FREQUENTLY ASKED QUESTIONS (FAQ s) Confined Space Program

Transcription

1 Frequently Asked Questions: 1) Who completes the confined space work risk assessment? 2) Does the air quality tester need to wear respiratory PPE for initial air quality testing? What PPE do they require? 3) Who must complete the initial air quality test for confined space entry? 4) Why do we need to reference MSDS with the entry plan documentation at the confined space? 5) Can the confined space permit issuer be the confined space entry supervisor? 6) Why is a coordination document required? 7) Who is responsible for the coordination document? 8) Can the attendant be part of the Rescue Team? 9) What level of first aid training and rescue procedure training is required? 10) Is the rescue team leader allowed to enter the confined space? 11) Does rescue equipment need to be deployed? Example the Sked stretcher. 12) Back up rescue plan: where is this identified on the forms? Is this an alternate rescue plan? Is this doubling up on available rescuers? 13) Does the rescue team need to be identified on the coordination document? 14) Must rescuers monitor and take air quality readings during a rescue? 15) How many rescuers do I need for a safe entry? Where does the rescue team members need to be located with regards to response time to the confined space entry point? 16) Can the Confined Space entry supervisor be the rescue team leader? 17) Are there confined space rescue restrictions, which would halt or put a rescue on standdown condition? 18) We have tested our rescue plans by retrieving a 200 lbs mannequin from the confined space, do I need to tag-out and send out the rescue retrieval equipment for recertification? 19) We have tested our rescue plan 5 yrs ago and it worked, do we have to re-test our plans? 20) What are the training requirements for external service providers? 21) Must I wear a full body harness in a confined space? 22) Does it have to be a supervisor who completes the initial air quality test? Ontario Operations Confined Space program FAQ s Pg. 1 of 10

2 23) Can a supervisor designate another supervisor, mechanic, labourer, miner as the confined space entry supervisor? 24) Do contractors have access to the Vale tested confined space rescue plans-proceduresrescue plan test documentation? 25) Who is responsible to ensure that the Vale Confined Space program is followed by contractors? 26) Do employees that are used for back-up rescue plan need to be recorded on the rescue plan sheet with the primary rescue team? 27) If a complete test is done and recorded on a rescue test form, does a new form need to be generated each time for the same confined space and is the exact same as tested and recorded rescue plan)? 28) Regarding the confined space entry permit number, what defined the permit numbers? 29) Do we notify Vale 1st Aid at mines or plants of our entry into a confined space? 30) What training is required for a plant operator to be able to enter a confined space and isolate (example: a high pressure steam line) with a contractor confined space team in place? Ontario Operations Confined Space program FAQ s Pg. 2 of 10

3 1) Q: Who completes the confined space work risk assessment? A: The confined space entry supervisor who in consultation with the permit issuer on behalf of the owner of the confined space within an operating area. Note: the permit issuer is the operations supervisor or his/her designate employee competent person or in the case of a project the Constructor. 2) Q: Does the air quality tester need to wear respiratory PPE for initial air quality testing? What PPE do they require? A: Dependent on the confined space work risk assessment of potential atmospheric hazards of the confined space upon initial opening and air quality testing the person taking the air quality test may require respiratory PPE, the work risk assessment will identify the type of respiratory PPE which may be requires for the initial air quality test (i.e. ½ mask, full face mask, SCBA, etc.). 3) Q: Who must complete the initial air quality test for confined space entry? A-1: The initial air quality test for existing Vale owned confined spaces, are completed by Vale qualified personnel (operating area who owns the confined space), and then at this point ownership of the confined space gets handed over to a Vale work crew / group who Manages the job / task or project management group who Manages the project (i.e. Constructor, EPCM firm (ex: Hatch), or General Contractor) to complete the initial test on subsequent shifts or days, until handed back over to operations. A-2: For newly constructed confined spaces, it is the responsibility of the Constructor, EPCM, or General Contractor to complete the initial air quality test. Note: EPCM = Engineering, Procurement, Construction, Management. 4) Q: Why do we need to reference MSDS with the entry plan documentation at the confined space? A: The importance of referencing the MSDS of the contents or former contents of a confined space as some of our confined spaces may have potential residues which may affect atmospheric hazards, the same can be said for products and materials we plan to use in a confined space some may have potential to change atmospheric conditions. 5) Q: Can the confined space permit issuer be the confined space entry supervisor? A: Yes, if a supervisor of an operating area has some of his or her work crews performing work in a confined space within their operating area, and they are also supervising the confined space work, then the permit issuer and the confined space entry supervisor can be the same person. 6) Q: Why is a coordination document required? Ontario Operations Confined Space program FAQ s Pg. 3 of 10

