Title: Permitted Confined Space Entry. Environmental, Health, and Safety

Transcription

1 Environmental, Health, and No.: BCF Page: 1 of 24 RECORD OF REVISION Date Revision Details of Change Number 11/01/14 5 was changed to allow the option to use of 120 volt lights with a GFCI during confined space entries Temporary Lighting Temporary lighting shall be provided by one of the following means: In hazardous atmospheres intrinsically safe lights In damp conditions approved Low Voltage (12 volt) lights protected by a ground fault interrupter If neither of the above conditions exist then 120 volt lights protected by a ground-fault circuit interrupter can be used

2 Environmental, Health, and No.: BCF Page: 2 of PURPOSE To establish standard work practices and procedures for safely entering and working within Permitted Confined Spaces by BASF Corporation ("BC") personnel, Contractor Employee, and Contracted Employee. 2. DEFINITIONS 2.1. Attendant An individual stationed outside one or more Permitted Confined Space(s) who monitors the Authorized Entrants and who performs all Attendants duties specified in Section 7.7 of this procedure Authorized Entrant An individual authorized by the site s program to enter a Permitted Confined Space Authorized Designee Another person from the Operating/ Owning Dept., other than the Entry Supervisor, that has been authorized by that Depts. Operating/Service Manager to issue Confined Space Permits Barricade The use of a cover, panel, etc., which can only be accessed with the use of tools, to restrict unauthorized entry into a Permitted Confined Space that does not have an Attendant stationed at the entry. The use of signs may be unnecessary if all affected personnel are informed about such spaces and know that they are not to be opened and entered without following the requirements of the site s Permitted Confined Space Entry Program Barrier The use of red tape, chain, scaffolding, etc., with signs, to restrict unauthorized or unknowing entry into a Permitted Confined Space that does not have an Attendant stationed at the entry. A sign must be used with a Barrier Bodily Entered A space that is large enough to accommodate the entire bodily Entry of a person Bump Test (Function Test) Check of the meter using a known concentration of test gas for oxygen, flammable gas/vapor and toxic gas/vapor/mist of concern to verify that the meter reads the correct concentration Confined Space

3 Environmental, Health, and No.: BCF Page: 3 of 24 Spaces which can be Bodily Entered and have limited or restricted means of egress and are not designed for continuous occupancy Permitted Confined Spaces Spaces which can be Bodily Entered and have limited or restricted means of egress and are not designed for continuous occupancy, and have one or more of the following characteristics: Contain or have the potential to contain a Hazardous Atmosphere (such as having held flammable, explosive, acidic, caustic, toxic materials) or where oxygen enriched or deficient atmospheres or noxious odors may exist. Contain a material that has the potential for engulfing an Authorized Entrant. Have an internal configuration such that an Authorized Entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section. Contain any other recognized serious safety or health hazards; such as ionizing radiation, electric shock, temperature, or moving parts. Is considered a process or storage tank/vessel. Such spaces include, but are not limited to: tanks, tank trucks, tank cars, duct work, vats, tubs, hoppers, bins, boilers, kilns, cooling towers, stacks, chimneys, sewers, trenches, pits, manholes, elevated, or other similar equipment/structures. This may also include structures greater than four feet in height, or excavation that are greater than four feet in depth that has potential to accumulate heavy gases. NOTE: Temporary ladders and temporary, movable, spiral, or articulated stairs may be considered a limited or restricted means of egress. Fixed industrial stairs or ladder will be considered a limited or restricted means of egress when the conditions or physical characteristics of the space, in light of the hazards present in it, would interfere with the Authorized Entrant s ability to exit or be rescued in a hazardous situation Confined Space Permit Permit issued for a specified Permitted Confined Space documenting that the space has been properly cleared, cleaned, isolated, tested, prepared (i.e. ventilation installed) and is ready for entry. Documentation of testing, 2-hr. readings for continuous monitoring and entry time In/Out is recorded on the permit. Only personnel that have been trained qualified and authorized can issue or modify Confined Space Permits or Safe Work Permit for Confined Space on behalf of the Operating/Owning Department. NOTE: The Confined Space Permit does not authorize work activity in the Permitted Confined Space. A Safe Work Permit must be issued for each work activities that will take place in a Permitted Confined Space.

