training for those individuals in his area of responsibility who utilize portable gas detection equipment when issuing work permits. 3. It is the responsibility of the production personnel who use portable gas detection equipment in conjunction with Axiall work permitting procedures to comply with the manufacturer s directions and the applicable instructions contained in this procedure. 4. Tests confined space atmospheres and record results on permit. 5. Reviews hazards and precautions of each confined space entry with Authorized Entrants and Attendants and agree that all permit specifications have been met. 6. Determines the necessary procedures and equipment for safe entry. 7. Provides specific confined space entry details that are unique to the job or

7 Page 7 of 49 affected personnel in the area. 8. Assists Department Supervision in classifying the confined space permit as A, B, or C. 9. Ensures field function tests on monitoring equipment are performed once a day. 4.6 Maintenance Crew Leader 1. Learns, understands, and follows Axiall's Confined Space Permit Program. 2. Consults with Department Supervision for hazard identification and hazard control before confined space entry. 3. Reviews hazards and precautions of each confined space entry with Authorized Entrants and Attendants and agrees that all permit specifications have been met. 4. Determines the necessary procedures and equipment for safe entry. 5. Ensures preplan is followed prior to work permit issued. 4.7 Authorized Entrant 1. Learns, understands, and follows Axiall's Confined Space Permit Program. 2. Uses proper confined space entry procedures. 3. Follows established emergency procedures. 4. Wears appropriate personal protective equipment during confined space entry. 5. Recognizes potentially hazardous conditions for self-initiated evacuation from the confined space. Notifies Attendant upon self-initiated evacuation. 6. Receives Health and Safety approved training before entering a confined space. 7. Follows permit requirements, entry procedures, and immediately exits a confined space when requested.

8 Page 8 of Attendant 1. Learns, understands, and follows Axiall's Confined Space Permit Program. 2. Receives Health and Safety approved training before serving as an Attendant. 3. Obtains and inspects equipment in the Confined Space Attendant's Kit. 4. Is familiar with the equipment used in the confined space and know how to shut them off in case of emergency (e.g., welding/burning equipment, air compressors, etc.) 5. Does not leave the job site for any reason while people are in the confined space. Attendants must be in contact (visual, radio, rope tug ) with all Authorized Entrants in the confined space at all times. If space is left unoccupied, the entrance must be properly barricaded with Red Barricade Tape to alert and deter unwarranted entrance into the confined space. 6. Summons CSRT as soon as Manway Attendant determines rescue of Authorized Entrants is warranted. 7. Follows established preplan and emergency procedures. 8. Immediately reports all emergencies to Axiall Supervision. 9. Maintains accurate entry/exit log 10. Knows the emergency phone number. (Ext. 333) 11. Is familiar with the evacuation procedure for the operating unit in which the confined space occurs and monitor the wind direction. 12. Knows the location of the nearest working emergency eyewash/shower station and fire fighting equipment. 13. Keeps all unauthorized personnel clear of the confined space work. 14. It is the responsibility of the respective contract superintendent to obtain and document user training for those contract employees who use portable gas detection equipment when assigned as an attendant in Axiall confined space permit procedure.

9 Page 9 of It is the responsibility of the contract employee, when assigned work as a confined space attendant, to comply with the portable gas detection equipment manufacturer s directions and the applicable instructions contained in this procedure. 16. It is the responsibility of the contract employee, when assigned work as a confined space attendant, to perform periodic/continuous monitoring as required and to complete the required documentation of the monitoring on the entry permit. 17 Prior approval from the H&S Department and Unit Management is required before a non-evergreen contractor is allowed to provide confined space entry attendant services. 4.9 Confined Space Rescue Team Member 1. Learns, understands, and follows Axiall's, Plaquemine Complex Confined Space Permit Program. 2. Properly performs assigned rescue functions. 3. Maintains current certification in Confined Space Rescue, first aid and cardiopulmonary resuscitation (CPR) skills. 4. Develops a Rescue Plan for each confined space entry and notifies a safety representative if scaffolding will be used for rescue purposes prior to use. 5. Waives retrieval equipment for confined spaces when applicable (Section 5.4). 6. Maintains state of readiness and availability during confined space entries. 7. Learns, understands, and follows Axiall's, Plaquemine Complex, Bloodborne Pathogens Exposure Control Plan (OSHA's 29 CFR ) Contractors 1. Contractors operating at Axiall must meet or exceed Axiall's Confined Space Permit Procedures complying with OSHA's 29 CFR (c). 2. Contractor employees are required to use Axiall's confined space permits for entry in areas or during tasks in confined spaces. 3. Contractors will provide H&S documentation to demonstrate they are