4 A-1: The coordination document as per the regulation is required when employees of more than one employer perform work in the confined space or related work with respect to the same confined space, for Vale Ontario Operations we have added more than one employer or Vale work group(s). A-2: The coordination document is intended to ensure that employers of workers or Vale work groups working in a confined space are aware of potential or existing hazards that may be introduced by one or the other employers or Vale work groups, and that there is communication between the employers or Vale work groups in order to ensure worker safety. 7) Q: Who is responsible for the coordination document? A-1: For operations the coordination document is prepared by the Lead Employer. The Lead Employer as defined by the regulation is an employer who contracts for the services of one or more other employers or independent contractors or Vale Work Group in relation to one or more confined spaces that are located either in the Lead Employer s workplace or in another Employer s workplace. A-2: On a construction project, the Constructor is responsible for the preparation of the coordination document, if workers of more than one employer or Vale Work Group perform work in the same confined space or related work with respect to the same confined space on a construction project. 8) Q: Can the attendant be part of the Rescue Team? A: No, not unless the attendant has been replaced by another person knowledgeable in the attendant duties. During the rescue, an attendant must remain in place stationed outside and near the entrance to the confined space. The attendant may assist the rescue as long as the work does not impede the attendant s duties. Example: The entry plan has the entrant connected to a winch or SRL 3, and the rescue plan is a non-entry rescue and identifies if the entrant is incapacitated the entrant is retrieved out of the confined space, the retrieval devices are at the entrance to the confined space where the attendant is situated, then the attendant can call for rescue assistance and begin retrieving the entrant out of the confined space, rescuers would arrived and assist in removing the entrant from the confined space access point. 9) Q: What level of first aid training and rescue procedure training is required? A-1: The regulation does not define the level of training required. However employers are required to determine the level of training required based on the assessment and the relevant plan and written on-site rescue procedures. A-2: First aid training in the province of Ontario is regulated by the WSIB O.Reg clearly identified Employer s responsibilities for first aid training and supplies as per the size of the workforce/crew. A-3: Vale SPI SAF 08 First Aid Training identifies key individuals within any workforce must have first aid training, and also identifies mandatory training levels for 1st line supervisors (standard first aid & CPR), Plant Protection Personnel (advanced first aid including automatic external defibrillation), Mine Rescue Personnel (Mine Rescue Standard First Aid & CPR), Electricians (standard first aid & CPR), any other employee who wishes to obtain or remain current in first aid will be given the opportunity to take the course on their own Ontario Operations Confined Space program FAQ s Pg. 4 of 10

5 time (restricted to a maximum 2-day standard first aid course. Please refer to SPI SAF 08 for more information. 10) Q: Is the rescue team leader allowed to enter the confined space? A: Yes, the rescue team leader is the person in charge of all rescue activities, there may be rescue situations which he or she may have to enter the confined space to lead or direct the rescue team. 11) Q: Does rescue equipment need to be deployed? Example the Sked stretcher. A: This is dependent on the work risk assessment, type of rescue required. Ex.-1: For a vertical lift to extricate an injured person from the confined space, then the Sked stretcher should be prepared for a vertical lift, and then re-loaded back into the Sked carry bag to facilitate passing the Sked to rescuers inside of the confined space. Ex-2: The Sked used as a stretcher for a same level extrication, the Sked can be rolled up inside the carry bag, and then passed to rescuers inside, deployed, package the injured person and carry them out of the confined space. 12) Q: Back up rescue plan: where is this identified on the forms? Is this an alternate rescue plan? Is this doubling up on available rescuers? A1: Every good rescue plan has contingency plans, there are two entrants that need to be rescued, two rescuers enter the confined space, what if a rescuer is incapacitated from a slip and fall on same level and fracture his leg, what s the plan? A-2: A back up plan is meant to identify who else from the confined space work crew or the operating area can be a back-up rescuer, are they trained in the use of the rescue equipment, have they reviewed the entry plan and rescue procedures, have they locked out, are they available, how do we communicate to call them into action? 13) Q: Does the rescue team need to be identified on the coordination document? A: Only if they are a different employer, or different Vale work group. 14) Q: Must rescuers monitor and take air quality readings during a rescue? A: Yes, during any entry type rescue, continuous air quality monitoring and at frequent intervals as identified in the rescue plan, the atmosphere in all parts of the confined space to be entered for Oxygen Content, Flammability, Lower Explosive Level (LEL) and Toxicity is required and in that order, these readings are also communicated back to the attendant and recorded as part of the rescue plan recorded data. Ontario Operations Confined Space program FAQ s Pg. 5 of 10