4 Environmental, Health, and No.: BCF Page: 4 of Contractor/Agency A company which will be either placing or bringing Contractor(s), Temporary Employee(s) or Contractor Employee(s) onto a BC site Contracted Employee (i.e. contractors brought in without their company supervision on site) A Contracted Employee is an individual or group of individuals for whom BC provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed Contractor Employee (i.e. Nestor, daily and shutdown contractors with supervision on site) An individual engaged by or through a third party to perform services principally for the third party Entry The action by which a person intentionally passes through an opening into a Permitted Confined Space and is considered to have occurred as soon as any part of the entrant s body breaks the plane of an opening into the space Entry Supervisor The person from the Operating/ Owning unit that is responsible for authorizing the Confined Space Permit and determining: If acceptable Entry conditions are present at the Permitted Confined Space, If termination of Entry activities is required. NOTE: An Entry Supervisor also may serve as an Attendant or as an Authorized Entrant, as long as that person is trained and equipped as required for each role he or she fills. Also, the duties of Entry Supervisor may be passed from one individual to another during the course of an Entry operation Environmental Temperature Atmospheric conditions that could present heat or cold stress situations Explosive Atmosphere A range of concentrations of gases, dusts, or fibers with air that can support ignition. The range of concentrations is material-specific. The range for a material can vary based on pressure, temperature, and oxygen content Hazardous Atmosphere An atmosphere that may expose employees to the risk of death, incapacitation, and impairment of ability to self rescue, injury or acute illness from one or more of the following causes: Flammable gas, vapor or mist in any detectable concentration using a calibrated combustible gas meter operating in the percent range of sensitivity. Airborne oxygen concentration below 19.5% or above 21.0%.

5 Environmental, Health, and No.: BCF Page: 5 of 24 Atmospheric concentration of any substance for which a dose or permissible exposure limit is published in 29 CFR 1910 Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, and which could result in the employee exposure in excess of its dose, threshold limit value (TLV), or permissible exposure limit (PEL). Any other atmospheric condition that is immediately dangerous to life or health. Airborne combustible dust at a concentration that meets or exceeds its lower flammable limit. This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less. NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, refer to Attachment #2, BASF Exposure Assessment Occupational Exposure Limit Reference Value Determination in establishing acceptable atmospheric conditions Immediately Dangerous to Life or Health ( IDLH ) Any conditions that pose an immediate or delayed threat to life or that would cause irreversible adverse health interfere with an individual s ability to escape unaided from a Permitted Confined Space. Included in this definition is an oxygen deficient atmosphere containing less than 19.5 percent oxygen by volume. (Refer to the NIOSH Pocket Guide to Chemical Hazards or MSDS for IDLH limits for toxic chemicals) Low Voltage For the intent of this, Low Voltage is referring to AC power supply of 12 volts or less Non-Entry Rescue The ability to facilitate rescue by means of Retrieval Systems or other methods without entering the Permitted Confined Space Operating/Owning Department The BASF unit or department that operates or is responsible for the daily operation of the process, area, or facility where work is being conducted Prior Contents Includes the previous chemical contents in the equipment before clearing and any chemical agents (i.e. soda blasting, soaps, etc) used for cleaning Rescue Team or Rescue Team Member Personnel designated by BASF to enter Permitted Confined Spaces and perform rescue operations Retrieval System The equipment used for Non-Entry Rescue of persons from a Permitted Confined Space. This includes retrieval line, full body harness, lifting devices or fixed point Re-Validate a Permit

6 Environmental, Health, and No.: BCF Page: 6 of 24 To review the conditions for work specified on the permit, ensure that they are still met, and secure the appropriate signatures and approvals Testing The process by which the hazards that may confront Authorized Entrants of a Permitted Confined Space are identified and evaluated. Monitoring includes specifying the tests and the order in which they are to be performed in the Permitted Confined Space Vertical Entry An Entry straight down from top of the Permitted Confined Space to the working surface. 3. SCOPE This procedure applies to the. 4. PREPARATION 4.1. Evaluation Each Operating/ Owning Department shall evaluate the workplace to determine if any spaces are Permitted Confined Spaces as defined in Section 2.9. The evaluation need not be documented; however, the location must be able to explain how the evaluation was conducted and describe the results Identification Each Operating/ Owning Department shall inform exposed personnel, by posting danger signs or by other equally effective means, of the existence and location of the danger posed by the location s Permitted Confined Spaces. Alternative methods, such as additional training, may be used where they are truly effective in warning all personnel who could reasonably be expected to enter the space Authorization No person shall enter any Permitted Confined Space, which is within the scope of this procedure without prior written approval from an authorized permit writer. Effective means shall be implemented to prevent unauthorized Entry. These measures may include but are not limited to: Permanent closure and sealing Use of physical barriers (signs must be used) Bolting and locking the space The above measures may be supplemented by training personnel and posting danger signs or labels Permitted Confined Space Cleaning Prior to Entry, all Permitted Confined Spaces that may have contained a hazardous material or atmosphere must be cleaned of prior contents by washing, steaming, or purging with nitrogen, followed by an air purge.