10 Page 10 of 49 properly trained and comply with all portions of Axiall's Confined Space Permit Program. 4. Learn, understand, and follow Axiall's, Plaquemine Complex, Confined Space Permit Program for its employees Instrument and Electrical (I&E) Maintenance Department 1. It is the responsibility of the Maintenance Manager to provide the facilities, tools and resources required to perform repairs, calibration and documentation of portable gas detection equipment used in conjunction with Axiall s work permitting procedures. 2. It is the responsibility of the Central Maintenance I/E Supervisor to obtain the training and manufacturer s statement of qualification for those I/E Technicians assigned to repair and calibrate the portable gas detection equipment employed in Axiall s work permitting procedures. 3. It is the responsibility of the Central Maintenance I/E Supervisor to obtain replacement parts and maintain the required equipment documentation and the technician qualification as specified by Axiall Process Safety Management Program. 4. It is the responsibility of those qualified I/E Technicians assigned to repair and calibrate portable gas detection equipment to perform their work in accordance with the manufacturer s procedures and specifications and to comply with the applicable steps outlined in this procedure NFPA Certified Marine Chemist (shipping department has contractor listing) 5.0 PROCEDURE 1. Complete and issue Marine Chemist Certificates, OSHA Forms 74, to marine dock employees before any maritime vessel confined space entry. 2. Comply with all applicable NFPA and OSHA standards. 5.1 Confined Space Classification A confined space must be designated as an A, B or C based upon atmospheric testing prior to entry or known potential atmospheric hazards. 1. Class "A" Confined Space

11 Page 11 of 49 A confined space that is immediately dangerous to life or health (IDLH). Conditions can include, but are not limited to: oxygen deficiency, explosive or flammable atmospheres, and/or concentrations of toxic substances. Entry requires prior authorization of the Health and Safety Department (H&S). 2. Class "B" Confined Space A confined space that has the potential for causing injury and/or illness, if preventive measures are not used, but not immediately dangerous to life and health. Entry requires prior authorization of the Health and Safety Department (H&S). 3. Class "C" Confined Space 5.2 Hazard Recognition A confined space in which the potential hazard may not require any special modification of work procedures. Each Production Department will be required to determine potential hazards of each confined space under their supervision. Department Supervision is responsible for implementing specific procedures to ensure safe confined space entries. It is the intent of Axiall that all confined spaces shall be considered Permit Required. If Department Supervision feels that a confined space presents such low hazard possibilities as to negate the need for permit protocol then they should contact H&S for an evaluation. H&S and Department Supervision will classify the entry as either requiring or not requiring a permit. Since conditions can vary with job scope, a space that does not require a permit for one job may require a permit for another job. If the space is so configured and the potential hazards are such that the space can be permanently listed as a non-permit required space, H&S will issue a memorandum to the appropriate Unit granting this designation. Confined spaces must be conspicuously posted with an appropriate warning. (Danger Confined Space Authorized Personnel Only) Tanks, vessels, reactor columns, etc. are not required to be posted, if all possible entries are securely closed during operation. Immediately following the opening of a manway or other vessel opening the entry must be posted as a confined space. This posting will be conducted by maintenance or operations personnel responsible for removing the manway cover.

12 Page 12 of Oxygen Deficient Atmosphere: Any atmosphere with less than 19.5% O2 will not be entered without an approved positive pressure, self-contained breathing apparatus (SCBA) or will be properly ventilated until the oxygen content is maintained to at least 19.5%. 2. Flammable Atmosphere: a. Two items make an atmosphere flammable: the oxygen in the air and a flammable gas, vapor, or dust in the proper mixture. If a source of ignition is introduced into a space containing a flammable atmosphere, an explosion and/or fire will result. b. An oxygen-enriched atmosphere (oxygen content above 23.5%) will cause certain flammable materials to burn violently when ignited. 3. Toxic Atmosphere: Most substances such as liquids, vapors, gases, mists, solid materials, and dust should be considered as hazardous in a confined space. 4. Engulfment: Loose material, such as soil during excavations that can engulf and suffocate a worker. 5. Slick or Wet Surfaces: Slips and falls can occur on a wet surface with injury or death resulting. A wet surface can increase the likelihood of electrical shock in areas where electrical circuits, equipment, and tools are used. 6. Falling Objects: Individuals working in confined spaces should be aware of the possibility of falling objects, particularly in spaces that have topside openings for entry and where work is being accomplished above the individual in the confined space. 7. Vehicular and Pedestrian Traffic