6 15) Q: How many rescuers do I need for a safe entry? Where does the rescue team members need to be located with regards to response time to the confined space entry point? A-1: The confined space work risk assessment will assist in determining how many rescuers are required for the plan and where they are to be staged, (i.e. general work area or at the confined space.) A-2: When entry is made into an IDLH atmosphere or that can quickly develop an IDLH atmosphere (if ventilation fails or for other reasons) the emergency response team shall be present and ready to respond immediately. Present and ready to respond immediately means the emergency response team specified in the rescue plans are at the confined space, PPE is donned (respirator mask is at the ready position), and all other controls needed to enter the confined space immediately are in place. When these conditions are satisfied, the team members should reach the entrant(s) in 3 minutes. 16) Q: Can the Confined Space entry supervisor be the rescue team leader? A: Yes, the confined space entry supervisor was part of the work risk assessment, development of the plan specific procedures, development and testing of the written on-site rescue plans and for the confined space job, the confined space entry supervisor would also be required to be trained in the use of rescue equipment to the plan specific rescue plans, and have a good working knowledge of the rescue team leader roles and responsibilities as outlined in the confined space program. 17) Q: Are there confined space rescue restrictions, which would halt or put a rescue on standdown condition? A: Yes, the intent of this topic is to not perform hazardous rescue entries and to ensure that hazards to rescuers are kept to an absolute minimum: 1. rescuers should not enter confined spaces containing atmospheres greater that >10% LEL, regardless of PPE worn, (there is no adequate protection from an explosion within a confined space, increase ventilation and exhaust CFM to lower the LEL); 2. Limit the danger of entanglement to rescuer, (if an entrant is entangled, the rescue team leader must identify the source of energy that cause the entanglement and bring to a Zero Energy State); 3. Allow for easier retrieval of rescue entrant should this become necessary, (provide for clear passage through the opening without the removal of necessary PPE including SCBA); 4. Major fire or explosion(s) within a confined space 5. Any other identified uncontrolled risk that would compromise the safety of rescuers. 18) Q: We have tested our rescue plans by retrieving a 200 lbs mannequin from the confined space, do I need to tag-out and send out the rescue retrieval equipment for recertification? A: Yes, retrieval devices (winch / SRL2 / SRL3) once loaded with weight must be re-certified by a manufacturers authorized service agent. Ontario Operations Confined Space program FAQ s Pg. 6 of 10