7 Environmental, Health, and No.: BCF Page: 7 of Isolation Prior to Entry, Permitted Confined Spaces must be isolated from adjoining piping including all process, drains, overflow and utility connections in order to ensure that liquids, solids, vapors, or gases do not enter the Permitted Confined Space. All isolation points shall be as close to the vessel as possible. The method of isolation must meet one the following criteria: A pancake or spectacle blind that is bolted between the process or utility piping flange and the Permitted Confined Space nozzle flange. NOTE: Pancakes and blinds used for a primary isolating device, or do not have a method to avoid pressure build up (by use of a bleed valve or air gap), must be rated to match size and pressure rating of the line or equipment. An air gap (12 or greater) created by removing a spool piece or miss-aligning the process or utility piping and the Permitted Confined Space nozzle so as to prevent liquids or vapors from entering the Permitted Confined Space. A double block and bleed where the two block valves are closed; the bleed is open and locks/isolation tags are applied and are in accordance with the sketches (Attachment 1). The block valves in a line to jackets, coils, reboilers and similar items which in themselves are not open to the area in which work is to be performed are closed and tagout applied. The only exception would be the use of external cooling water on vessel jackets or coils during hot weather. If the Permitted Confined Space contains internal power driven mechanisms, such as agitators, all switch gear and other power sources shall be locked, tagged and tried in accordance with BCF , Control of Hazardous Energy Sources procedure. Entry Supervisor must sign onto the Master Isolation Procedure to ensure the isolation for is maintained while a Confined Space Permit is open. All radioactive device shutters must be locked out to prevent exposure during Entry (See IH #3) Testing Entrance for Atmosphere Testing (if Entry is necessarily to conduct Testing) Initial Authorized Entrants that enter a Permitted Confined Space for the purpose of conducting and/or confirming atmospheric tests must wear appropriate PPE as well as self-contained breathing apparatus (SCBA) or airline respirator with an emergency egress bottle inside the Permitted Confined Space until the atmosphere has been verified to meet acceptable

8 Environmental, Health, and No.: BCF Page: 8 of 24 Entry conditions. At that time, respiratory protection may be downgraded as specified by the Entry Supervisor Order of Atmospheric Testing Atmospheric Testing must be conducted in the following order: Oxygen Flammable/Combustibles Toxic Substances/Particulates Radiation Testing Any space containing a radioactive device must be verified and tagged with a Nuclear Source Isolation by the RSO or the designee prior to Entry. (See BCF Radiation Protection Program) Location of Testing Initial and periodic Testing shall be conducted to the extent feasible throughout the space and at various heights and lengths. NOTE: As well as determining absence of toxics checking at various levels is done to account for oxygen being displaced by gases heavier or lighter than air Instrumentation Maintenance and Calibration Combustion meters shall be calibrated per manufacturers recommendations and be bump /function tested prior to each use. All other atmospheric Testing instrumentation will be maintained and bump /function tested according to manufacturer s specifications Frequency of Atmospheric Testing A. Initial Testing Testing of the Permitted Confined Space to determine that acceptable conditions exist before Entry is authorized to begin and shall include testing for oxygen, LEL, toxics and other potential hazards that can be tested for (i.e. ph, dust, etc) NOTE: Do not list prior contents in this section if test methods are not available. Communicate the exposure limits in the Hazardous Communication section. All initial Monitoring for atmospheric conditions shall be conducted as close to the first Authorized Entry time as possible and at no time shall it exceed two hours prior to entry. Initial Testing will be recorded on all subsequent Confined Space Permits with the initials of the person that preformed the testing and date and time the testing was conducted.

9 Environmental, Health, and No.: BCF Page: 9 of 24 If the atmospheric tests indicate unacceptable Entry conditions, then additional forced ventilation and/or PPE must be specified for the Authorized Entrants (See G for requirements for record retention). B. Periodic and Continuous Testing Continuous monitoring for LEL/O2 is required during Entry activities to detect outside influences that may affect the atmospheric conditions of the space. NOTE: In situations where continuous monitoring is unreliable, such as during hydro-blasting, pre-determined periodic (not to exceed two hours) monitoring shall be conducted. When this exception to continuous monitoring is used the appropriate box on the Safe Work Permit must be checked. If the space is unoccupied due to work breaks or delays of more than two hours, Monitoring shall be performed as close to (re)entry time as possible and at no time shall it exceed two hours prior to entry. Permitted Confined Spaces that contain toxic gases/vapors/mists shall be evaluated to determine the appropriate sampling frequency that will accurately assess the atmospheric exposure. C. Re-Testing Re-Testing for oxygen, flammable gases/vapors and toxics shall be conducted whenever there is a change in work conditions, isolation, or when block emergency or seek shelter horns are sounded in the Unit due to a release affecting the work Entry Conditions A. Oxygen (Acceptable Levels 19.5% to 21%) Where the level of oxygen is between 19.5% and 21% and the integrity of the atmosphere can be maintained, Entry may be made without respiratory protection provided the provisions for flammables/combustibles and toxins are met. Atmospheres found to have enriched oxygen supplies (greater than 21%) require appropriate action to reduce the level to 21%. Where the level of oxygen cannot be maintained above 19.5%, an airline respirator with emergency egress bottle (5-minute escape pak) or self-contained breathing apparatus ( SCBA ) shall be used. No entries shall be made if the oxygen level is 16% or less or greater than 21% without the written approval of the area Senior Production Manager/Director and EHS Team Leader or their designees except for Emergency rescue operations by qualified personnel.