13 Page 13 of 49 Any confined space entry below grade such that pedestrian or vehicles could impact operations will be adequately flagged and barricaded to protect the entrants and attendants. Examples may include concrete barriers, fencing and saw horses. (See HSP-302 for more detail) 8. Cooling Towers 5.3 Hazard Control All cooling tower entries are considered permit-required confined spaces including shroud. Control measures will be performed to maintain an acceptable atmosphere as allowed by the confined space entry permit. 1. Where conditions warrant, the confined space must be properly cleaned, purged, and/or ventilated to remove any dangerous conditions, gases, or vapors. 2. Verify that only UL approved electrical devices, i.e., lights, tools, power cords, and equipment are used when entering a confined space. 3. Only low voltage lighting devices will be used within metal vessels. High voltage lighting and electric driven tools or devices may be used in connection with UL approved ground fault circuit interrupters (GFCI's). 4. When entering wet or damp confined spaces, ground fault circuit interrupters or similar approved devices must be used. 5. When entering confined spaces where flammable atmospheric conditions may exist, explosion-proof devices, i.e., lanterns, test equipment, etc. must be used. 6. Any welding, torch cutting, or similar hot work in a confined space requires specific written hot work permit approval. (See Axiall's, Plaquemine Complex, Safe Work Permit Program.) 7. Only breathable grade air may be utilized to power pneumatic tools within confined spaces. Never use pure oxygen to power tools or to ventilate a confined space. 8. Because Axiall plant air is backed up with nitrogen it may not be used to power pneumatic tools within confined spaces or to drive pneumatic air

14 Page 14 of 49 movers. 5.4 Safety Equipment 1. Retrieval System a. The following applies to the use of harnesses and lifelines for confined space entry. A retrieval harness with attached lifeline is required for entry into a confined space. Each Authorized Entrant must know how to properly wear the harness. Attendants must know how to attach the harness and retrieval line to Authorized Entrants; and Retrieval lines must be in good condition with a rate capacity of 750 lbs. b. An approved mechanical device must be present to retrieve personnel from vertical type confined spaces more than five feet deep. The end of the retrieval line must be attached to a mechanical device or fixed point outside the confined space in such a manner that rescue can begin immediately. c. Wristlets may be used in lieu of the retrieval harness if the use of wristlets is the safest and most effective retrieval method. d. If work in a confined space is such that a greater hazard will exist by wearing retrieval equipment, a waiver can be requested by utilizing the following steps: A verbal request for waiver should be made to the Confined Space Rescue Team member writing the Rescue Pre-plan. If a waiver is granted, a notation will be made in the comment section of the Confined Space permit and Safe Work Permit at the time of issue. It shall specify that retrieval equipment is not required for the job. This waiver will apply for the duration of the project, unless the scope of work changes. All requests for waivers will be made on a case by case basis prior to scheduling the work. There will be no permanent waiver given for any confined space.

15 Page 15 of Attendant Kit A Confined Space Attendant Kit shall be present for all entries. The kit shall include: Alarm Air horn Red Barricade tape Duct tape Flashlight Inventory list (kit) Pencil Vest (high visibility color) Zip lock bags Radio 5.5 Atmospheric Monitoring 1. All confined spaces will be tested by the designated Area Technician. 2. Before employing any portable gas detection equipment, the qualified user will determine the next scheduled calibration date recorded on the calibration sticker or internal memory on MSA meters. Equipment that does not have a current calibration date will not be used for permitting. The user will record the calibration date on the form when issuing a permit. 3. Confined space atmospheres will be initially tested with a direct-reading instrument(s) and recorded on the Confined Space Permit. Ventilation must be off for at least 15 minutes prior to atmospheric testing. The testing data must be evaluated in the following order: a. O2 content; b. Combustible gases and vapors (LEL); and c. Carbon Monoxide (CO) d. Potential Toxic Air Contaminants NOTE: Although bag samples are not considered as part of the initial test, they may be specified by the entry supervisor to verify that: 1) the direct reading instrument is capable of detecting any toxic gases that may be present and 2) that the direct reading instrument is