7 Special Note: It is recommended to use the SRL and status tag describing For Training Use Only so the SRL being used for the rescue plan test does not get mixed up with the certified for use SRL s, as the one used for the rescue plan test was actually loaded and required re-certification. 19) Q: We have tested our rescue plan 5 yrs ago and it worked, do we have to re-test our plans? A-1: Once the developed and written on site rescue plan has been tested there is no requirement to have it re-rested, however, if through annual procedure reviews the procedure changes for some reason say due to engineering improvements inside of the confined space to make it possible for a non-entry rescue from an entry rescue identified in the procedure, or new rescue retrieval/product becomes implemented then yes the rescue procedure will need to be re-tested. Please note: our program now identifies 4 options for testing of rescue plans that are acceptable. A-2: If the successful recorded rescue test was an non-entry type rescue, and the plan has changed for a specific task / job / project to an entry type rescue, then the entry type rescue needs to be tested. 20) Q: What are the training requirements for external service providers? A-1: All external service provider employers and employees who may be required to work in a or manage the work in a confined space or perform related work with respect to the same confined space require a Generic confined space entry, air quality testing and monitoring training (i.e. NORCAT, WSN or an In- House training program) and be also trained to the specific entry plan and procedures. A-2: External service provider employers who have their in-house rescue personnel who are designated as rescuers and staff personnel who may be required to develop a confined space rescue plan or manage a rescue must also be trained in rescue, rescue equipment and be trained to the specific written on-site rescue procedures. Special Note: New 2014 Vale Confined Space program update: External Service Provider Confined Space Entry Supervisors must complete the Vale General Training Method program Confined Space awareness, Confined Space Attendant & Entry Personnel, and Rescue Training programs which are to be delivered by Vale Learning & Development trainers, then must also complete the New Vale Confined Space Entry Supervisor training module, also delivered by L&D trainers, scheduling session is through their Vale project contract person. 21) Q: Must I wear a full body harness in a confined space? A-1: The answer is determined in the confined space work risk assessment and rescue plan development a) Are there elevation changes within the confined space, or is a scaffold used to access various levels of a confined space, or are there open hole conditions within the confined space, or does the rescue plan call for a full body harness to facilitate emergency extrication from a confined space, if the answer is yes to any of these questions then yes a full body harness must be work by all who enter a confined space. Ontario Operations Confined Space program FAQ s Pg. 7 of 10

8 b) In the event the confined space work risk assessment identified that a full body harness may pose potential hazards to entry personnel due to restricted areas of the confined spaces, then alternate measures and devices for extrication must be identified for the specific entry and rescue plans as well as information, instruction and training must also be given to entry personnel of the specific confined space. c) The confined space work is in a baghouse, with a large door, no elevation changes, and the rescue procedures identified that the injured person is picked up and placed into a stretcher and carrier out, then no a full body harness is not required; a similar situation may be a Thickener with a large opening, proper access and egress provisions are in place, no elevation changes, the rescue procedures identify that the injured person is picked up and placed into a stretcher and carried out. 22) Q: Does it have to be a supervisor who completes the initial air quality test? A-1) this can be completed by the supervisor or a designate who is trained in the Vale Confined Space Entry training program, and who has also been trained on the air quality monitoring device they are utilizing. A-2: If we have a contractor who is to perform work in an existing confined space (U/G & Surface), the Vale supervisor or designate (as identified above) can perform the initial confined space air quality test, identify the readings, test all levels of the confined space, identifies the readings on the permit and all other safe guards are in place (top portion of permit only), then sign off on the permit and the contractor entry supervisor will complete the bottom portion of the permit, signs off and starts the job, then for the start of the next shift/day we would need to complete the process over again, as we own the equipment (confined space) A-3: Another option to the above statement is when you have a constructor (which does not happen underground in a mine), and can happen on the surface at a mines (i.e. Coleman Sand Plant or Smelter Clean AER Project) and the project is being managed by Vale PMO (All Mines or Surface) or a EPCM Firm or other Constructor (surface projects only), then the Vale supervisor or designate can complete the initial air quality testing in a confined space, confirm required safe guards are in place (isolation-zes etc.) complete the top portion of the permit, then the contractor can complete the bottom portion, signs off and the job starts. At the start of the next shift/day the PMO (Vale Constructor) or EPCM firm or other Constructor would be the Vale entity who would complete the initial air quality test, complete the top portion of the permit, sign off, and contractor entry supervisor completes the bottom portion and also signs of and the job starts. A-4: If a general contractor is to build a new confined space (one that never existed), they can complete all pre-entry requirements on the confined space entry permit (top and bottom), please note the contractor must use the Vale permit and associated documentation as identified in our program. 23) Q: Can a supervisor designate another supervisor, mechanic, labourer, miner as the confined space entry supervisor? A: Our position is if the designated person is trained, qualified, experienced, has a good understanding and has been trained in our Vale general training as well as entry supervisor training, understands the hazards of the particular confined space as per the entry plan, understand the coordination document requirements (multi-employers of Vale Work Groups), understands the rescue plan, rescue equipment and rescue team requirements, understands their duties and responsibilities as the confined space entry supervisor, then we see not issue with a designated person supervising confined space work. Ontario Operations Confined Space program FAQ s Pg. 8 of 10