10 Environmental, Health, and No.: BCF Page: 10 of 24 B. IDLH Atmospheres The following are the requirements when Entry is made into an IDLH atmosphere or into a space that could quickly develop an IDLH atmosphere (if ventilation fails or for other reasons): Rescue personnel standing by at the Permitted Confined Space. The rescue plan will determine the quantity, type and location of supplied breathing air. C. Flammable/Combustible Gases and Vapors Permitted Confined Spaces shall not be entered if any detectable flammable/combustible gases and vapors are determined to be present by a combustible gas meter operating in the percent range of sensitivity. D. Generation of Flammable/Combustible Gases and Vapors If work activities to be performed in a Permitted Confined Space are expected to generate flammable gases/vapors, continuous ventilation and representative-continuous monitoring are required. If flammable gases/vapors are detected, immediate corrective action must be taken to reduce their concentrations; e.g., increased ventilation and reduced rate of vapor generation. Appropriate PPE is required to insure Authorized Entrants safety. (Airline respirator or SCBA). If flammable gases/vapors are detected at 5% of the Explosive Atmosphere work must cease and the Authorized Entrants must exit the space immediately and immediate corrective action must be taken to reduce concentrations (e.g., increased ventilation, reduced rate of vapor generation, etc.). See G below for requirements for record retention requirements. NOTE: Detection of flammable gases/vapors at 5% of the Explosive Atmosphere may exceed the allowable PEL or TLV and require appropriate PPE. E. Toxic Substances The level of the toxic substance in the Permitted Confined Space should be maintained below the appropriate allowable level at all times during Entry. In those situations where the concentrations cannot be maintained below the allowable limit the appropriate PPE (e.g. respiratory protection) shall be used by all personnel within the Permitted Confined Space in accordance with the Unit/Site Respiratory Protection Program. Appropriate skin protection is required to prevent exposure to chemicals which are skin absorbed or corrosive.

11 Environmental, Health, and No.: BCF Page: 11 of 24 F. Particulates Permitted Confined Spaces containing airborne dust at a concentration that obscures vision at a distance of five feet or less shall not be entered. G. Documentation The following must be documented on the Entry permit: Confirmations of the Monitoring instruments bump tests. Permitted Confined Space atmosphere monitoring results, including the time of the tests and the tester's initials. The continuous monitoring for LEL/O2 shall be documented every 2- hours. Results of air monitoring that indicate the atmosphere the employee actually entered, including oxygen concentration below 19.5%, and flammable gases/vapors and toxic materials above zero ppm. The results are considered IH exposure records subject to recordkeeping requirements. After Closure the permit must be returned to the EHS Specialist for proper record retention Ventilation of Permitted Confined Spaces Confined spaces must be appropriately ventilated ( % O2, 0% LEL) prior to Entry consistent with the requirements listed below Ventilation devices may be air movers or blowers. Air Movers used as ventilation device: o Must be properly grounded, secured and positioned such that maximum air is being pulled through the vessel (i.e. sealed). o Must be tagged with a Danger or Information Tag to prevent removal or shutdown Permitted Confined Spaces with adequate natural ventilation or that have large open side(s) such as cooling towers, fan shrouds, pits, diked areas, etc are considered to be appropriately ventilated The plant air system, which is backed up by nitrogen, may not be used to ventilate Confined Spaces. An air compressor that introduces air into the must meet CO (Carbon Monoxide) requirements. This requires a CO monitor and ability to shutdown the compressor when CO at or above 10 ppm is detected. 5. COMPLETING CONFINED SPACE PERMIT INFORMATION All information shall be printed legibly. The permit shall be completed as follows:

12 Environmental, Health, and No.: BCF Page: 12 of Confined Space Permit Process A Confined Space Permit (Attachment 3) shall be completed by the Entry Supervisor of the Operating/ Owning Department where the Entry is to be made. The Confined Space Permit is written for the space to indicate the conditions in the space meet all requirements for entry. The Attendant(s) will accept the permit. Work activities in the space will be permitted by issuing Safe Work Permit(s) that accompanies the Confined Space Permit Entries into equipment or a vessel with work activity resulting in the Entrants entering and exiting two or more openings (manway) can be permitted with one Confined Space Permit as long as there is an Attendant and combustible gas meter stationed at each entry point. One Attendant will have the responsibility of documenting the entry, exit and 2-hour LEL/O2 readings for the openings. The other Attendants must have a means to communicate the activities to the Attendant with the Confined Space Permit. NOTE: If the work activity and/or companies are different then a separate Confined Space Permit may be required if the companies do not agree to use the same Confined Spare Permit. Due to different work activities in the space separate Safe Work Permits will be required for each work activity and/or company The Confined Space Permit remains open through-out the designated time period on the permit (not to exceed 16 hours from Start Time). As work activities are completed the Permits (Confined Space and Safe Work) are returned to the Entry Supervisor or an Authorized Designee The Safe Work Permit is closed-out. The Confined Space Permit is retained to accompany the next Safe Work Permit issued for work activities in the space General Information Section Unit/Department: Unit or department where permit is being issued. Location/Equipment: Area of the unit where equipment is located and description and/or identifier (e.g. vessel number) of equipment being entered. Authorized Duration of Permit Shall not exceed 16 hours from Start Time. Start Time / End Time: Must use military time or indication of A.M. or P.M. Is accompanied with a properly completed Safe Work Permit Pre-Entry Checklist Section All boxes must be appropriately checked.