16 Page 16 of 49. performing adequately. 4. Confined spaces will be classified based on known potential hazards and/or O2, LEL, and toxic atmosphere monitoring results. 5. When continuous forced air ventilation is used, confined space atmospheres must be continuously monitored (same as initial testing, and data recorded every hour minimum) to ensure ventilation is preventing an accumulation of a hazardous atmosphere. 6. Hot work such as welding in a confined space will require continuous air monitoring for the duration of the work. 7. Initial and periodic monitoring results will be recorded on the permit. 8. Any vacancy of a confined space for greater than thirty minutes shall require the space to be re-monitored prior to reentry, with the same type of direct reading instrument(s) as used in the initial test. This testing must include the same parameters as the initial test. (See HSP above) NOTE: Although bag samples are not considered as part of the initial test, they may be specified by the entry supervisor to verify that: 1) the direct reading instrument is capable of detecting any toxic gases that may be present and 2) that the direct reading instrument is performing adequately. 9. Based on test results, the need for respiratory protection and other personal protection and safety requirements will be determined. (See Appendix D - Requirements for Confined Space Entry.) 10. No entry into confined spaces will be allowed if atmospheric testing reveals that permit specifications have not been met. 11. Any authorized entrant, who will be entering a space, must be given the opportunity to observe all pre-entry monitoring. 12. Any authorized entrant has the right to request re-monitoring of a space if; they did not have an opportunity to observe the initial monitoring; they have reason to believe the monitoring to be inadequate; or they believe

17 Page 17 of Permitting atmospheric conditions may have changed. 1. The Confined Space Entry Permit (Appendix A) documents that confined space entry procedures have been followed. 2. The permit must be signed by: Entry Supervisor Department Supervision, or their designee; Area Technician; and Contractor or Maintenance Supervisor 3. Department Supervision will keep the white copy as an original. 4. The field copy (yellow) must be available at the entrance of the confined space, along with the safe work permit and any additional permits if necessary. (See Axiall's, Plaquemine Complex, Safe Work Permit Program.) 5. More than one Construction or Maintenance Crew may work from the same Confined Space Permit with separate Safe Work Permits. Each additional Supervisor must sign the field copy of the Confined Space Permit in the comment section at the bottom of the permit. 6. The field copy must be returned to Department Supervision following completion of the work or expiration of the permit. 7. The entry permit is valid only during the maintenance shift in which it is issued. Permits must be reissued for each successive shift. The permit will become invalid at the end of the maintenance shift or if conditions change from those in effect when the permit was issued. 8. All (applicable) permit categories must be filled out for the permit to be considered valid. 9. Any authorized entrant, who will be entering a space, must be given the opportunity to observe all pre-entry monitoring. 10. Department Supervision must consult with H&S if toxic atmospheres

18 Page 18 of 49 readings are at or above the action level for OSHA's PEL or ACGIH's TLV before the permit can be completed. Any % LEL may indicate the appropriate PEL has been exceeded. (See appendices.) If this condition occurs, immediately contact department supervision. 11. The permit is invalidated if personnel, personal protective equipment, cleaning processes, hazardous energy control procedures, or work procedures being performed are changed. A reevaluation of the space is required, and the entry permit must be revalidated prior to a second entry. 12. All work must stop immediately if confined space atmospheric monitoring detects a hazardous condition that does not meet permit specifications. Each Authorized Entrant must leave the space immediately, Work can not continue until the confined space has been reevaluated to determine how the hazardous atmosphere developed; and The hazardous atmosphere must be controlled or respiratory protection provided. The Confined Space Permit must be revalidated before entry. 13. The Entry Log (back of Confined Space Permit - Appendix A) must be maintained at the entry point by the Attendant. 5.7 Entry Sequence 1. Department Supervision will issue safe work permits for confined space permit procedures to commence: The safe work permit hard copy must be available at the confined space entry point (manway or vessel) along with the field (yellow) copy of the confined space permit, The safe work permit must have all the required signatures; and All information contained on the safe work permit must be filled out accurately. (See Axiall's, Plaquemine Complex, Safe Work Permit Program.) 2. The Equipment Proprietor will isolate the confined space from hazardous energy. Turn off, lockout, and tag all pertinent electrical, hydraulic,