9 Please Note: the confined space entry supervisor training requirements as per Vale Confined Space Program 1) Awareness level, 2) Attendant and Entry Personnel 3) Rescue training, 4) Entry Supervisor training as well meet the requirements of SPI SAF 8 First Aid training requirements section 5.0 as a supervisor designate. 24) Q: Do contractors have access to the Vale tested confined space rescue plans-proceduresrescue plan test documentation? A: Yes, contractors can have access to these tested rescue plans ; all you need do is ask your plant or project contact person so you can review. Note: If a contractor chooses to use the same plan, same method, same rescue equipment, the rescue plan does not have to be re-tested, if a contractor changes the wording, or uses other type of rescue equipment (say the Vale rescue plan is to use a tripod, and the contractor elects to use a davit arm), then the rescue plan is not the same and must be tested as per our Vale Confined Space program. Special Note: If the Vale plant or project contact person want the contractor to test the very same plan that has been tested in the past, they have that right, many times this is to ensure the contractor workforce understands and can execute the rescue plan. 25) Who is responsible to ensure that the Vale Confined Space program is followed by contractors? A: The Vale plant/mine/project contact person. Examples: a) CCNR contracts directly to a contractor (Vale CCNR contact person accountability). b) CCNR Vale blanket purchase order (BPO s) (Vale CCNR contact person accountability) c) CCNR Ont. Ops. PMO directly manages the contractor (Vale CCNR PMO contact person accountability) d) Vale Corp (VTSL), PMO (i.e. AER projects (Vale Corp PMO contact person accountability, can also be EPCM firm i.e. SNC Lavalin, HATCH etc.) e) 26) Q: Do employees that are used for back-up rescue plan need to be recorded on the rescue plan sheet with the primary rescue team? A: Yes, their names also need to be recorded on the form (they can be identified with a BP beside their name, and they are also required to lock out, just like the primary rescue team at the start of the confined space work, this ensures that if they are needed, no time is waited having to lock out, so that a backup team member can enter the confined space to assist in rescue. 27) Q: If a complete test is done and recorded on a rescue test form, does a new form need to be generated each time for the same confined space and is the exact same as tested and recorded rescue plan)? Ontario Operations Confined Space program FAQ s Pg. 9 of 10

10 A: No, a copy of the record of the completed test is to be kept with the entry documentation package (for auditing purposes). Note: If the rescue plan was tested and recorded, and all components of the rescue plan are the same, then only a review with all members of the entry team and rescue team, including back-up rescue personnel is required, and their sign-off on the specific entry and rescue plan training record is to attest to the fact that the entry and rescue plan has been reviewed with all members of this confined space work. 28) Q: Regarding the confined space entry permit number, what defined the permit numbers? A: The Vale Confined Space program does not dictate how the permit number sequence should work, this is determined by the mine or plant. Example: a) Coleman 3220 Loading Pocket, the permit number could be the vessel number, date, shift: 10ML27_ _S1 or 10ML27_ _S2 (1 st or 2 nd shift). b) Some plants at the Smelter Complex have a series of sequential numbers for the confined Spaces. 29) Q: Do we notify Vale 1st Aid at mines or plants of our entry into a confined space? A: No, we do not notify or inform Vale 1 st Aid at our mines or plants of our entry into a confined space, this is not part of the Vale or part of our security department protocols. 30) Q: What training is required for a plant operator to be able to enter a confined space and isolate (example: a high pressure steam line) with a contractor confined space team in place? A: Vale Confined Space program Awareness Level training, and Entry Level training (this is the general training required), also must be trained in the specific entry plan, review of the confined space work risk assessment, coordination document, and review of the rescue plan and be signed off on the site specific entry and rescue plan training form, to be compliant with the Vale and meet the intent of O.Reg.632/05 section 8, 9, and 9.1 Ontario Operations Confined Space program FAQ s 10 Pg. 10 of