13 Environmental, Health, and No.: BCF Page: 13 of Hazard Communication Section The section is located on the back of the hard copy of the permit and must be completed or indicate an information sheet communicating the health hazards and symptoms/consequences of exposure is attached to the hard copy of the permit Testing Section See section Entry Supervisor Section Prepares the Confined Space Permit and shall sign their name as Entry Supervisor #1. Signs on the Master Isolation Procedure (MIP) to prevent changes in the isolation during periods when no work in taking place in the Permitted Confined Space. Entry Supervisor #2-4: In the event the Entry Supervisor duties are relinquished the on-coming Entry Supervisor will sign as Supervisor #2, 3, or 4 and document the time turn-over occurred. The active Entry Supervisor will be notified when a Safe Work Permit is issued for work in the Permitted Confined Space or any changes are made to the Confined Space Permit (additional Attendants added, Permit is closed, etc.) Attendant Section The Attendant(s) will be informed of their duties by the Entry Supervisor and sign on the permit. If more than one Attendant is needed to monitor the Entry, they will all sign and record Time Accepted on the Confined Space Permit. They may swap from one Attendant to the other as long as one of the Attendants is always at the Entry Point monitoring the well-being of the Entrants. If additional Attendant(s) are added to the Confined Space Permit for subsequent Safe Work Permits the Attendant(s) will sign and enter the Time Accepted on the Confined Space Permit. When the Confined Space Permit is returned to the Entry Supervisor or Authorized Designee the Attendant(s) will record Time Returned on the permit. The Attendant that last held the responsibility will return the permit Confined Space Permit Returned The Confined Space Permit is returned to the Entry Supervisor or Authorized Designee with the Safe Work Permit and review of the debriefing comments is conducted. An Attendant and Entry Supervisor or Authorized Designee must verify that all Entrants are out of the space and have initialed off the Confined Space Permit, tools and equipment are out to the space, and that a barrier and sign have been placed across the space.

14 Environmental, Health, and No.: BCF Page: 14 of 24 The Attendant(s) enters time Returned on the Confined Space Permit. The permit remains open if necessary to accommodate additional work that may take place (within 16 hrs. or the Start Time) in the space. NOTE: If the work break is 2-hours or longer, the periodic testing must be conducted when the next Safe Work Permit is issued BASF Permit Close-Out and Debrief Section Any issues affecting safe entry conditions will be noted in the debriefing section of the Confined Space Permit by the Attendant and brought to the attention of the Entry Supervisor or a member of the Operating/ Owning Department prior to work activities continuing. A debrief of the Entrants by the Attendant will be conducted at the conclusion of each work activity permitted by a Safe Work Permit. Comments will be noted in the debriefing section of the Confined Space Entry Permit. The Attendant or member of the Work Crew will return the Confined Space Permit (with the appropriate Safe Work Permit) to the Entry Supervisor or Authorized Designee who will accept the permit, review debriefing comments on the entry activities, enter the close-out time and sign Close by. Any comments about the permit or any other aspect pertaining to the process may be noted in the debriefing section. Any issues with the Entry must be resolved before another Safe Work Permit is issued for work in the Permitted Confined Space. 6. CONFINED SPACE PERMIT WORK INSTRUCTIONS Prior to authorization of work, the Entry Supervisor, Attendant, Safe Work Permit Acceptor and Entry personnel or their representative, involved in the Entry shall: personally inspect the Permitted Confined Space preparation, review prior contents and potential hazards review precautions taken, review personal protective equipment to be used, review procedures to be followed and instructions for all employees involved in the Entry, provide an opportunity for the Authorized Entrant(s) or their representative to observe pre-entry and periodic Testing of the atmosphere, and re-evaluate the Permitted Confined Space in the presence of any Authorized Entrant or their representative upon requests by either if they have reason to believe that the initial evaluation may not have been adequate The completed Confined Space and Safe Work Permits shall be reviewed with all Authorized Entrants or their representative prior to Entry (if reviewed with representative, the representative is responsible for reviewing with ALL other Entrants).