19 Page 19 of 49 pneumatic, chemical, thermal, gravitational, and mechanical energy sources. (See Axiall's, Plaquemine Complex, Control of Hazardous Energy Program.) 3. When entrance covers are removed and present a fall hazard, the entryway must be promptly guarded by a railing, temporary cover or other barrier that will prevent an accidental fall through the opening and protect Authorized Entrants from falling objects and immediately posted as a Confined Space. (See HSP-302 for more detail) 4. Attendants must obtain a Confined Space Attendant's Kit from the tool room. 5. Attendants will inspect all safety equipment in the confined space kit. 6. Department Supervision (or his designee) will review a written preplanned rescue procedure with the maintenance foreman so he can communicate the preplan with his employees. 7. The Area Technician will test the confined space atmosphere. 8. A Confined Space Entry Permit must be completed. 9. If ventilation equipment is installed the attendant will ensure that the ventilation system does not block the exit. Air supplied for ventilation must be from a clean source (cannot use plant air). 10. The Area Technician, Construction or Maintenance Supervisor/foreman, Attendant, and Entrant(s) will review the permit and agree that all permit specifications have been met. This will serve as the Pre-entry conference. 11. The Authorized Entrant will sign and note the time on the Entry Log and enter the confined space to perform the necessary work. 12. The Attendant must maintain continuous communication with the Authorized Entrant(s) at all times. This may be direct visual and voice communication or two-way radio communication. 13. The Authorized Entrant(s) must exit the confined space immediately when: Physical or mental changes are recognized; There is a suspected increase of impurities or decrease in oxygen level,

20 Page 20 of 49 Changes are detected by monitoring equipment; or Ordered to evacuate by the Attendant. 14. The Attendant must report any unauthorized entry incident or near miss to Department Supervision. 15. Upon completion of the work, the attendant will clean, inspect, and replace required items in the attendant's kit and return it to the tool room. 16. The attendant will ensure that the confined space entry permit has been completely filled out, all entrants names have been logged out and return it to the responsible Department Supervision. 17. A post-entry conference must be held following completion of work, involving the attendant and Operations to discuss special occurrences during the entry. Participants in the Post Entry Conference must sign the Confined Space Permit in the section Post Entry Conference Conducted. Participants must include the attendant and the Entry Supervisor/designee. 5.8 Emergency Rescue Axiall has evaluated confined space rescue options utilizing OSHA s Appendix F Rescue Team or Rescue Service Evaluation Criteria from 29CFR Permit-required Confined Spaces. Based upon this evaluation Axiall will utilize trained in-house personnel in the execution of confined space rescue. 1. Confined Space Rescue Pre-Plan a. A rescue pre-plan must be developed by a CSRT member prior to any Confined Space Entry. b. The pre-plan must be documented on the Axiall Confined Space Rescue Pre-Plan (or equivalent) form in Appendix F. c. The pre-plan may be completed in advance with the exception of the CSRT on Site section, which must be completed on the date of entry. d. Security will facilitate availability of CSRT members for each shift. e. Prior to the issuance of the Confined Space Entry Permit, the Department Supervision or his designee must:

21 Page 21 of 49 contact a CSRT member to authorize that the pre-plan is valid for conditions existing on day of entry verify and document CSRT on site (Appendix F) alert CSRT members identified on preplan of confined space entry f. ADEQUATE CSRT COVERAGE AS DEFINED IN THE PREPLAN IS REQUIRED PRIOR TO CONFINED SPACE ENTRY AND MUST BE MAINTAINED FOR THE DURATION OF THE ENTRY. g. The Confined Space Rescue Pre-plan must be communicated to all affected employees prior to the entry. h. The original Confined Space Rescue Pre-Plan form must remain in the custody of operations. i. A copy of the Confined Space Rescue Pre-Plan must be attached to the field copy of the Confined Space Entry Permit for the duration of the job. The Confined Space Entry Permit must be retained for one year. 2. Rescue Procedures a. A rescue preplan must be developed prior to any Confined Space Entry by a CSRT member. b. The following steps should be reviewed with the Confined Space Attendant prior to all entries. c. When a rescue becomes necessary the attendant: will sound four short blasts from an alarm horn during an emergency. will immediately notify Axiall Supervision to summon the Confined Space Rescue Team and void all Confined Space Entry Permits via the red phone. will attempt rescue using lifeline and mechanical retrieval equipment from outside the confined space (non-entry rescue). will not under any circumstance enter the confined space to rescue