15 Environmental, Health, and No.: BCF Page: 15 of 24 Each Authorized Entrant will print their name in the Entrant Log of the Confined Space Permit. By printing their names on the Entrant Log it acknowledges they have been informed of: the hazards, control measures, monitoring conducted for the Entry and opportunity to witness the monitoring, duty to only perform the work specified on the Safe Work Permit, alert the Attendant of any signs of danger or prohibited conditions, and to exit the Permitted Confined Space as quickly as possible when conditions require. NOTE: All personnel working under the Safe Work Permit for the Permitted Confined Space must initial WCAF On Job/ Off Job Personnel Changes Any personnel changes concerning Attendants and Authorized Entrants shall be approved by the Entry Supervisor and documented on the Confined Space Permit. If a change in Entry supervision occurs, the out-going Entry Supervisor signs off the MIP and on-coming Entry Supervisor signs on the MIP. Within 2-hours of the change the on-coming Entry Supervisor must visit the Permitted Confined Spaces they have assumed duties for to inform representative personnel involved in the Entry of the change in supervision and Sign and record the time of the change in supervision on the Confined Space Permit Duration NOTE: If a change is supervision is anticipated before the end of the working crew s shift the initial Entry Supervisor will communicate this when issuing the permit. After supervision has changed the on-coming Entry Supervisor must complete the requirements above within 2-hours of the change in supervision A Confined Space Permit shall be valid for up to16 hours from Start Time. Safe Work Permits issued for the Permitted Confined Space shall follow requirements of the Safe Work, BCF Confined Space Permits are void and must be revalidated and retested if work stops for more than two hours, changes in the isolation occur, or for any emergency that occurs which affects the Entry or conditions in the Permitted Confined Space Canceled Confined Space Permits Upon completion or discontinuation of the Entry, the canceled Confined Space Permits shall be returned to the Entry Supervisor or Authorized Designee.

16 Environmental, Health, and No.: BCF Page: 16 of Completed Confined Space Permits and all associated Safe Work Permits shall be reviewed to determine the effectiveness of the program Any problems encountered during an Entry shall be noted on the Confined Space Permit and/or the Safe Work Permit and reported to EHS. 7. PERMITTED CONFINED SPACE ENTRY GENERAL REQUIREMENTS 7.1. Permitted Confined Space Evaluation Each Operating/ Owning Dept. will have a process that will identify each space, its hazards, and safe guards for Entry Communication Communications (visual, verbal, audio or signal line) shall be maintained between Authorized Entrants and the Attendant. The method of communication shall be documented on the permit Retrieval System A full body harness shall be used whenever an Authorized Entrant enters a Permitted Confined Space An evaluation is required for each Entry to determine if a retrieval line will be attached to the Authorized Entrant(s). Authorized Entrants will use a retrieval line attached to a mechanical Retrieval System or fixed point outside the Permitted C Confined Space to facilitate Non-Entry Rescue, unless a retrieval line would increase the overall risk of Entry or would not contribute to the rescue of the Authorized Entrant A mechanical device shall be set-up for vertical type Permitted Confined Spaces more than 5 feet deep Entry Supervisor Duties During a, the Entry Supervisor shall: Perform the initial Testing or verify that all Testing has been conducted and that the isolation and conditions of the Permitted Confined Space have not changed since the initial Testing, Signs on the MIP Ensure that the permit is located at the work site,

17 Environmental, Health, and No.: BCF Page: 17 of Ensure that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing Entry to begin, Provide the all personnel, or their representative, involved with Entry an opportunity to observe any monitoring or Testing of permit spaces. If the any personnel request to observe the Testing/monitoring, they will initial next to the tester in the periodic or retest section of the permit, Remove any unauthorized individuals who enter or attempt to enter the Permitted Confined Space during Entry operation, Terminate the Entry and cancel the permit as required The Entry Supervisor or Authorized Designee that closes out the Confined Space Permit has the responsibility to: Verify that all personnel have exited the Permitted Confined Space, Ensure that all equipment is left in a safe condition, Ensure that barrier and signs are in place to prevent unauthorized Entry into the Permitted Confined Space Debrief the Attendant or Authorized Entrants at the conclusion of the Entry operations regarding the Permitted Confined Space program that was followed and regarding any hazards confronted or created in the Permitted Confined Space during Entry operations, Ensure housekeeping is maintained Authorized Entrant Duties During a, the Authorized Entrants shall: Know the hazards that may be faced during Entry, including information on the mode, signs or symptoms, and consequences of the exposure; Inspect and properly use all required equipment (e.g. safety harness); Communicate with the Attendant as necessary to enable the Attendant to monitor Authorized Entrant status; Alert the Attendant whenever: The Authorized Entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or The Authorized Entrant detects a prohibited condition;

18 Environmental, Health, and No.: BCF Page: 18 of Exit from the permit space as quickly as possible whenever: An order to evacuate is given by the Attendant or the Entry Supervisor, The Authorized Entrant recognizes any warning sign or symptom of exposure to a dangerous situation, The Authorized Entrant detects a prohibited condition, or An emergency alarm is activated that affects the Entry Attendant Duties When personnel are working within a Permitted Confined Space, a trained Attendant shall be immediately outside the space to perform their duties as described below. The Attendant may monitor more than one Permitted Confined Space provided that the monitoring of these spaces is performed without compromising the safety of any Authorized Entrant in any of the Permitted Confined Spaces monitored by the Attendant Know the hazards that may be faced during Entry, including information on the mode, signs or symptoms, and consequences of the exposure to Hazardous Atmospheres Be aware of possible behavioral effects of exposure to Hazardous Atmospheres in Authorized Entrants Continuously maintain an accurate count of Authorized Entrants in the Permitted Confined Space, and ensure that the means to identify Authorized Entrants accurately identifies who is in the space (record times Authorized Entrants are in and out of space) Remain outside the permit space during Entry until relieved by another Attendant. The relieving Attendant will indicate the time of relief on the permit Communicate with Authorized Entrants as necessary to monitor Authorized Entrant status and to alert Authorized Entrants of the need to evacuate the space Monitor activities inside and outside the space to determine if it is safe for Authorized Entrants to remain in the space, and order the Authorized Entrants to evacuate the permit space immediately under any of the following conditions: If the Attendant detects a prohibited condition; If the Attendant detects the behavioral effects of hazard exposure in an Authorized Entrant; If the Attendant detects a situation outside the space that could endanger the Authorized Entrants;

19 Environmental, Health, and No.: BCF Page: 19 of 24 If the Attendant cannot effectively and safely perform all the required duties Be knowledgeable in the use and limitations of air monitoring instruments Document LEL/O2 monitor readings on the Confined Space Permit every 2 hours, Summon rescue and other emergency services by notifying the control room Ensure that electrical or spark producing equipment used during the Entry is shut off Take the following actions when unauthorized persons approach or enter a permit space while Entry is underway: Warn the unauthorized persons that they must stay away from the permit space; Advise the unauthorized person that they must exit immediately if they have entered the permit space; and Inform the Authorized Entrants and the Entry Supervisor if unauthorized persons have entered the permit space Perform no duties that might interfere with the Attendant s primary duty to monitor and protect the Authorized Entrants At conclusion of each permitted work activity note comments in debriefing section of Confined Space Permit associated to the entry activities Ensure that Barriers and Signs are in place to prevent unauthorized entry when space is unattended Welding and Burning in a Permitted Confined Space Ventilation measurements shall be taken using a velocity flow meter and shall meet the requirements of at least 2000 cubic feet per minute (cfm) for each welder If adequate ventilation cannot be obtained air-line respirators or SCBAs shall be used See BCF Hexavalent Chromium Compliance and BCF Metal Welding, Thermal Cutting, Grinding Respiratory Protection and Ventilation requirements.

20 Environmental, Health, and No.: BCF Page: 20 of Gas cylinders used for welding and welding machines must be located outside the Permitted Confined Space. NOTE: Argon is a heavy gas and may accumulate in lower portions of the space. Ventilation and monitoring should be considered to eliminate the hazard Whenever gas welding or cutting inside a Permitted Confined Space is suspended for 30 minutes or more, or in the event of an emergency affecting the Entry: The torch valves and hoses shall be removed from the Permitted Confined Space when feasible, the electrodes must be removed. The gas supply to the torch positively shut off somewhere outside of the Permitted Confined Space and hoses disconnected When arc welding inside a Permitted Confined Space is suspended for 30 minutes or more, or in the event of an emergency that affects the Entry: all electrodes must be removed from the holders, and the holders located such that accidental contact cannot occur, and the welding machine must be disconnected from the power source if electrical, or engine shut-off if motorized Equipment Use Electrical All electrical equipment used inside a Permitted Confined Space shall be: Consistent with the area classification or permitted as a Low Energy Hot Work, In good conditions, Grounded or double insulated. A ground fault circuit interrupter shall be used for all electrical equipment and located as close to the power source as possible (always outside of the Permitted Confined Space) Temporary Lighting Temporary lighting shall be provided by one of the following means: In hazardous atmospheres intrinsically safe lights In damp conditions approved Low Voltage (12 volt) lights protected by a ground fault interrupter If neither of the above conditions exist then 120 volt lights protected by a ground-fault circuit interrupter can be used Voltage regulator devices must be located outside of the Permitted Confined Space. Temporary lighting shall be equipped with guards to prevent contact with the bulb.