22 Page 22 of 49 the employee inside. d. During rescue operations, all other confined space entry permits are voided until the all clear is given via the red phone. Confined space permits must be reissued. 3. Confined Space Rescue Team a. The Confined Space Rescue Team is composed of volunteer Axiall employees trained in the aspects of confined space rescue (see Axiall Emergency Response Procedures). 5.9 Monitoring Equipment Atmospheric monitoring equipment is available through each operating area. 1. Department Supervision: a. Ensures required calibration of their atmospheric testing equipment is conducted (see HSP-414). b. Ensures field tests (function test) are performed before each use. This function test must be documented in Daily Operation Log. 2. Instrument and Electrical: Maintenance Department a. The Central I&E Shop is responsible for calibrating all atmospheric testing equipment per manufacturer's specification. b. Monitoring instrument calibrations will be documented. c. Monitoring instruments will be marked with a calibration sticker with date of calibration, re-calibration due date, and the person performing the calibration. d. In the event that Central I&E is not available for calibration, a qualified individual may calibrate the instrument and must document this process Marine Dock Work and Ship Inspection Whenever work is performed in vessels, ships or barges, a Marine Chemist Certificate and OSHA Form 74 "Log of Inspections and Tests by Competent Person" must be issued by a NFPA Certified Marine Chemist or competent person.

23 Page 23 of 49 This requirement will include confined space entry by Axiall marine dock employees for inspections and/or analysis of the ship's compartments. Requirements of the National Fire Protection Association's (NFPA 306) "Standard for the Control of Gas Hazards on Vessels" must be met. The NFPA Certified Marine Chemist or competent person is responsible for ensuring compliance with these requirements. 1. NFPA Certified Marine Chemist or Competent Person: a. Must hold a valid certification card issued by the National Fire Protection Association in accordance with the "Rules for Certification of Marine Chemists." b. Is responsible for performing all the duties of an Area Technician. c. Must physically inspect and test each applicable compartment or confined space ensuring compliance with OSHA and NFPA requirements before issuing a Marine Chemist Certificate. d. Must complete, then issue the Marine Chemist Certificate, OSHA Form 74, to marine dock employees before any maritime vessel confined space entry. 2. Marine Chemist Certificate: a. The Marine Chemist Certificate must be prepared and contain all information required by the National Fire Protection Association's Standard NFPA 306. The Marine Chemist Certificate must be signed by: An NFPA Certified Marine Chemist; and Shipping Supervision. b. Copies of the Marine Chemist Certificate, OSHA Form 74, and any other necessary permits will be posted outside the confined space before entry. 6.0 TRAINING Health and Safety (H&S) will consult with production departments to establish specific training programs. 6.1 Initial Training:

24 Page 24 of Confined Space training will be provided to: Department Supervision; Authorized Entrants; Attendants; Area Technicians; and Confined Space Rescue Team. 2. Instruction for safe confined space entry including demonstration of safety equipment and gas testing devices will be provided. 3. Additional detailed instructions will be provided to Authorized Entrants and Attendants, and the Confined Space Rescue Team on: Proper application of the Confined Space Permit Procedure; The types of potential hazards of each confined space; Communication with control room and communication with entrants; Emergency rescue; and Protective equipment. 4. All employees will receive appropriate Confined Space training prior to performing any confined space entries. 6.2 Refresher Training Employees will receive training under the following circumstances: 1. Job reassignment or there is a change in confined space operations that presents a hazard that an employee has not previously been trained. 2. Revisions of Axiall's, Plaquemine Complex, Confined Space Program. 3. Whenever a periodic inspection reveals that employees are not fully aware of or are not following established procedures. 6.3 Confined Space Rescue Team 1. Are instructed in proper rescue functions: Equipment necessary for confined space rescue; and Personnel protective equipment.

25 Page 25 of Will practice making confined space rescues at least once a year: Simulating rescue operations; and Removing personnel through representative confined space openings. 7.0 RECORDKEEPING 3. Will receive annual basic first aid, CPR, and Bloodborne Pathogen training. (See Axiall's, Plaquemine Complex, Bloodborne Pathogens Exposure Control Plan.) 7.1 Permits 1. Confined space entry permits will be maintained by the production departments and forwarded to H&S on a timely basis. 2. Marine Chemist Certificates, OSHA Forms 74, and Axiall Confined Space Permits for marine dock work will be maintained by the Shipping Department for 3 months following work completion. Permits will then be forwarded to H&S. 3. H&S will retain all canceled confined space entry permits for one year to facilitate the Confined Space Permit Program audit. 4. If confined space work is performed in an atmosphere containing airborne chemical concentrations above OSHA-PEL or ACGIH-TLV, then permits will be maintained with the employee's workplace monitoring file for at least thirty (30) years. 7.2 Training Records 1. Training records are maintained in the Plateau electronic data base. 7.3 Instrumentation 1. Calibration records for monitoring equipment will be maintained by maintenance for one year. 8.0 REVIEW 8.1 Axiall's Confined Space Permit Procedures will be reviewed annually. H&S will