21 Environmental, Health, and No.: BCF Page: 21 of Battery Powered Equipment All battery powered equipment shall be consistent with the area classification or permitted as a Low Energy Hot Work Pneumatic Tools Anytime pneumatic tools connected to an air compressor and used within a Permitted Confined Space must meet CO (Carbon Monoxide) requirements. This requires a CO monitor and ability to shutdown the compressor when CO is detected at or above 10 ppm Rescue A Retrieval System shall be used whenever an Authorized Entrant enters a Permitted Confined Space unless the retrieval equipment would increase the overall risk of Entry or would not contribute to the rescue of the entrant. The Retrieval System shall consist of a chest or full body harness with a retrieval line in good condition attached to the entrant at any point which presents a profile small enough for the successful removal of the entrant to a fixed point or mechanical device outside the Permitted Confined Space. A chest or full body harness shall be donned before entering any Permitted Confined Space where Entry is through a manway or other restricted opening. A mechanical device shall be used for vertical type Permitted Confined Spaces more than five feet deep. Rescue Services shall be available either on-site or through a 3 rd party which would provide appropriate response times and training for rescue workers. Non-Entry rescue shall be used whenever possible. When non-entry rescue is not possible due to the space configuration or obstructions, any rescue equipment which would be used in an Entry rescue shall be readily available, at or near the area, to reduce the response time. Any Entry into an atmosphere which may be hazardous to retrieve a downed person shall require the use of an air-line respirator with an emergency egress bottle or a SCBA. NOTE: Rescue requirement details can be found in the s Rescue. Link to BCF a Rescue Requirements for Permitted Confined Spaces 8. TRAINING 8.1. Persons Directly Involved in Entry Operations: Permit Issuers, Authorized Entrants, Attendants, testers and other personnel directly involved in shall receive training on: o how to recognize the applicability of Entry situations, o the requirements for issuing a permit,

22 Environmental, Health, and No.: BCF Page: 22 of 24 o the necessary means to safeguard against the hazards posed during these activities, o their specific roles/responsibilities under the program. Training shall be delivered in accordance with the EHS curriculum assignment process. Retraining of an employee is required whenever: o Deviations or inadequacies in an employee s performance of an applicable procedure indicate that lack of knowledge is a cause. o An applicable procedure has been changed Persons Not Directly Involved in Entry Operations: Personnel not directly involved in will receive awareness training for this and other safe work practices in accordance with the EHS curriculum assignment process Documentation for BASF and Contracted Employees. Training will be documented including: o each Trainee's name, o date(s) of attendance, o Means to verify understanding o Learning Objectives for the course o Documentation shall be maintained according to BC037, Record Retention Policy and the applicable record retention schedule Contractor Employees Refer to BC Contractor EHS Qualification and Oversight for requirements. 9. RESPONSIBILITIES 9.1. Site Manager The Site Manager has responsibility for ensuring the implementation of this procedure Production Execution Manager, Site and Area Logistics Managers Has the responsibility for: ensuring this procedure is followed, designating, in writing, DOT/DST members who have been trained and approved to be an Entry Supervisor to issue Confined Space Permits Team Leader Has primary responsibility for: the initiation, re-issuance, audit, administration, and/or interpretation of this procedure.

23 Environmental, Health, and No.: BCF Page: 23 of Senior Production Manager/Director ensuring the annual Management Review (Section 10) is conducted. 9.5 Freeport BASF Employees and Contract Employees Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure. 10. PERMITTED CONFINED SPACE MANAGEMENT SYSTEM REVIEW A review of the effectiveness of practices shall be conducted at least annually to ensure that the management system is properly implemented and the elements adequately control Permitted Confined Space activities. As a minimum, the following elements of the management system shall be included in the review: Review the site procedure and permit to ensure all currently required elements are included. A review of all incidents and other nonconformance reports involving Permitted Confined Space Entry activities that have occurred since the last management system annual review. The review should verify root causes have been properly identified and appropriate corrective actions have been implemented. Inspection of at least one job-in-progress to verify site practices comply with the site procedure. Verification of the training personnel involved in this job-in-progress have received. Interviews with a representative number of Permit Issuers, persons performing Permitted Confined Space Entry, and other affected employees, including Contractor and Contracted Employees where applicable, to verify they understand their role/responsibility. A review of applicable equipment and instrument maintenance and calibration records. The review shall be documented. For an example, see the Management Review Checklist for Permitted Confined Space program in Attachment RELATED DOCUMENTS BC Confined Space Entry 29 CFR BCF Safe Work BCF Personnel Protective Equipment BCF Respiratory Protection IH 3 Radiation Protection BCF Hexavalent Chromium Compliance IH 6 Hexavalent Chromium IV Program

24 Environmental, Health, and No.: BCF Page: 24 of ATTACHMENTS Attachment 1 Attachment 2 Attachment 3 Attachment 4 Attachment 5 Double Block and Bleeds Example BASF Occupational Exposure Limit Reference Value Determination Confined Space Permit Management System Review Checklist Additional Entry Log Form