26 Page 26 of 49 ensure this review is performed. The purpose is to assess compliance, to ensure that all employees who should be included are, and to evaluate program effectiveness. The review will evaluate: The current Confined Space Permit Procedures; All employee work practices involving activities and application of the Confined Space Permit Program; Canceled Confined Space Entry Permits; Employee training records; Equipment necessary for safe entry; Equipment necessary for rescue; and Employee awareness. 8.2 Following the review, the Confined Space Permit Program will be revised to include any necessary changes. Review results will be documented. All employees will be informed of any changes made in the plan. 8.3 Department Managers will be informed of review results. SIT will develop corrective action plans and schedules to address any deficiencies documented during reviews. Corrective action plans will be submitted to PMT and H&S. 8.4 In the event of a confined space entry accident, an Incident Investigation will be conducted following procedures outlined in Axiall's, Plaquemine Complex, Emergency Response Program. 9.0 REFERENCES American National Standards Institute (1989). "Safety Requirements for Confined Spaces," ANSI Z , New York, NY. National Fire Protection Association (1988). "Standard for the Control of Gas Hazards on Vessels," NFPA 306, Boston, MA. National Institute for Occupational Safety and Health (NIOSH), (December, 1979). "Criteria for a Recommended Standard--Working in Confined Spaces," DHEW (NIOSH) Publication No , Cincinnati, OH. National Institute for Occupational Safety and Health (NIOSH), (July, 1987). "Guide to

27 Page 27 of 49 Safety in Confined Spaces," DHHS (NIOSH) Publication No , Morgantown, WV APPENDICES Appendix A - Confined Space Entry Permit. Appendix B - Confined Space Classification Table. Appendix C - Checklist of Considerations for Entry, Working In, and Exiting Confined Spaces. Appendix D - Requirements for Confined Space Entry. Appendix E - Confined Space Toxic Atmosphere Summary. Appendix F- Confined Space Rescue Pre-Plan Appendix G Confined Space Permit and Check List

28 Appendix A Confined Space Entry Permit

29

30

31 Appendix B Confined Space Classification Table

32 CONFINED SPACE CLASSIFICATION TABLE Parameters Class A Class B Class C Characteristics immediately dangerous to dangerous, but not potential hazard - requires life and health - rescue immediately life threatening no modification of work procedures require the - rescue procedures require procedures - standard entry of more than one the entry of one or more rescue procedures - direct individual fully equipped than one individual fully communication with with life support equipment equipped with life support workers, from outside the - maintenance of equipment - indirect visual confined space communication requires an or auditory communication additional standby person with workers stationed within the confined space Oxygen 16% or less 16.1% to 19.4% or greater than 23.6% 19.5% % Flammability Characteristics 20% or greater of LEL 10% - 19% LEL <10% LEL Toxicity *IDLH greater than contamination less than contamination

33 level, referenced in 29 CFR Part 1910 Sub Part Z - less than *IDLH level referenced in 29 CFR Part 1910 Sub Part Z *Immediately Dangerous to Life or Health - as referenced in NIOSH Registry of Toxic and Chemical Substances, Manufacturing Chemists data sheets, industrial hygiene guides, or other recognized authorities. Note: Class A work is not permitted by Axiall Personnel unless for rescue purposes.

34 Appendix C Checklist of Considerations for Entry, Working In, and Exiting Confined Spaces

35 CHECKLIST OF CONSIDERATIONS FOR ENTRY, WORKING IN, AND EITING CONFINED SPACES ITEM CLASS A 4 CLASS B 4 CLASS C 1. Safe Work Permit 2. Confined Space Permit 3. Hot Work Permit O O O 4. Atmospheric Testing (LEL, O2, and Toxic) 5. Monitoring (Welding, PEL contaminants) O 6. Medical Surveillance (i.e., respirator qualification) O 7. Training of Personnel 8. Labeling and Posting 9. Preparation Hazardous Energy Control Procedures 1 Purge and Ventilate Cleaning Processes Requirements for Special Equipment/Tools O O O O O O 10. Procedures Initial Plan Attendant Communications/Observation Rescue Plan Work 11. Safety Equipment and Clothing 2 Head Protection Hearing Protection Hand Protection Foot Protection Body Protection Respiratory Protection 3 Safety Belts Life Lines, Harness O O O O O O O O O O O O O O O O O O 12. Rescue Equipment 13. Recordkeeping - indicates requirement O - indicates determination by the qualified person 1. See Axiall's, Plaquemine Complex, Control of Hazardous Energy Program 2. See Axiall's, Plaquemine Complex, Personal Protective Equipment Program 3. See Axiall's, Plaquemine Complex, Respiratory Protection Program 4. Class A and B Entry requires prior authorization of the Health and Safety Department (H&S)

36 Appendix D Requirements for Confined Space Entry

37 REQUIREMENTS FOR CONFINED SPACE ENTRY Needed Equipment Class A Class B Class C Positive pressure SCBA for each man in confined space plus one for Attendant outside. Devices must be fully charged. OR 5-minute positive pressure escape pack with airline supply. 1 Hose length must not exceed 250' per man. 2 NO Body Protection (head, body, arms, hands, feet) As Required Harnesses 3 Must be worn Must be worn Must be worn Lifeline Attached 4 Alarm Horn 3 Radio Communication Provided Atmospheric Testing Continuous Monitor NO Personnel Training Preparation Hazardous Energy Control Procedures Purge and Ventilate Cleaning As Required Requirement for Special Tools As Required As Required As Required

38 1. Plant air is not to be used as source of breathing air under any circumstances. (See Axiall's, Plaquemine Complex, Respirator Program.) 2. See Axiall's, Plaquemine Complex, Respirator Program.) 3. Item included in Confined Space Attendant's Kit available from tool rooms. 4. The lifeline may be discontinued if its use will endanger the entrant.

39 Appendix E Confined Space Toxic Atmosphere Summary

40 Confined Space Toxic Atmosphere Summary OSHA ACGIH PEL 1 TLV 2 IDLH 3 LEL 4 10% LEL 5 10% LEL Chemical (ppm) (ppm) (ppm) (%) (%) (ppm) 6 Acetone , ,500 AMS (α - methylstyrene) ,900 Carbon Dioxide 5,000 5,000 40,000 N/A N/A N/A Carbon Monoxide , ,500 Chlorine N/A N/A N/A Cumene EDC (Ethylene dichloride) 1 10 Ca ,200 Ethylene NE 200 NE ,700 Hydrogen NE SA 9 NE ,100 Hydrogen Chloride C 5 C 2 50 N/A N/A N/A Hydrogen Sulfide C ,000 Methane N/A 1,000 NE ,300 Methanol (methyl alcohol) , ,000 Phenol ,800 Sodium Hydroxide (NaOH) N/A 2 (mg/m 3 ) 10 (mg/m 3 ) N/A N/A N/A Vinyl chloride 1 1 Ca ,600

41 ppm: parts per million N/A: Not Applicable NE: Not Established Ca: Cancer causing agent or cancer suspect agent SA: Simple Asphyxiant, A substance that can cause unconsciousness or death by suffocation (asphyxiation) without other significant physiologic effects. C: Ceiling limit, A concentration that shall not be exceeded during any part of the working exposure Occupational Safety and Health Administration (OSHA) Permissible Exposure Limit (PEL): The value listed in the table is the more conservative value from either the 1989 Vacated OSHA PELs or the current OSHA PELs. American Conference of Governmental Industrial Hygienists Threshold Limit Value. Immediately Dangerous to Life and Health. LEL: Lower Explosive Limit. 10% LEL: Atmospheres with a concentration of flammable vapors at or above 10 percent of the lower explosive limit (LEL) are considered hazardous when located in confined spaces. However, atmospheres with flammable vapors below 10 percent of the LEL are not necessarily safe. 6 To convert from an LEL percent (%) concentration (C) of a gas to parts per million (ppm): Cppm = ( C% ) x 1,000,

42 Note: This calculation is used with only atmospheric testing equipment calibrated for the specific gas in question. Sources: ACGIH's TLV for Chemical Substances and Physical Agents and Biological Exposure Indices NIOSH's Pocket guide to Chemical Hazards OSHA's 29 CFR "Air Contaminants - Tables Z-2-A, Z-2, and Z-3"

43 APPENDI F CONFINED SPACE RESCUE PRE-PLAN

44